Place Quick, Inc. — Hazardous Materials Safety Interpretation

Page 1US. Department of Transportation Vashington, D.C. 2059 00 Seventh Street, S.W Research and Special Programs Administratior JUN 1 4 2000 Ms. Dianne Bechtold Ref. No. 00-0164 Place Quick, Inc. .O. Box 68091 Schaumburg, IL 60168-009 Dear Ms. Bechtold: This is in response to your letter dated June 1, 2000, concerning use of certain reflective materials on transport vehicles to communicate hazard warnings specified in the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180). Except for hazard warning labels, placards, and orange panels that must conform to certain color tolerances, general marking requirements in § 172.304(a) of the HMR are prescribed as a performance standard. For example, markings must be durable, in English, displayed on a background of sharply contrasting color, and located away from any other marking that could substantially reduce its effectiveness. With respect to your inquiry concerning the display of a proper shipping name or an appropriate common name on a cargo tank, as specified in § 172.328(b), we believe that requirement may be satisfied through the use of red and white reflective material. The application of this marking in a 4" × 12" rectangle would not be prohibited under provisions of § 172.502(a). If changes to the HMR for labels, placards and other hazard warning instruments constructed of reflective materials are adopted, those changes would be in the form of rules of general applicability. Thus, I must inform you that a grant of exclusive rights to Place Quick, Inc. for the manufacture of labels and placards made from materials proposed in your petition is not a possibility. I hope this information is helpful. Sincerely, omn A. Cellan Director, Office of Hazardous Materials Standards 172.519 000164#

Page 2• PLACE allan QUICK, INC. § 1a519 P.O. Box 68091, Schaumburg, IL. 60163-0091 • Telephone (630) 980-0181 Fax (630) 980-0271 00-0164 June 1, 2000 Dear Mr. Mazzullo, Thank you for your response to my letter dated February 28, 2000 regarding the Diamond Grade plaquards. I am glad to see that a rulemaking session has been added to your agenda concerning this matter. It ha: dissappointed should it be passed and I do not receive exclusive rights for an extended specific period of been almost five years since I asked for an exemption in manufacturing this item. I will however be very adoption into the specifications. time. If it had not been for my diligence in pursuing this matter, it may never have been considered for I would appreciate being given an exemption or exclusive rights (for an extended period of time) after a decision has been made. I would hate to feel that five years of my life have been wasted pursuing this of letters and nothing to show for my efforts. exemption, only to have the large companies step in with their mass production leaving me with a stack inches high and 12 inches wide, made of red and white diamond grade (just like the conspicuity tape) While we are awaiting the rulemaking session, I propose another question. If a rectangle, perhaps 4 intrusion on the plaquards? I feel they would no more interfere with the plaquards as would the large lettered with a word such as "PROPANE" were applied to the side of designated trucks.be considered an company logos applied to every truck. Please consider this option and reply in a timely matter so that I can answer to my customers who have repeatedly asked me to make such signs for their fleets. I await your prompt reply. Sincerely: Draine Becktred Dianne Bechtold 630-483-4041 President cc: Illinois Senator Durbin Illinois Senator Crane Tom Allen Haz-Mat MEMBER FEMALE BUSINESS ENTERPRISE (MAFBE)#