{"operation":"document","citation":"00-0069","title":"Place Quick, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-05-02","effective_on":null,"summary":"00-0069 response to Place Quick, Inc. concerning 172.519.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0069.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0069.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0069","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000069.pdf","body":"<<<PAGE 1>>>\n\n400 Seventh Street. SW\nWashington, D.C.\n20590\nMAY - 2 2000\nMs. Dianne Bechtold\nRef. No. 00-0069\nPlace Quick, Inc.\nP.O. BOx 68091\nSchaumburg, IL\n60168-0091\nDear Ms. Bechtold:\nThis is in response to your letter dated February 28, 2000,\nconcerning use of Scotchlitem Reflective Sheeting Diamond Grade\nreflective materials for labels and placards used to\ncommunicate warnings posed by hazardous materials in\ntransportation.\nopinion of this office that the placards you submitted for our\nIn a letter dated May 7, 1996, we advised that it is the\nreview do not meet the requirements specified for placards in\n§ 172.519 of the Hazardous Materials Regulations (HMR; Title 49\nCFR parts 171-180). Specifically, we stated, in part, that the\nplacard colors (including red) do not fall within prescribed\ntolerances. You now ask whether a carrier may voluntarily\ndisplay a placard made from the non-conforming color materials,\nif a placard that fully conforms to all requirements in the HMR\nis displayed also.\nAs § 172.502 (a) (1) (iii) prohibits the\ndisplay of any placard that does not conform to requirements of\nthe HMR, you may not supplement the display of conforming\nplacards with additional placards that do not conform to\ncurrent standards.\nCurrently, this office is considering whether to propose a\ndifferent standard for labels, placards and other hazard\nwarning instruments constructed of retroreflective materials.\nconforming to ASTM D\nSpecifically, we are focusing on white and red Type V sheeting\n4956, Standard Specification for\nRetroreflective Sheeting for Traffic Control.\nThis is the\n172519\n000069\n\n<<<PAGE 2>>>\n\nAdministration\nstandard referenced by the National Highway Traffic Safety\napplicable to certain truck tractors and trailers.\nin 49 CFR 571.108 for conspicuity systems\nAdministration in Docket No. RSPA-99-5005 (HM-206B), Hazard\nis being addressed by the Research and Special Programs\nCommunication Requirements -- Petitions for Rulemaking and\nMiscellaneous Amendments.\nWe will advise you when a notice of\nproposed rulemaking is\nissued in this docket.\nI hope this information is helpful.\nSincerely,\nelend Mazelle\n‚dward T. Mazzul]\nDirector,\nOffice of Hazardous\nMaterials\nStandards\n\n<<<PAGE 3>>>\n\nCalicen\nPLACE\n$n2.519\nQUICK, INC.\n00 - 0069\nP.O. Box 68091, Schaumburg, IL 60168-0091 • Telephone 4630198\n530) 980-0271\nFebruary 28, 2000\nDear Mr. Mazullo;\nI am sure you remember all of the letters that have been back and forth between our\noffices during the past four and a half years concerning the exemption 1 have filed for\nDiamond Grade plaguards. I am only corcerned with the red and white plaquards to be\nused on \"dedicated\" trucks.\ninsists that I get a ruling. He would like to put the Diamond Grade plaquards on \"in\nI talked with Tom Allen about 3 weeks ago and asked another question. My customer\naddition to \" the paper plaquards. He too insists that the paper plaquards are no longer\n\"white\" after the truck has been washed. If companies are ailowed to custom letter the\ntrucks without interfering with the paper plaquards, then reflective plaquards would not\ninterfere with the paper plaquards.\nI am awaiting the ruling meeting concerning the exemption, but would like a written\nreply as to an answer on this new question.\nIf you have any questions, please contact me between 10:00 am and 5pm Monday\nthrough Friday.\nI am under the assumption that\nthe ruling meeting is being planned and wish to be\nnotified of the date and time, so I may arrange my schedule so that I might attend.\nYour prompt reply would be greatly appreciated.\nSincerely,\nBechtald\nDianne Bechtold\n630-483-4041\nCC\nSenator Richard Durbin\nRep. Philip Crane\nTom Allen","truncated":false,"body_characters":3669}