Interpretation Response #24-0056
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: J. J. Keller & Associates, Inc.
Individual Name: Mr. Michael Atkinson
Location State: WI Country: US
View the Interpretation Document
Response text:
August 29, 2024
Mr. Michael Atkinson
Editor-Hazardous Materials Trans
J. J. Keller & Associates, Inc.
P.O. Box 368
Neenah, WI 54957-0368
Reference No. 24-0056
Dear Mr. Atkinson:
This letter is in response to your June 19, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the visibility and display of placards. Specifically, you ask whether a placard holder that your company produces would be considered similar to the recommended placard holder displayed in Appendix C to Part 172 based on drawings you have provided of the holder. You state that you have received feedback from customers who used a previously produced placard holder that the placards would get stuck and would be ripped, torn, or bent—rendering them unusable; therefore, your company modified the placard holder to include finger indentations to allow the user to push and pull the placard with their fingers to reduce damage. You also included a picture of your proposed placard holder in use.
As stated in § 172.516(d), the means used to attach a placard may not obscure any part of its surface other than the borders except for a placard holder similar to that in Appendix C to Part 172. It is the opinion of this Office that based on the picture of the placard holder you have provided (along with the drawings), the placard holder would be acceptable because it is similar to the placard holder provided in Appendix C to Part 172.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Eamonn Patrick
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.516(d)
Regulation Sections
| Section | Subject |
|---|---|
| 172.516 | Visibility and display of placards |