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Interpretation Response #99-0048 ([Georgia Public Service Commission] [Captain Bruce Bugg])

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

Interpretation Response Details

Response Publish Date:

Company Name: Georgia Public Service Commission

Individual Name: Captain Bruce Bugg

Location State: GA Country: US

View the Interpretation Document

Response text:

MAY 6, 1999


Captain Bruce Bugg                                                       Reference No. 99-0048
Hazardous Materials Specialist
Georgia Public Service Commission
47 Trinity Avenue, SW
Atlanta, GA 30354-5701

Dear Captain Bugg:

This is in response to your letter of February 17, 1999, regarding clarification of 172.504 and 172.516 under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you
ask whether mounting the front or rear placard on the fenders of cargo tanks, even with the front of the cargo tank to as much as 24 inches from the end of the tank satifies the requirements of § § 172.504 and/or 172.516.

The answer is no. Section 172.504 states that a transport vehicle must be placarded on each side and each end. A placard located on the tank fender that “faces” the front of the tank is not "on" the front end, and therefore, the placard does not comply with 172.504. Additionally, the location of the placard does not satisfy the visibility requirements of 172.516(a).

I hope this answers your inquiry. If we can be of further assistance, please contact us.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.504 General placarding requirements