Interpretation Response #22-0015
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Mr. Kurt Colborn
ICE Service Group & SPS Packaging Systems
238 Moon Clinton Road, Suite 200
Moon Township, PA 15108
Reference No. 22-0015
Dear Mr. Colborn:
This letter is in response to your February 23, 2022, email and subsequent phone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the placarding of rail cars. You provide a scenario and photograph in which four freight containers are placed end-to-end lengthwise on a single rail car; however, only one of the four freight containers requires placarding. You state that the freight container which requires placarding is placarded on both sides and both ends; however, both ends are obstructed by the other freight containers in which it is interspersed. You ask whether additional placards must be duplicated on both ends of the single rail car in such a configuration.
The answer to your question is no. Section 172.504 states that "...each bulk packaging, freight container, unit load device, transport vehicle or rail car containing any quantity of a hazardous material must be placarded on each side and each end..." In addition, § 172.516 states that "Each placard on a motor vehicle and each placard on a rail car must be clearly visible from the direction it faces, except from the direction of another transport vehicle or rail car to which the motor vehicle or rail car is coupled. This requirement may be met by the placards displayed on the freight containers or portable tanks loaded on a motor vehicle or rail car." It is the opinion of this Office that for the configuration you describe, there is no need to duplicate additional placards on both ends of the single rail car, since the placards which are currently present—although obstructed by the other freight containers on the single rail car-are facing in the direction of other rail cars to which it is coupled.
Please note that the placards on both sides of the freight container or rail car must remain visible and unobstructed.
I hope this information is helpful. Please contact us if we can be of further assistance.
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
|§ 172.516||Visibility and display of placards|