Texkota Transit, LLC — 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 MAY 0 9 2013 Mr. HC Brown Manager Texkota Transit, LLC P.O. Box 2001 Kilgore, TX 75663 Ref. No.: 13-0086 Dear Mr. Brown: This is in response to your April 24, 2013 email, concerning the display of placards on motor vehicles. You asked whether the display of two-sided placard affixed on the crossbar of a headache rack (approximately six inches behind and even in height with the cab), with one placard visible from the front, one from the rear, would comply with the placarding requirements of the Hazardous Materials Regulations (HMR; 49 CFR Patis 171-180 ). The answer to your question is no. When placarding is required by§ 172.504 ofthe HMR, a transport vehicle must be placarded "on each side and each end." The placarding scenario that you describe in your letter does not meet the requirement in§ 172.504 for placarding on each side and each end of a transport vehicle. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, !Uaff· Delmer Billings Senior Regulatory Advisor Standards and Rulemaking Division#

Page 2Drakeford, Carolyn (PHMSA) From: Sent: To: Subject: INFOCNTR (PHMSA) Friday, April 26, 2013 2:30 PM Drakeford, Carolyn (PHMSA) FW: 172.516 Placarding Hi Carolyn, This caller requested we submit his e-mail as a formal letter of interpretation. Thanks, Victoria From: Texkota Transit [mailto:texkotatransitllc@yahoo.com] Sent: Wednesday, April 24, 2013 4:10PM To: INFOCNTR (PHMSA) Subject: 172.516 Placarding I plan to operate a Dodge Crew Cab 5500 single axle vehicle with an 11' flat bed. I have a headache rack that is approximately 6" behind the cab and the height is even with said cab. According to regulation 172.516 paragraph (a) "each placard must be clearly visible from the direction it faces" My desire is to affix a two sided placard(s) on the cross bar of the headache rack with one side facing forward and the other side facing the rear. The visibility from both directions would be greatly enhanced and protection of the placard(s) from road debris, mud, and unfortunate incidents with other vehicles would be more secure. Your consideration and hopefully positive interpretation is greatly appreciated. HC Brown Manager Texkota Transit, LLC P.O. Box 2001 Kilgore, Texas 75663 Office (903) 984-1961 Fax (903) 984-0946 Cell (903) 241 5222 1#