AMCOM, U.S. Army Garrison — Hazardous Materials Safety Interpretation

Page 1JUN 2 3 2006 400 Seventh Street, S.W. Washington, D.C. 20590 ipeline anc laministratinterials Safet Mr. Richard E. Eads Reference No. 05-0309 Ammunition Surveillance (QASAS) Quality Assurance Specialist AMCOM, U.S. Army Garrison Redstone Arsenal, Al 35898-5000 Dear Mr. Eads: This is in response to your letter requesting clarification on the correct display of placards on the front of a tractor-trailer motor vehicle under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the placard must appear on the the delay in responding and any inconvenience this may have caused. front of the truck's tractor or if it may appear on the front of its trailer. We apologize for When placarding is required by § 172.504(a) of the HMR, a transport vehicle must be placarded on each side and each end. The HMR require a placard to be clearly visible it is coupled (see § 172.516(a)). For purposes of the HMR, a "transport vehicle" is a from the direction it faces, except from the direction of another transport vehicle to which cargo-carrying vehicle, such as a van, tractor, trailer, semi-trailer, tank car, or rail car used for the transportation of cargo by any mode. Each cargo-carrying body is a separate transport vehicle. Thus, in the example you cite of a truck tractor with a flatbed trailer, a placard is not required on the front of the truck tractor if the flatbed trailer is placarded on each side and each end, even if the placard on the front of the flatbed trailer is not visible. We appreciate your concern that the exception in § 172.516 could have implications for emergency responders at an accident scene. We considered this issue, that is the visibility of the front placard on the trailer being obscured by the attached tractor, in an advance notice of proposed rulemaking published under Docket No. HM-206 (57 FR stating revisions to the placard visibility requirements were not necessary, we proposed 24532, June 9, 1992). Based on the comments received in response to the ANPRM no revisions in the notice of proposed rulemaking (Docket No. HM-206, 59 FR. 41848, August 15, 1994). Sincerely Hille z mite hel Hattie L. Mitchell, Chief Office of Hazardous Materials Standards Regulatory Review and Reinvention 172.504 172.516 050309#

Page 2Edmonson 8172-516 §172.504 IMSE-RED-LGS-A Placaraint 01 December 2005 15-0300 MEMORANDUM FOR Office of Hazardous Materials Standards, Research and Special Programs Administration SUBJECT: Interpretation of Part 172.504 and 172.516 of 49 CFR a. Request that Parts 172.504 and 172.516 of 49 CFR be made clearer to the layman, specifically regarding placarding of transport vehicles and the ability of the ›lacards to be seen in traffic and by first responders from all directions 2. Proposed language amendment to: a. Subpart 172.504 (a) (1). General. Except as otherwise provided in this subchapter, each bulk packaging, freight container, unit load device, transport vehicle or rail car containing any quantity of a hazardous material must be specified in Tables 1 and 2 of this section and in accordance with placarded on each side and each end with the type of placards specifications for the placards named in the tables and described in other placarding requirements of this subpart, including the detail in subpart 172.519 through 172.560. The placards must be placed so that they are visible from all directions while in transit. b. Subpart 172.516 (b) (1). The required placarding of the front of a motor vehicle may be on the front of a truck-tractor instead of or in addition to the placarding Placarding done to the front of the cargo body must be visible to on the front of the cargo body to which the truck-tractor is attached. the front of the truck-tractor (to which the cargo body is attached), oncoming traffic, particularly first responders. If it is not visible from the truck-tractor must be placarded. 3. My interest in this stems from my 23 years of work and training in the field of HAZMAT shipments. I am required to be recertified every 2 years to be able to ship HAZMAT by all modes of transportation world wide. In the 23 years I have personally been involved in this process I have never heard or seen anything like what took place here at Redstone Arsenal this week. We had a truck-tractor with a flatbed loaded with 1.1 explosive items about to leave our area to head to the West Coast. I arrived at the location of the truck-tractor and noticed that I didn't see any told me he wasn't going to put one explosive placard posted to the front of the vehicle. I spoke with the driver and he#

Page 3IMSE-RED-LGS-A 01 December 2005 on the front because he had one on the front of the trailer. I informed him that it was required to be on the front of the truck-tractor since the one on the front of the trailer was not visible. He proceeded to tell me I was wrong and I needed to call his HAZMAT Trainer. After speaking with his trainer who also informed me I was wrong and that he las been teaching this way of placarding for his company for over 12 years. That is hov experts at the DOT then we need to make it clearer. numerous installations worldwide dealing with the transport of HAZMAT and this is the and training. I can say that I have never had this problem arise before. I have worked at 5. No additional cost will be involved to anyone in this proposed action if implemented 6. No environmental impacts are involved in this proposal. 7. POC is Richard Eads, QASAS, phone (256) 842-9086 RICHARD E EADS Ammunition Surveillance (QASAS) Quality Assurance Specialist GS-1910-11 Garrison- Redstone Arsenal#