{"operation":"document","citation":"11-0079","title":"Mr. Roger W. Cooper — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-05-03","effective_on":null,"summary":"11-0079 concerning 172.516, 172.519.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0079.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0079.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0079","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110079.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation 1200 New Jersey Ave, SE\nWashington, D.C. 20590\nPipeline and Hazardous Materials\nSafety Administration\nMAY 0 3 2011\nMr. Roger W. Cooper\n8412 Dutch Bethel Road\nFreedom, In. 47431\nReference No.: 11-0079\nDear Mr. Cooper:\nThis responds to your March 30, 2011 letter requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180) applicable to placarding requirements. Specifically,\nyou state in your letter that you have designed a placard holder utilizing a sheet of clear acrylic to\nprotect the placards from damage. You ask whether your placard holder is permissible under the\nHMR so that you may produce this item for commercial sale.\nThis Office does not provide approval for commercial products. However, provided the placard\nitself meets the general specification requirements for placards specified in § 172.519, and the\nplacard holder meets the dimensional specifications in Appendix C to Part 172 and does not\nprevent the placard from meeting the visibility and display requirements specified in § 172.516,\nthe placard holder would be permitted to be used under the HMR.\nI hope this satisfies your inquiry. Please contact us if we can be of further assistance\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nMarch 30, 2011\nMr. Kurt Eichenlaub\nOffice of Hazardous Materials Standards\nPipeline and Hazardous Materials Safety Administration\nUS Department of Transportation\n400 Seventh St, SW\nWashington, DC 20590-0001\nkurt.eichenlaub@dot.gov\nRe: Design Example #1\nThank you for taking the time to talk with me on March 28,2011 at 10:15am in regards to the dimensions\nof the placard holder. What we talked about was the design of the placard holder. I do not want to change\nthe size or shape, I want to improve it. The placards don't stay in the holder, they fly out. The cardboard\nplacards work better until they get wet and then they soften up and fly out. The vinyl placards are hard to\nkeep in the holder as well. So, what I came up with is a design that incorporates a sheet of clear acrylic\nthat is approved by Motor Vehicle Safety Standards ANSI Z26.1. With this product placed at the front of\nthe placard holder and held in place the placards should not fly out. This would save trucking company's\nmoney because they can reuse the placards and drivers would not have to keep extras on the truck to\nreplace the ones that fly out while in route to their destination. It would cut down on the litter on the\nhighways. It would take stress off of the drivers as they are the ones that are ticketed for missing\nplacards. When a driver rolls up in the scale house or for DOT inspection they won't have to worry about\nwhat placard flew off.\nIt is a simple design change of adding a sheet of clear acrylic cut to fit in the original. already approved\nplacard holder. The dimensions would be 10 %\" X 10 %\" and it would fit perfectly in the original placard\nholder.\nAttached are pictures of before and after and you can see there are no significant changes between the\nsize of the two. There will be enough clearance between the frame and the glass that it shouldn't hold any\nwater.\nI sincerely hope that you will take a good hard look at this. It is a step that needs to be taken to eliminate\nthe problem of placards coming out while in route.\nWhat I am asking for is a letter of approval so I can go forward with this design.\nIf you need more information or speCifications, please feel free to contact me bye-mail\nsheilacooper@hughes.net or my cell number 317-372-4472.\nThank you again for your time.\nRespectfully,\nRoger W. Cooper\n8412 Dutch Bethel Road\nFreedom, Indiana 47431\n317-372-4472 cell","truncated":false,"body_characters":3747}