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Interpretation Response #20-0003

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

Interpretation Response Details

Response Publish Date:

Company Name: Texas Department of Public Safety

Individual Name: Corporal Casey Jones

Location State: TX Country: US

View the Interpretation Document

Response text:

April 17, 2020

Corporal Casey Jones
Texas Department of Public Safety
Texas Highway Patrol – Commercial Vehicle Enforcement
600 W. Kilpatrick
Cleburne, TX  76033

Reference No. 20-0003

Dear Corporal Jones:

This letter is in response to your January 16, 2020, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding. Specifically, you ask about the proper location for placards for compliance with the placement and visibility requirements in §§ 172.504 and 172.516.

We have paraphrased and answered your questions as follows:

Q1. You provided pictures in which a placard is displayed on the front face of the cargo tank portion of a truck (visible from the front on one side), and displayed on the "headache rack" of flatbed trucks, instead of the cab portion of the transport vehicle. You ask whether the front placard must be attached to the front of a unit truck (i.e., grille or front bumper).

A1. The answer is no. The HMR do not limit the placement of the front placard to the truck cab; placement on the tank portion of the truck is appropriate and placement on a "headache rack" is acceptable (see Letter Ref. No. 19-0124), so long as it is visible when facing the front of the truck. However, we have concerns that the placement of the placard shown in the picture of the bobtail truck you submitted does not appear to fully meet the visibility requirements, as the placard is obscured by the truck's mirror and appears to be visible from only one side of the truck. Although, from the picture alone, we cannot tell if there is another placard on the opposite side of the cab.

Q2. You ask whether side placards must be placed on the outermost edge of a vehicle or what distance inward from the outermost edge is appropriate for side placards.

A2. The answer is no; appropriate placard placement is not limited to the outermost edge of the truck. The HMR do not specify a distance from the edge of the side of a transport vehicle at which a placard is required; any location that satisfies the conditions of § 172.516 is suitable for placard placement.

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, 172.516,

Regulation Sections

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