Interpretation Response #22-0106
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
December 12, 2022
Environmental Health and Safety Manager
115 Jacobus Avenue
Kearny, NJ 07032
Reference No. 22-0106
Dear Mr. Prevosti:
This letter is in response to your October 6, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to prohibited display of placards. Specifically, you ask whether a flip placard displaying "blank" white panels constitutes prohibited placarding in accordance with § 172.502(a)(2). When turned to the "blank" side, a flip placard maintains the square-on-point design (i.e., shape of a placard) but does not display any hazard communication information.
The answer is no, display of a "blank" white flip placard does not constitute prohibited placarding. Similarly, an empty placard holder frame also does not constitute prohibited placarding.
I hope this information is helpful. Please contact us if we can be of further assistance.
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
|§ 172.502||Prohibited and permissive placarding|