Halliburton — Hazardous Materials Safety Interpretation

Page 143/3 s. Loop 1604 E. Elmendorf, TX 78114 Reference No. 16-0166 Dear Mr. Vandeaver: This letter is in response to your October 12, 2016, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding. You describe in your letter a scenario where a pickup truck with a trailer attached contains an amount of hazardous materials that requires placarding. Specifically, you ask whether the front of the pickup truck may be placarded to satisfy the front placard requirement prescribed in § 172.504(a). The answer is yes. Except as otherwise provided by the HMR, each bulk packaging must be placarded on each side and each end with the type of placards specified in Tables 1 and 2 of § 172.504(e). However, as authorized in § 172.516(b), the required placarding of the front of a motor vehicle may be on the front of a truck-tractor instead of or in addition to the placarding on the front of the cargo body to which a truck-tractor is attached. Therefore, the placarding scenario you describe in your letter is authorized by the HMR. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Please submit this as a letter of interpretation. I spoke with Mr. Vandeaver. Please let me know if you have any questions. Thanks, Jordan From: Albert Vandeaver [mailto:Albert. Vandeaver@halliburton.com] Sent: Wednesday, October 12, 2016 3:42 PM To: INFOCNTR (PHMSA) Cc: Albert Vandeaver Subject: Request for clarification See attachment regarding clarification of placarding regulation. Thanks, Albert R. Vandeaver Halliburton HRD Office # 210-621-1815 Mobile # 210-400-9948 This e-mail, including any attached files, may contain confidential and privileged information for the sole use of the intended recipient. Any review, use, distribution, or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive information for the intended recipient), please contact the sender by reply e-mail and delete all copies of this message.#

Page 3This is in regards to a question of placard placement on a pickup/trailer combination. The pickup is attached to a trailer that is carrying hazardous materials (placardable amount), and the driver places the placard on the front of the pickup, as opposed to the front of the trailer. The other three sides of the trailer are appropriately placarded. From my take on 172.516(b), the regulation specifically addresses a placard may be placed "on the front of the cargo body to which a truck-tractor is attached." An assistance you may provide in clarification would be greatly appreciated. Sincerely, asht R. Vonseou Albert R. Vandeaver#