J.B, Hunt Transport, INC — Hazardous Materials Safety Interpretation

Page 1U.S. Department 1200 New Jersey Avenue, SE of Transportation Washington, D.C. 20590 Pipeline and Hazardous Administration Materials Safety SEP 2 4 2014 Mr. James Cherry J.B. Hunt Transport, Inc. 615 J B Hunt Corporate Drive Lowell, AR 72745 Ref No. 14-0106 Dear Mr. Cherry: This is a response to your May 30, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to placarding. Specifically, you request clarification on what constitutes substantially reduced placard visibility. In your email, you provide examples of damaged placards. As required by § 172.516(c)(6), each placard on a transport vehicle, bulk packaging, freight container or aircraft unit load device must be maintained by the carrier in a condition so that the format, legibility, color, and visibility of the placard will not be substantially reduced due to damage, deterioration, or obscurement by dirt or other matter. All are considered "substantially reduced" because for each example provided, the format has been substantially reduced. The format of the corrosive placard must be as shown in § 172.558. I hope this information is helpful. If you have any more questions, please do not hesitate to contact this office. Acting Chief, Standards Development Standards and Rulemaking Division#

Page 2Suchak 8172. 516 c6) Drakeford, Carolyn (PHMSA) Placarding Sent: From: INFOCNTR (PHMSA) Subiect: To: Friday, May 30, 2014 4:36 PM 14-0106 FW: Request letter of interpretation - 49 CFR 172.516 (c)(6) Drakeford, Carolyn (PHMSA) Hi Carolyn, This caller requested we submit this e-mail as a formal letter of interpretation. Thanks, Victoria Sent: Friday, May 30, 2014 9:25 AM From: James Cherry@jbhunt.com [mailto:James Cherry@jbhunt.com] To: INFOCNTR (PHMSA) Cc: HAZMAT@jbhunt.com Subject: Request letter of interpretation - 49 CFR 172.516 (c)(6) (6) Be maintained by the carrier in a condition so that the format, legibility, color, and visibility of the placard will not be substantially reduced obscurement by dirt or other matter; due to damage, deterioration, or To whom it may concern: I am looking for clarification on what constitutes "substantially reduced" visibility of the placard due to factors such as damage from road debris or weather. The way I train drivers is that any damage can interpreted as "substantial," and the DOT allows inspectors wide latitude in enforcing the regulation; drivers must inspect their placards regularly and repair or replace them if there is any visible damage. On the other hand, if a reasonable person can clearly perceive that it is a hazmat placard, determine the hazard class, etc the case can be made that the placard was provided by the shipper in without adversely impacting safety. good faith, affixed by the driver in good faith and that road damage caused the placard to get out-of-spec, non preventable, Example 1: CORROSIVE Example 2: fail RROSIVE 8 Example 3:#

Page 3CORROSIVE 8 Example 4: CORROSIV 8 Example 5: N3/ Example 6: CORROSIVE Thanks, James Cherry | Hazardous Materials Coordinator | Safety - Compliance J. B. HUNT 479.419.3838 (O) | 479.236.6792 (C) | 479.820.5723 (F) J.B. Hunt Transport, Inc. | What's your nextmove? ™ Single Source | Intermodal | Dedicated | Final Mile | Truckload | LTL | Refrigerated | Flatbed distribution of emails, attachments, or information therein is strictly prohibited Email from J.B. Hunt Transport, Inc. is considered confidential and for use by the intended recipient or entity only. Any unauthorized 2#