Department of Public Safety — Hazardous Materials Safety Interpretation

Page 1.. . • .S. Departmen 400 Seventh St., S.W. Research and f Transportatio Washington, D.C. 20590 pecial Program dministratio AUG - | 2000 Mr. C.D. Lavender Ref. No. 00-0192 S.C. State Police Transport Police Hazardous Material Unit Department of Public Safety 800 Dutch Square Boulevard Columbia, SC 29210 Dear Mr. Lavender: This is in response to your letter of July 3, 2000 requesting clarification regarding the placement of a placard on a tender (left - highway side) of a cargo tank motor vehicle. You state that the placard is displayed at approximately a 45 degree angle and is approximately 12 to 18 inches rearward of the front of the cargo tank motor vehicle. You ask if this display is in compliance with the requirements of the Hazardous Materials Regulations (49 CFR 171-180). The answer to you question is no. As provided by § 172.504(a) "each bulk packaging, ...transport vehicle, or rail car containing any quantity of hazardous materials must be placarded on each side and each end with the placard specified ...." A placard displayed on a fender 12 to 18 inches rearward of the front of the cargo tank motor vehicle does not meet this requirement because there is no placard displayed on the front end of the cargo tank. I hope this satisfies your inquiry. Sincerely, Nilm Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172.516 000192 2P405025#

Page 2US Department of Transportation 400 Ji St. S.W. Research and Special Programs Administration July 3, 2000 BilliNgs Washington D.C. 20590 5172-546504 00-0192 Dear Sir; In the situation of a truck-tractor pulling a cargo tank vehicle, containing a hazardous material (highway side) of the cargo tank, at approximately a 45 degree angle, approximately 12 to 18 inches which requires marking/placarding. May the front placard/l.D.# be displayed on a fender on the left rearward of the front head, instead of being displayed on the actual front of the cargo tank vehicle. Will this method of display meet the visibility/display requirements of 172.516 (a) ? S.C. State Transport Police C.D. Lavender Hazardous Material Unit 800 Dutch Square Blvd. Dept. of Public Safety Dutch Plaza, Room 205 Columbia, S.C. 29210#