Midwest Meter, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Materials Safety Pipeline and Hazardous Administration JUL 2 3 2014 Mi. Marcus Kofoot Midwest Meter, Inc. P.O. Box 376 Hampton, IA 50441 Ref No.: 14-0087 Dear Mr. Kofoot: This is a response to your April 25, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to placard specifications. Specifically, you request clarification on whether a placard may have a white ½ inch border instead of a solid line inner border. In your email you provide examples of your placard design. Provided the placard, including the dimensions of the inner and outer borders conforms to the specifications in § 172.519(c), a white inner border is acceptable. In the example you provide, the inner border is a solid line. As stated in § 172.519(d)(4), the placard color must extend to the inner border and may extend to the edge of the placard in the area designated on each placard except the color on the CORROSIVE and RADIOACTIVE placards (black and yellow, respectively) must extend only to the inner border. I hope this information is helpful. If you have any more questions, please do not hesitate to contact this office. Sincerely, Rho Bulat Robert Benedict Chief, Standards Development Standards and Rulemaking Division#

Page 2Suchak Drakeford, Carolyn (PHMSA) 3172.519 From: Sent: INFOCNTR (PHMSA) To: Monday, April 28, 2014 12:03 PM Placarding Drakeford, Carolyn (PHMSA) Subject: FW: Hazardous Placard Regulation Inquiry 14-0087 Hi Carolyn, This caller requested we submit this e-mail as a formal letter of interpretation. Thanks, Victoria From: Marcus Kofoot - Midwest Meter Inc. [mailto:mkofoot@midcomcorp.com] To: INFOCNTR (PHMSA) Sent: Friday, April 25, 2014 5:27 PM Subject: Hazardous Placard Regulation Inquiry Attn. office of the Department Of Transportation, Washington D.C., I am writing in regards to CFR § 172.519 (c) and CFR § 172.519 (d)(4) the regulations regarding the border of hazardous materials transportation placards. The code states in section (c) that the placard "must have a solid line inner border approximately 12.7 mm (0.5 inches) from edge" as it appears in my first example below. I have placards that look like my second example. Every dimension is exactly the same but the ½" border surrounding the placard is white. Is this admissible, in relation to section (4) which states "The placard color must extend to the inner border and may extend to the edge of the placard"? Thank you for your consideration, 1005 1005 2 Best regards, Marcus Kofoot Midwest Meter, Inc. P.O. Box 376 Hampton, IA 50441 Fax: 641-456-4600 Phone: 641-456-5205 1#