{"operation":"document","citation":"00-0164","title":"Place Quick, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2000-06-14","effective_on":null,"summary":"00-0164 response to Place Quick, Inc. concerning 172.519.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0164.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0164.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-00-0164","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000164.pdf","body":"<<<PAGE 1>>>\n\nUS. Department\nof Transportation\nVashington, D.C. 2059\n00 Seventh Street, S.W\nResearch and\nSpecial Programs\nAdministratior\nJUN 1 4 2000\nMs. Dianne Bechtold\nRef. No. 00-0164\nPlace Quick, Inc.\n.O. Box 68091\nSchaumburg, IL 60168-009\nDear Ms. Bechtold:\nThis is in response to your letter dated June 1, 2000, concerning use of certain reflective materials on\ntransport vehicles to communicate hazard warnings specified in the Hazardous Materials Regulations\n(HMR; 49 CFR parts 171-180).\nExcept for hazard warning labels, placards, and orange panels that must conform to certain color\ntolerances, general marking requirements in § 172.304(a) of the HMR are prescribed as a performance\nstandard. For example, markings must be durable, in English, displayed on a background of sharply\ncontrasting color, and located away from any other marking that could substantially reduce its\neffectiveness. With respect to your inquiry concerning the display of a proper shipping name or an\nappropriate common name on a cargo tank, as specified in § 172.328(b), we believe that requirement\nmay be satisfied through the use of red and white reflective material. The application of this marking in a\n4\" × 12\" rectangle would not be prohibited under provisions of § 172.502(a).\nIf changes to the HMR for labels, placards and other hazard warning instruments constructed of\nreflective materials are adopted, those changes would be in the form of rules of general applicability.\nThus, I must inform you that a grant of exclusive rights to Place Quick, Inc. for the manufacture of\nlabels and placards made from materials proposed in your petition is not a possibility.\nI hope this information is helpful.\nSincerely,\nomn\nA. Cellan\nDirector, Office of Hazardous\nMaterials Standards\n172.519\n000164\n\n<<<PAGE 2>>>\n\n•\nPLACE\nallan\nQUICK, INC.\n§ 1a519\nP.O. Box 68091, Schaumburg, IL. 60163-0091 • Telephone (630) 980-0181 Fax (630) 980-0271 00-0164\nJune 1, 2000\nDear Mr. Mazzullo,\nThank you for your response to my letter dated February 28, 2000 regarding the Diamond Grade\nplaquards.\nI am glad to see that a rulemaking session has been added to your agenda concerning this matter. It ha:\ndissappointed should it be passed and I do not receive exclusive rights for an extended specific period of\nbeen almost five years since I asked for an exemption in manufacturing this item. I will however be very\nadoption into the specifications.\ntime. If it had not been for my diligence in pursuing this matter, it may never have been considered for\nI would appreciate being given an exemption or exclusive rights (for an extended period of time) after a\ndecision has been made. I would hate to feel that five years of my life have been wasted pursuing this\nof letters and nothing to show for my efforts.\nexemption, only to have the large companies step in with their mass production leaving me with a stack\ninches high and 12 inches wide, made of red and white diamond grade (just like the conspicuity tape)\nWhile we are awaiting the rulemaking session, I propose another question. If a rectangle, perhaps 4\nintrusion on the plaquards? I feel they would no more interfere with the plaquards as would the large\nlettered with a word such as \"PROPANE\" were applied to the side of designated trucks.be considered an\ncompany logos applied to every truck. Please consider this option and reply in a timely matter so that I\ncan answer to my customers who have repeatedly asked me to make such signs for their fleets.\nI await your prompt reply.\nSincerely:\nDraine\nBecktred\nDianne Bechtold\n630-483-4041\nPresident\ncc: Illinois Senator Durbin\nIllinois Senator Crane\nTom Allen Haz-Mat\nMEMBER FEMALE BUSINESS ENTERPRISE (MAFBE)","truncated":false,"body_characters":3684}