# Place Quick, Inc. — Hazardous Materials Safety Interpretation

**Citation:** 00-0069  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2000-05-02

00-0069 response to Place Quick, Inc. concerning 172.519.

## Document text

<<<PAGE 1>>>

400 Seventh Street. SW
Washington, D.C.
20590
MAY - 2 2000
Ms. Dianne Bechtold
Ref. No. 00-0069
Place Quick, Inc.
P.O. BOx 68091
Schaumburg, IL
60168-0091
Dear Ms. Bechtold:
This is in response to your letter dated February 28, 2000,
concerning use of Scotchlitem Reflective Sheeting Diamond Grade
reflective materials for labels and placards used to
communicate warnings posed by hazardous materials in
transportation.
opinion of this office that the placards you submitted for our
In a letter dated May 7, 1996, we advised that it is the
review do not meet the requirements specified for placards in
§ 172.519 of the Hazardous Materials Regulations (HMR; Title 49
CFR parts 171-180). Specifically, we stated, in part, that the
placard colors (including red) do not fall within prescribed
tolerances. You now ask whether a carrier may voluntarily
display a placard made from the non-conforming color materials,
if a placard that fully conforms to all requirements in the HMR
is displayed also.
As § 172.502 (a) (1) (iii) prohibits the
display of any placard that does not conform to requirements of
the HMR, you may not supplement the display of conforming
placards with additional placards that do not conform to
current standards.
Currently, this office is considering whether to propose a
different standard for labels, placards and other hazard
warning instruments constructed of retroreflective materials.
conforming to ASTM D
Specifically, we are focusing on white and red Type V sheeting
4956, Standard Specification for
Retroreflective Sheeting for Traffic Control.
This is the
172519
000069

<<<PAGE 2>>>

Administration
standard referenced by the National Highway Traffic Safety
applicable to certain truck tractors and trailers.
in 49 CFR 571.108 for conspicuity systems
Administration in Docket No. RSPA-99-5005 (HM-206B), Hazard
is being addressed by the Research and Special Programs
Communication Requirements -- Petitions for Rulemaking and
Miscellaneous Amendments.
We will advise you when a notice of
proposed rulemaking is
issued in this docket.
I hope this information is helpful.
Sincerely,
elend Mazelle
‚dward T. Mazzul]
Director,
Office of Hazardous
Materials
Standards

<<<PAGE 3>>>

Calicen
PLACE
$n2.519
QUICK, INC.
00 - 0069
P.O. Box 68091, Schaumburg, IL 60168-0091 • Telephone 4630198
530) 980-0271
February 28, 2000
Dear Mr. Mazullo;
I am sure you remember all of the letters that have been back and forth between our
offices during the past four and a half years concerning the exemption 1 have filed for
Diamond Grade plaguards. I am only corcerned with the red and white plaquards to be
used on "dedicated" trucks.
insists that I get a ruling. He would like to put the Diamond Grade plaquards on "in
I talked with Tom Allen about 3 weeks ago and asked another question. My customer
addition to " the paper plaquards. He too insists that the paper plaquards are no longer
"white" after the truck has been washed. If companies are ailowed to custom letter the
trucks without interfering with the paper plaquards, then reflective plaquards would not
interfere with the paper plaquards.
I am awaiting the ruling meeting concerning the exemption, but would like a written
reply as to an answer on this new question.
If you have any questions, please contact me between 10:00 am and 5pm Monday
through Friday.
I am under the assumption that
the ruling meeting is being planned and wish to be
notified of the date and time, so I may arrange my schedule so that I might attend.
Your prompt reply would be greatly appreciated.
Sincerely,
Bechtald
Dianne Bechtold
630-483-4041
CC
Senator Richard Durbin
Rep. Philip Crane
Tom Allen

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000069.pdf>
- Source ID: `phmsa`
- SHA-256: `4686e626fe26e80706438228f2573fb3401b031f8c7218f83e7e0e703805e455`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-23T07:47:38.517Z
- Document slug: `phmsa-interpretation-00-0069`

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