# CHS Cooperatives — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 02-0263
- **title:** CHS Cooperatives — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2003-03-02
- **effective on:** Not available
- **summary:** 02-0263 response to CHS Cooperatives concerning 172.516.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020263.pdf
**body:**

<<<PAGE 1>>>

of Transportation
U.S. Department
400 Seventh St., S.W.
Research and
Washington, D.C. 20590
Special Programs
Administration
MAR 2 0 2003
Mr. John R. Macpherson
Corp. C Manager
Ref. No. 02-0263
16682B 245th Street
CHS Cooperatives
Mason City, IA
50401
Dear Mr. Macpherson,
This is in response to your September 23, 2002, letter
regarding placarding requirements on a cargo tank motor
vehicle under the Hazardous Materials Regulations (HMR; 49 CFR
photographs you provided, if you are in violation of
Parts 171-180). Specifically, you ask based on the
$ 172.516 (c) (4).
The placards and markings shown in the provided photographs
are
172.516 (c) (4) states that the placard must be located away
not in violation of § 172.516 (c) (4).
Section
from any markings (such
substantially reduce its effectiveness and in any case at
as advertising) that could
displayed next to the placards in the submitted photographs
least 3 inches (76.0mm.) away from such marking. The markings
are required by § 172.328 and Special Provision 13.
markings.
Therefore, § 172.516(c) (4) is not applicable to these
I hope this satisfies your request.
Sincerely,
11808
Transportation Regulations Specialist
Office of Hazardous Materials
Standards
172516
020263

<<<PAGE 2>>>

BAH
CHS
8112.516 (c)4)
COOPERATIVES
placardina
02-0268
Cenex Fleet Service Center
16682B 245" Street
Mason City, IA 50401
Phone: (641) 422-9346
Fax:
641) 422-9348
September 23, 2002
Mr. Edward T Madzulla
US-D.O.I. - RSPA (DHM-10)
Director of Hazardous Material Standards
Washington, DC 20590-0001
00.7th Street
RE: 172.$1560(4) Visibility and display of placards.
Dear Mr. Madzulla;
Be located away from any marking (such as advertising) that could substantially reduce its effectiveness,
Our company is in need of an interpretation of this regulation. This regulation specifically states:
and in any case at least 76.0 mm (3 inches) away from such markings.
capacities of these vessels range from 9200-gallons to 15,200-gallons. We have encountered a problem
We pperate. 350 plus. MC 331 DOT.Cargo transport vessels through out the US and Canada. The
pictures of exactly how we are placarding these vessels. The problem we are encountering is that the label
with the way we are placarding these vessels in Connecticut and Massachusetts. We have enclosed 4
is to close to the placards. The 2 above mentioned states are issuing citations at a fine of $500 for each one
convey a hazard to the public and emergency personnel, we cannot understand how this can reduce the
of these on the vessel. There are 4 per vessel for a total fine of $2000 per unit. Since we are trying to
associated with the products we are transporting. Please give us your departments interpretation, sowe.
effectiveness of the placard and contend that this improves the effectiveness in conveying the hazard
have a clear understanding of this regulation.
Your quick responșe to thiscatter will be-greaily appreciated.
Sincerely:
Phone: (641) 422-9346
Fax:
Cell:
(641) 430-3634,
(641) 422-9348
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