Landstar Transportation Logistics — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, SE Washington, D.C. 20590 ~~AY 13 2010 Mr. WesPace Director, Hazmat Compliance Landstar Transportation Logistics 13410 Sutton Park Drive, South Jacksonville, FL 32224 Ref. No. 10-0075 Dear Mr. Pace: This responds to your April 14, 2010 request for clarification ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your scenario involves a flatbed trailer with mUltiple pallets ofnonbulk packages (e.g., 5 gallon pails) that have been individually shrink wrapped and properly secured to a transport vehicle. Specifically, you ask whether the requirements in § 172.516 are met ifthe required placards (adhesive backed) are placed on the shrink wrapped pallets so that the placards are visible from all four sides ofthe transport vehicle. The required placards may be attached or affixed to the load ofpackages instead ofthe truck itself. However, the shipment must conform to all the display and visibility requirements. Each placard must be readily visible from the direction it faces except when the vehicle is attached to another motor vehicle (§ 172.516(a». The required placards must be securely attached or affixed to the load of packages, and they must be located clear of appurtenances and devices (e.g. ladders, pipes, doors, and tarpaulin). The placards must also be affixed to a background of contrasting color or have a dotted or solid line outer border which contrasts with the background color (§ 172.516(c). I hope this answers your inquiry. If you need additional assistance, please contact this Office. Sincerely, ~~ Charles E. Betts . ef. Standards Development Office ofHazardous Materials Standards#

Page 2IANDSTAR. i londstar Transporllllion logistics, Inc. 13410 Suffon Park Drive, SouIb JDCksonvil/e, FL 32224 ~~e. ~ 17Z · ~/(P • 904 398 9400 P(acar-d, n:J lD"0015 U.S. DOT PHMSA Office of Hazardous Materials Standards Attn: Mr. Edward Mazzullo East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 Mr. Mazzullo, Please except this letter as my request for an interpretation of49CFR 172.516 (Visibility and Display of Placards). Specifically, I'm requesting clarification on the use of placards on shrink wrapped pallets of non-bulk packages on a flat bed to meet the transport vehicle placard requirements. The scenario is, a flatbed trailer with multiple pallets of non-bulk packages (5 gallon pails for example) which have been individually shrink wrapped and are properly secured on the transport vehicle. Would the requirements of 172.516 be met ifthe required placards (adhesive backed) were placed on the shrink wrap of pallets in a manner where placards are visible from all four side of the transport vehicle? There is no specific reference to this scenario in 172.516 (c) and it would seem as though the intent of the rule would be met when a transport vehicle had been placarded in the method described. Your assistance is greatly appreciated. Sincerely, Wes Pace Director, Hazmat Compliance Landstar Transportation Logistics (904) 390-4815 wpace[al,landstar.com Providing Supply Chain Solutions and Complete Global &Domestic Transportation Services#