{"operation":"document","citation":"19-0124","title":"Dru Chem Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2020-02-10","effective_on":null,"summary":"19-0124 response to Dru Chem Inc. concerning 172.504, 172.516.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0124.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0124.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0124","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/73411/190124.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPlpellne and Hazardous\nMaterials Safety\nAdministration\nFebruary 10, 2020\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nBill Krause\nDru Chem Inc.\n1329 County Road 358\nP.O. Box 1088\nEl Campo, TX 77437\nReference No. 19-0124\nDear Mr. Krause:\nThis letter is in response to your October 16, 2019, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the visibility and\ndisplay of placards. You explain that your company occasionally transports small loads of\noilfield chemicals using a 1-ton flatbed motor vehicle, which is required to display hazardous\nmaterials placards on all four sides. You provide photographs illustrating the placement of\nplacards mounted to your flatbed vehicle. Instead of facing the forward direction on the front\nportion of the vehicle (e.g., the grill), the placards are mounted on top of the \"headache rack\"\n(i.e., rear of the cab as shown in the photographs provided) and displayed to the front.\nSpecifically, you seek confirmation that having the placards mounted on top of the \"headache\nrack\" and facing forward is permissible in accordance with the HMR.\nYes, based on the photographs you provided, the placards mounted on the \"headache rack\"\nwould be permissible. In accordance with§ 172.504(a), a transport vehicle containing any\nquantity of hazardous materials must be placarded on each side and each end. The display and\nvisibility of that placard must comply with§ 172.516(a), by which each placard must be clearly\nvisible from the direction it faces. The placards on the \"headache rack\" are clearly visible from\nthe direction they face.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nrrk De.., ............ y .... ~en\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nDodd, Alice (PHMSA)\nFrom: INFOCNTR (PHMSA)\nSent:\nTo:\nThursday, October 17, 2019 1:38 PM\nHazmat Interps\nSubject: FW: Placard Interpretation\nHello Alice and lkeya,\nPlease see below for letter of interpretation request. The requester spoke with Sarah and Lynsey in the HMIC. We\nprovided him with letter 13-0086 and said that the regulations do not specify where on the front of the cab the placard\nhas to be, and neither does this letter. According to 172.516 it is based on being clearly visible from the direction it\nfaces. He is deciding to move forward with an LOI to confirm that he can put his placard on a \"headache rack.\"\nPlease contact our office with any questions.\nThank you,\nKathryn, HMIC\nFrom: William Krause [mai1to:wdk49model@yahoo.com]\nSent: Wednesday, October 16, 2019 4:13 PM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nCc: Druchem <druchem@sbcglobal.net>\nSubject: Placard Interpretation\nI am a safety consultant for a company that transports oilfield chemicals. On our larger trucks we\ndon't have a problem but we have a 1 ton flatbed we use on small loads. We have been stopped by\nTexas DPS and advised that our placards are not properly displayed to the front. We mounted 4\nplacards on top of the headache rack displayed to the front. The Trooper said they have to be\nmounted on the front of the vehicle. If we mount them on the front bumper they block the headlights\nand radiator. If we lower them they will drag on the ground. The sides and rear are no problem.\nCould we get something in writing saying this is alright or please offer a solution to our problem.\nThank You,\nBill Krause\nSafety Consultant\nDru Chem Inc.\nP.O. Box 1088\nEICampo, Texas77437\n1329 County Road 358\nEl Campo, Texas\n979-543-6843\n1\n\n<<<PAGE 3>>>\n\nFired\nDOH-3287\n\n<<<PAGE 4>>>\n\n\n\n<<<PAGE 5>>>\n\n\n\n<<<PAGE 6>>>","truncated":false,"body_characters":3702}