{"operation":"document","citation":"15-0224","title":"Schneider National Bulk Carriers — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2016-01-11","effective_on":null,"summary":"15-0224 response to Schneider National Bulk Carriers concerning 172.516, 172.519.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0224.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0224.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0224","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2016/150224.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nJAN 1 1 2016\nMs. Shannon Schick\nBulk Hazardous Materials Manager\nSchneider National Bulk Carriers\n1555 Glory Road\nGreen Bay, WI 54304\nRef. No.: 15-0224\nDear Ms. Schick\nThis responds to your letter dated November 17, 2015, requesting clarification on whether\naffixing placards to a motor vehicle with tape satisfies the requirements of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180). In your letter you enclose a picture\nand describe a method of affixing placards by placing duct tape along the outer borders of a\nplacard in which the tape covers only the border of the placard and does not obscure any part\nof the surface other than the borders.\nThe method described in your email and the picture is an acceptable method of affixing a\nplacard provided the placard is securely attached or affixed (see§ 172.516(c)(l)). Also, the\nHMR require a placard to be affixed to a background of contrasting color or have a dotted or\nsolid line outer border which contrasts with the background color (see§ 172.51.6(c)(7)). The\ndotted line border is not part of the placard specification. However, a dotted or solid line\nouter border may be used when needed to indicate the full size of a placard that is part of a\nlarger format or is on a background of a non-contrasting color (see 172.519(b )(2)).\nI hope this answers your inquiry. If you need additional assistance, please contact the\nStandards and Rulemaking Division at (202) 366-8553.\nSincerely,\n~~A- c-py:_~\nDuane A. Pfund r\nInternational Standards Coordinator\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nGoodall, Shante CTR (PHMSA)\nFrom: Geller, Shelby CTR (PHMSA)\nSent:\nTo:\nSubject:\nAttachments:\nThursday, November 12, 2015 12:22 PM\nHazmat Interps\nFW: Request for Interpretation\nFullSizeRender jpg\nDear Shante and Alice,\nForwarded is a request for a letter of interpretation. Ms Schick spoke with Eamonn Patrick in the info center.\n-\nThanks,\nShelby\nFrom: Schick, Shannon [mailto:SchickS@schneider.com]\nSent: Wednesday, November 11, 2015 12:30 PM\nTo: INFOCNTR (PHMSA)\nSubject: Request for Interpretation\nGood Afternoon,\nI'd like to request an interpretation in reference to 172.516, specifically around visibility and display of the\nplacards. While placard holders are typically considered the best means of securing a placard to a trailer we periodically\nfind that we are in a situation where we must display multiple placards and do not have available placard holders for all\nof them and self-adhesive placards aren't immediately available. That said, it was industry practice some years ago to\nsecure them to the trailer using duct tape on the outer boundary of the placards. Some years ago we started receiving\nwarnings and violations for doing this.\nTo clarify the tape is only on the outer boundary and would not come in to contact with the separation line leading to\nthe 'inner-workings' of the placard (please refer to attached picture). At such time we were advised that clear duct tape\nwould be an acceptable alternative so we started using that (I will add at a much higher cost than standard duct\ntape). To be fair, clear duct tape isn't a fully accurate description as its not perfectly transparent like clear packing\ntape. Clear packing tape however does not hold up well with any dirt, moisture, or wind and you will now likely find\nyourself in violation due to missing placards without the use of a tape with a more robust adhesive.\n172.516(d)\n(d) Recommended specifications for a placard holder are set forth in appendix C of this part. Except for a placard holder\nsimilar to that contained in appendix C to this part, the means used to attach a placard may not obscure any part of its\nsurface other than the borders.\nAfter reviewing this section it seemed like we are operating within the regulations regardless of the color of the tape\nitself provided the tape does not exceed or touch the boundary line separating the innter & outer portions of the\nplacard. Is this an acceptable practice to follow or are their alternative options outside of the above referenced options\nthat can help us maintain compliance with the requirements of this section?\nYou can reach me by email or mail, mailing address below.\nMailing Address:\nSchneider National Bulk Carriers\nAttn: Shannon Schick\n1\n\n<<<PAGE 3>>>\n\n1555 Glory Road\nGreen Bay, Wi 54304\nThanks in advance,\nShannon Schick\nBulk Hazardous Materials Manager\nSchneider National Bulk Carriers\n920-592-5048\nMailstop: US.GRB.02.01.04\n2\n\n<<<PAGE 4>>>\n\n1993","truncated":false,"body_characters":4629}