{"operation":"document","citation":"05-0309","title":"AMCOM, U.S. Army Garrison — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-06-23","effective_on":null,"summary":"05-0309 response to AMCOM, U.S. Army Garrison concerning 172.504, 172.516.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0309.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0309.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-05-0309","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2005/050309.pdf","body":"<<<PAGE 1>>>\n\nJUN 2 3 2006\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nipeline anc\nlaministratinterials Safet\nMr. Richard E. Eads\nReference No. 05-0309\nAmmunition Surveillance (QASAS)\nQuality Assurance Specialist\nAMCOM, U.S. Army Garrison\nRedstone Arsenal, Al 35898-5000\nDear Mr. Eads:\nThis is in response to your letter requesting clarification on the correct display of placards\non the front of a tractor-trailer motor vehicle under the Hazardous Materials Regulations\n(HMR; 49 CFR Parts 171-180). Specifically, you ask if the placard must appear on the\nthe delay in responding and any inconvenience this may have caused.\nfront of the truck's tractor or if it may appear on the front of its trailer. We apologize for\nWhen placarding is required by § 172.504(a) of the HMR, a transport vehicle must be\nplacarded on each side and each end. The HMR require a placard to be clearly visible\nit is coupled (see § 172.516(a)). For purposes of the HMR, a \"transport vehicle\" is a\nfrom the direction it faces, except from the direction of another transport vehicle to which\ncargo-carrying vehicle, such as a van, tractor, trailer, semi-trailer, tank car, or rail car\nused for the transportation of cargo by any mode. Each cargo-carrying body is a separate\ntransport vehicle. Thus, in the example you cite of a truck tractor with a flatbed trailer, a\nplacard is not required on the front of the truck tractor if the flatbed trailer is placarded on\neach side and each end, even if the placard on the front of the flatbed trailer is not visible.\nWe appreciate your concern that the exception in § 172.516 could have implications for\nemergency responders at an accident scene. We considered this issue, that is the\nvisibility of the front placard on the trailer being obscured by the attached tractor, in an\nadvance notice of proposed rulemaking published under Docket No. HM-206 (57 FR\nstating revisions to the placard visibility requirements were not necessary, we proposed\n24532, June 9, 1992). Based on the comments received in response to the ANPRM\nno revisions in the notice of proposed rulemaking (Docket No. HM-206, 59 FR. 41848,\nAugust 15, 1994).\nSincerely\nHille z mite hel\nHattie L. Mitchell, Chief\nOffice of Hazardous Materials Standards\nRegulatory Review and Reinvention\n172.504\n172.516\n050309\n\n<<<PAGE 2>>>\n\nEdmonson\n8172-516\n§172.504\nIMSE-RED-LGS-A\nPlacaraint\n01 December 2005\n15-0300\nMEMORANDUM FOR Office of Hazardous Materials Standards, Research and\nSpecial Programs Administration\nSUBJECT: Interpretation of Part 172.504 and 172.516 of 49 CFR\na. Request that Parts 172.504 and 172.516 of 49 CFR be made clearer to the\nlayman, specifically regarding placarding of transport vehicles and the ability of the\n›lacards to be seen in traffic and by first responders from all directions\n2. Proposed language amendment to:\na. Subpart 172.504 (a)\n(1). General. Except as otherwise provided in this subchapter, each\nbulk packaging, freight container, unit load device, transport vehicle\nor rail car containing any quantity of a hazardous material must be\nspecified in Tables 1 and 2 of this section and in accordance with\nplacarded on each side and each end with the type of placards\nspecifications for the placards named in the tables and described in\nother placarding requirements of this subpart, including the\ndetail in subpart 172.519 through 172.560. The placards must be\nplaced so that they are visible from all directions while in transit.\nb. Subpart 172.516 (b)\n(1). The required placarding of the front of a motor vehicle may be on\nthe front of a truck-tractor instead of or in addition to the placarding\nPlacarding done to the front of the cargo body must be visible to\non the front of the cargo body to which the truck-tractor is attached.\nthe front of the truck-tractor (to which the cargo body is attached),\noncoming traffic, particularly first responders. If it is not visible from\nthe truck-tractor must be placarded.\n3. My interest in this stems from my 23 years of work and training in the field of\nHAZMAT shipments. I am required to be recertified every 2 years to be able to\nship HAZMAT by all modes of transportation world wide. In the 23 years I have\npersonally been involved in this process I have never heard or seen anything like\nwhat took place here at Redstone Arsenal this week. We had a truck-tractor with a\nflatbed loaded with 1.1 explosive items about to leave our area to head to the West\nCoast. I arrived at the location of the truck-tractor and noticed that I didn't see any\ntold me he wasn't going to put one\nexplosive placard posted to the front of the vehicle. I spoke with the driver and he\n\n<<<PAGE 3>>>\n\nIMSE-RED-LGS-A\n01 December 2005\non the front because he had one on the front of the trailer. I informed him that it was\nrequired to be on the front of the truck-tractor since the one on the front of the trailer\nwas not visible. He proceeded to tell me I was wrong and I needed to call his HAZMAT\nTrainer. After speaking with his trainer who also informed me I was wrong and that he\nlas been teaching this way of placarding for his company for over 12 years. That is hov\nexperts at the DOT then we need to make it clearer.\nnumerous installations worldwide dealing with the transport of HAZMAT and this is the\nand training. I can say that I have never had this problem arise before. I have worked at\n5. No additional cost will be involved to anyone in this proposed action if implemented\n6. No environmental impacts are involved in this proposal.\n7. POC is Richard Eads, QASAS, phone (256) 842-9086\nRICHARD E EADS\nAmmunition Surveillance (QASAS)\nQuality Assurance Specialist\nGS-1910-11\nGarrison- Redstone Arsenal","truncated":false,"body_characters":5656}