Brenntag North America, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 1200 New Jersey Avenue, SE Materials Safety Pipeline and Hazardous Administration SEP 1 Y 2016 Bruce Biehl Director of Regulatory Compliance Systems Brenntag North America, Inc. 2000 East Pettigrew St Durham, NC 27703 Ref. No. 16-0069 Dear Mr. Biehl: This responds to your April 18, 2016 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding. You ask whether a placard with a white center block intended for display of identification numbers may remain blank and be used to satisfy the placarding requirements in Subpart F of Part The answer is no. A placard with a blank white space (i.e., white center block) is only authorized for display of identification numbers in conformance with § 172.332(c). If a placard is not used for the display of an identification number, it must conform to the design requirements of § 172.519(b) which does not accommodate a blank white space in the center of the placard. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Ciccarone 172504 Goodall, Shante CTR (PHMSA) placancins From: Geller, Shelby CTR (PHMSA) 16-0069 Sent: To: Monday, April 18, 2016 10:03 AM Hazmat Interps Subject: FW: Placards Dear Shante and Alice, Forwarded is a request for a formal letter of interpretation. Mr. Biehl spoke with Jordan Rivera in the HMIC. Thanks, Shelby From: Bruce Biehl/Mid-South/Brenntag [mailto:BBiehl@brenntag.com] Sent: Monday, April 18, 2016 4:05 AM To: PHMSA HM InfoCenter Subject: RE: Placards Can a placard with the white center block with no numbers i.e. Blank be used in place of a standard placard. In other words, the shipment requires a placard but does not require the use of a numbered placard. The placard holders are permanantly attached to the vehicle that are the ones with the white center field designed for display of the UN number. Can these be used to placard the shipment with the center field blank white not displaying any numbers? Bruce Biehl Director of Regulatory Compliance Systems Brenntag North America, Inc. 2000 East Pettigrew Street Durham, NC 27703 Office 919-281-2932 Mobil 919-604-9156 bbiehl@brenntag.com NOTICE OF CONFIDENTIAL COMMUNICATION This communication and any subsequent electronic communication relating to this matter, including any attachments, constitute an "electronic communication" within the meaning of the Electronic Communications Privacy Act, 18 U.S.C.A. §2510 or any similar law of any other jurisdiction. In addition, this and any subsequent electronic communication, and any attachments, may be subject to the attorney-client privilege or be considered attorney work product. This communication, and any subsequent electronic communication relating to this matter, including any attachments, is CONFIDENTIAL and is intended solely for the addressee(s). If you are not an intended recipient, any use, review, dissemination, or copying of any such communication by you is strictly prohibited. If you believe you have received this or any other electronic communication in error, please do not read, copy, use 1#

Page 3or disclose it to others; also please notify the sender by replying to the communication, and then delete it and all accompanying files from your system. Please verify that you will delete the communication in your reply. Please note that any views or opinions presented in this communication or any subsequent communication, including any attachments, are solely those of the author or sender and do not necessarily represent those of Brenntag or its affiliated companies. Neither Brenntag nor any of its affiliated companies accepts any liability for any damage caused by any virus transmitted by any email or its attachments.#