SJ Transportation Co. 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 6 2016 Maureen Levy Poole SJ Transportation Co, Inc. 1176 US Route 40 PO Box 169 Woodstown, NJ 08098 Ref. No. 16-0035 Dear Ms. Poole: This responds to your March 3, 2016 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding. You request clarification on what constitutes substantially reduced placard visibility, as provided in § 172.516. In your email, you provide an example of a placard that is partially obstructed by a placard holder and ask whether this is considered damaged. The answer is no. We do not consider the example placard provided to be damaged. However, we note that the picture you provided shows a placard that does not fit precisely in the placard holder, which appears to be designed according to the placard holder specifications in Appendix C to Part 172. The Dimensional Specifications for Recommended Placard Holder in Appendix C to Part 172 were originally adopted to be consistent with the larger minimum size requirements of 273 mm × 273 mm (or 10¾ in. × 10¾ in.) for placards prior to the publication of final rule HM-218F on July 20, 2011 [76 FR 43510]. The HM- 218F rule reduced the placard minimum size requirements to 250 mm x 250 mm (~ 9¾ in. x 9¾ in.) to harmonize with international standards. The horizontal cross members of the recommended placard holder do not obstruct or cover any of the essential design elements of the original larger minimum size placard (i.e., a 273 mm × 273 mm placard). Yet, if a placard is designed to the current minimum size requirements (i.e., a 250 mm × 250 mm placard), it would not fit precisely in a placard holder strictly designed to Appendix C standards. The specifications in Appendix C are not intended to be fixed and should be adjusted accordingly for consistency with the size of the placard it is intended to hold. Regardless of which size placard is affixed to a transport vehicle, the placard holder used should not obscure the format of the placard.#

Page 2As 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 (emphasis added) by dirt or other matter. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely irk Der Kindere Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Accarone $172.5166)6) Dodd, Alice (PHMSA) Placarding From: Geller, Shelby CTR (PHMSA) 16-0035 Sent: To: Hazmat Interps Wednesday, March 02, 2016 3:46 PM Subject: FW: 49 CFR 172.516 (c)(6) Attachments: 0226160723-00.jpg Dear Shante and Alice, Forwarded is a request for a formal letter of interpretation. Ms Levy spoke with Jordan in the HMIC. Thanks, Shelby From: Maureen Levy [mailto:mlevy@sjtransportation.com] To: PHMSA HM InfoCenter Sent: Tuesday, March 01, 2016 1:28 PM Subject: 49 CFR 172.516 (c)(6) Good Afternoon, I am seeking to gain clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180. Specifically, clarification on what constitutes substantially reduced placard visibility, as referenced in § 172.516. Attached is an example of a placard. Can you please advise if this would be considered damaged? Thank you for your help with this matter. Safe Travels! Maureen Levy Poole Director of HR & Risk Management SJ Transportation Co, Inc. 1176 US Route 40 PO Box 169 Woodstown, NJ 08098 856-769-2741 ext. 125 ~ Phone 856-769-9811 ~ Fax www.sjtransportation.com ~ Website#

Page 4Mission Statement: Relentless pursuit to be the safest most respected transportation provider in North America/Canada; Delivering quality service and solutions that exceed our customers' & employees expectations 2#

Page 5Tank tended = be fled by 3264#