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Interpretation Response #19-0124

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

Interpretation Response Details

Response Publish Date:

Company Name: Dru Chem Inc.

Individual Name: Bill Krause

Location State: TX Country: US

View the Interpretation Document

Response text:

February 10, 2020

Bill Krause
Dru Chem Inc.
1329 County Road 358
P.O. Box 1088
El Campo, TX  77437

Reference No. 19-0124

Dear Mr. Krause:

This letter is in response to your October 16, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the visibility and display of placards. You explain that your company occasionally transports small loads of oilfield chemicals using a 1-ton flatbed motor vehicle, which is required to display hazardous materials placards on all four sides. You provide photographs illustrating the placement of placards mounted to your flatbed vehicle. Instead of facing the forward direction on the front portion of the vehicle (e.g., the grill), the placards are mounted on top of the "headache rack" (i.e., rear of the cab as shown in the photographs provided) and displayed to the front. Specifically, you seek confirmation that having the placards mounted on top of the "headache rack" and facing forward is permissible in accordance with the HMR.

Yes, based on the photographs you provided, the placards mounted on the "headache rack" would be permissible. In accordance with § 172.504(a), a transport vehicle containing any quantity of hazardous materials must be placarded on each side and each end. The display and visibility of that placard must comply with § 172.516(a), by which each placard must be clearly visible from the direction it faces. The placards on the "headache rack" are clearly visible from the direction they face.

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

172.504(a), 172.516(a)

Regulation Sections

Section Subject
172.504 General placarding requirements
172.516 Visibility and display of placards