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Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 Mr. Rich Kaczynski, CDS Safety Manager A. Duie Pyle Inc. P.O. Box 564 West Chester, PA 19381 Ref. No. 13-0107 Dear Mr. Kaczynski: This responds to your May 15, 2013 email requesting clarification of the carrier information contact requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request that we clarify the provisions of§ 172.606(b)(l) as to acceptable methods to mark the telephone number of the carrier on a transport vehicle containing hazardous materials. You provide photographs in your email (see attached) ofthe FMCSA annual inspection sticker, which includes the telephone number of the motor carrier. You indicate that the sticker is placed on the driver's front side exterior of the trailer. The photographs show that the sticker is on the front exterior near the brake hose and electrical connections. You ask if the location of the sticker on your trailers and telephone number on the FMCSA inspection sticker meets the requirements of§ 172.606(b )(1 ). Yes. The the company telephone number on the FMCSA annual inspection sticker and the placement of the sticker, as shown in the photographs, meets the requirements set forth in § 172.606(b)(l). I hope this answers your inquiry. If you need additional assistance, please contact this office at 202-366-8553. Sincerely, /?~U~ Robert Benedict Chief, Standards Development Branch Standards and Rulemaking Division#
Page 2O'Donnell 3172.606 Drakeford, Carolyn (PHMSA) Emergency Response Intormation From: Sent: INFOCNTR (PHMSA) 13-0107 Subject: To: Friday, May 17, 2013 4:39 PM FW: Request for Letter of Interpretation Drakeford, Carolyn (PHMSA) Hi Carolyn, This caller requested we submit his e-mail as a letter of interpretation. This caller spoke with Mike Pagel in the HMIC on 5/17/13. Thanks, Victoria From: Rich Kaczynski [mailto:rkaczynski@aduiepyle.com] To: INFOCNTR (PHMSA) Sent: Friday, May 17, 2013 2:59 PM Cc: Rich Kaczynski Subject: Request for Letter of Interpretation A. Duie PYLE PEOPLE DELIVER 650 Westtown Road, P.O. Box 564 West Chester, PA 19381-0564 800-523-5020 www.aduiepyle.com May 15, 2013 U.S. Department of Transportation 1200 New Jersey Ave., SE Pipeline and Hazardous Materials Safety Administration Washington, DC 20590 To Whom It May Concern: REQUEST FOR LETTER OF INTERPRETATION: After sending in an initial email question to the Info Center today regarding 172.606(b)(1), I was contacted by a representative from your office and directed to ask for a Letter of Interpretation. I have a question regarding 172.606(b)(1). On the front drivers side radius of our trailers is our trailer FMCSA Annual Inspection sticker(see pictures below). On that sticker is our company name-address-phone number for our company. Does this meet the required location and phone number requirements for when our trailers are separated from its motive power when loaded with hazardous materials? Thank you in advance for your time and input on this question. Any guidance you may give is greatly appreciated and we look forward to your response. Please contact me at rkaczynski@aduiepvle.com or 800-523-5020 x3182 if there is a need for clarification to adequately#
Page 3address these questions. Sincerely, Rich Kaczynski CDS Safety Manager A. Duie Pyle Inc P.O. Box 564 West Chester PA 19381 800-523-5020 Ext: 3182 •• .. .. 2#
Page 4::, . . , ' 1 ' ~ Toll Free 800.523.5020 <A.DuiePYL ... PYLE PEOPLE DEl.lV£11 3#
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