{"operation":"document","citation":"16-0166","title":"Halliburton — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-01-12","effective_on":null,"summary":"16-0166 response to Halliburton concerning 172.504, 172.516.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0166.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0166.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0166","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2017/160166.pdf","body":"<<<PAGE 1>>>\n\n43/3 s. Loop 1604 E.\nElmendorf, TX 78114\nReference No. 16-0166\nDear Mr. Vandeaver:\nThis letter is in response to your October 12, 2016, letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding. You\ndescribe in your letter a scenario where a pickup truck with a trailer attached contains an amount\nof hazardous materials that requires placarding. Specifically, you ask whether the front of the\npickup truck may be placarded to satisfy the front placard requirement prescribed in\n§ 172.504(a).\nThe answer is yes. Except as otherwise provided by the HMR, each bulk packaging must be\nplacarded on each side and each end with the type of placards specified in Tables 1 and 2 of\n§ 172.504(e). However, as authorized in § 172.516(b), the required placarding of the front of a\nmotor vehicle may be on the front of a truck-tractor instead of or in addition to the placarding on\nthe front of the cargo body to which a truck-tractor is attached. Therefore, the placarding\nscenario you describe in your letter is authorized by the HMR.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nPlease submit this as a letter of interpretation. I spoke with Mr. Vandeaver.\nPlease let me know if you have any questions.\nThanks,\nJordan\nFrom: Albert Vandeaver [mailto:Albert. Vandeaver@halliburton.com]\nSent: Wednesday, October 12, 2016 3:42 PM\nTo: INFOCNTR (PHMSA)\nCc: Albert Vandeaver\nSubject: Request for clarification\nSee attachment regarding clarification of placarding regulation.\nThanks,\nAlbert R. Vandeaver\nHalliburton HRD\nOffice # 210-621-1815\nMobile # 210-400-9948\nThis e-mail, including any attached files, may contain confidential and privileged information for the sole use of\nthe intended recipient. Any review, use, distribution, or disclosure by others is strictly prohibited. If you are not\nthe intended recipient (or authorized to receive information for the intended recipient), please contact the sender\nby reply e-mail and delete all copies of this message.\n\n<<<PAGE 3>>>\n\nThis is in regards to a question of placard placement on a pickup/trailer combination. The\npickup is attached to a trailer that is carrying hazardous materials (placardable amount), and\nthe driver places the placard on the front of the pickup, as opposed to the front of the trailer.\nThe other three sides of the trailer are appropriately placarded. From my take on 172.516(b),\nthe regulation specifically addresses a placard may be placed \"on the front of the cargo body to\nwhich a truck-tractor is attached.\"\nAn assistance you may provide in clarification would be greatly appreciated.\nSincerely,\nasht R. Vonseou\nAlbert R. Vandeaver","truncated":false,"body_characters":2849}