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
Nicholas Prevosti
Environmental Health and Safety Manager
Clean Earth
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.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
172.502(a)(2)
Regulation Sections
| Section | Subject |
|---|---|
| § 172.502 | Prohibited and permissive placarding |