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Interpretation Response #99-0282

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

Interpretation Response Details

Response Publish Date: 03-21-2000
Company Name: Montana Highway Patrol    Individual Name: Mr. George McLaughlan
Location state: MT    Country: US

View the Interpretation Document

Response text:

March 21, 2000


Mr. George McLaughlan               Ref  No. 99-0282
Montana Highway Patrol
P.O. Box 201419
Helena, MT 59620-1419

Dear Mr. McLaughlin:

This is in response to your letter and subsequent telephone conversations with Michael Johnsen of my staff concerning the placement of placards on a vehicle under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

You provided a description and photograph of a placard holder under the bed of a trailer, mounted behind the rear-under-ride protection device.  The rear door of the trailer is painted with an elaborate advertising design.  You ask if the location of a placard, as described and shown in the photograph, is in compliance with the HMR.

It is the opinion of this Office that a placard located below the bed of a trailer and behind a rear under­ride protection device significantly reduces the visibility of the placard and allows water, dirt, and other debris to be directed onto the placard.  Display of a placard in such a location does not comply with the provisions in § 172.516. Additionally, if a placard is displayed on the rear door of the vehicle in the photograph, the placard must be displayed away from any marking (including advertising) that could substantially reduce its effectiveness.  The placard must also be affixed to a background of contrasting color, or must have a dotted or solid line outer border which contrasts with the background color (see § 172.516(c)(4) and (7)).  This response has been coordinated with the Federal Motor Carrier Safety Administration Hazardous Materials Unit.

I hope this satisfies your request.



Edward T. Mazzullo
Director, Office of Hazardous
Hazardous Materials Standards


Regulation Sections

Section Subject
§ 172.510 Special placarding provisions: Rail