Approved Fire Protection Company — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety MAR 26 2007 Robert Bailey Ref. No.:07-0058 President Approved Fire Protection Company 114 Saint Nicholas Avenue South Plainfield, NJ 07080 Dear Mr. Bailey: This is in response to your March 9, 2007 letter requesting clarification of the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185) applicable to the Econoline cube van with a clearly visible placard mounted on the front of the cargo body. You visibility and display of placards. Accompanying your letter are photographs of a Ford ask if the van may be placarded on the front portion of the cargo body as depicted in the photos or if it must be placarded on the front grille. Section 172.516(b) allows the required placarding on the front of the motor veh cle to be displayed on the cargo body or grille, provided the it meets the visibility requirement in § 172.516(a). Therefore, the placarding may be placed on the front of the cargo body as depicted in your photographs. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, Chief, Standards Development Office of Hazardous Materials Standards 070058 172.516#

Page 2Supko Page 1 of 1 3172.516 Placarding Jarman, Erin <PHMSA> 07 - 0058 From: Robert Bailey [RBailey@afpnj.com] Sent: Friday, March 09, 2007 11:53 AM To: INFOCNTR <PHMSA> Subject: Request for formal interpretation - Mr. Edward Mazzullo Attachments: Pictures - truck 030.jpg; Pictures - truck 031.jpg; Pictures - truck 033.jpg; N.JSP Examination Report Dear Mr. Mazzullo, The DOT office has directed me to you to request a formal interpretation of the following: Proper placard location for the front of a Ford Econoline cube van. a copy of the Examination Report along with photos of our truck. Their concern was the placement of the front Ne have recently been cited by the New Jersey State Police for improper placarding of our cube van. Attached i placard. As you can see by the photos, the front placard is placed on the box portion of the truck directly over the ab. The NJSP stated we should have placed the placard on the front grille area (per 172.504a). We believe th Are we permitted to place the placard on the front portion of the box as shown in the photo? rille area is not the best location since it would be less visible and inhibit air flow for the cooling of the engine Thank you in advance for your consideration to this matter, Robert Bailey President Approved Fire Protection Company 114 Saint Nicholas Avenue 908-755-2222 Fax: 908-769-1424 South Plainfield, New Jersey 07080-1808 3/9/2007#