Interpretation Response #17-0034 ([R&R Trucking, AATCO, NEI] [Mr. David Vargyas])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 05/25/2017

Company Name: R&R Trucking, AATCO, NEI

Individual Name: Mr. David Vargyas

Location State: MO Country: US

View the Interpretation Document

Response text:

May 25, 2017

David Vargyas
Safety Director
R&R Trucking, AATCO, NEI
302 Thunder Road
Duenweg, MO 46841

Reference No. 17-0034

Dear Mr. Vargyas:

This letter is in response to your March 31, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the display of placards in accordance with § 172.516(c)(5). Specifically, you ask what constitutes the text or identification number on a placard to no longer be displayed horizontally. You also provide examples of a variety of placards and ask if they are in compliance with § 172.516(c)(5).

The answer is yes. The examples you provided meet the intent of § 172.516(c)(5). Section 172.516(c)(5) requires that each placard on a transport vehicle, bulk packaging, freight container or aircraft unit load device have the authorized hazard class name or identification number displayed horizontally, reading from left to right. With respect to what constitutes "horizontal," in the absence of defining criteria in the HMR we rely on a standard dictionary definition, which defines horizontal as "parallel to, in the plane of, or operating in a plane parallel to the horizon or to a baseline." Based on this definition, it is the opinion of this Office that the placard text or identification numbers are displayed in a horizontal manner so that they can be read from left to right.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

172.516(c)(5)

Regulation Sections