Oak Harbor Freight Lines, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 November 15, 2021 Mr. Jeff McLaughlin Pacific Northwest Safety Supervisor Oak Harbor Freight Lines, Inc. PO Box 1469 Auburn, WA 98071 Reference No. 21-0077 Dear Mr. McLaughlin: This letter is in response to your July 19, 2021, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the visibility and display of placards on highway motor vehicles. Specifically, you attach three photographs and ask whether the placards—as displayed in the photographs—meet the requirements of § 172.516. We have paraphrased and answered your questions with respect to the specific photographs provided as follows: Q1. You ask whether the photograph of the oxidizer placard shows the placard as meeting the requirements of § 172.516(c)(6) for format, legibility, color, and visibility of the placard. A1. The answer is yes. It is the opinion of this Office that the placard displayed in the photograph has not been “substantially reduced” with respect to its format, legibility, color, and visibility. Q2. You further ask whether the oxidizer placard meets the requirements of §§ 172.550 and 172.516(c)(5). A2. The answer is yes. The pictured oxidizer placard appears to meet the placard design requirements of § 172.550 and the formatting requirements of § 172.516(c)(5). The minor offset present in the hinged placard pictured neither adversely impacts the legibility of the word “OXIDIZER” nor the format and color of the placard. Please note that other relevant factors for determining placard compliance, including placard size, cannot be determined from this photograph.#

Page 2Q3. You ask whether the photograph of the flammable placards shows the placards as meeting the requirements of § 172.516(c)(6) for format, legibility, color, and visibility of the placards. A3. The answer is yes. It is the opinion of this Office that the placards displayed in the photograph have not been “substantially reduced” with respect to their format, legibility, color, and visibility. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Patrick From: INFOCNTR (PHMSA) To: Date: Dodd, Alice (PHMSA); Hazmat Interps Subject: FW: Interpretation request Tuesday, July 20, 2021 11:46:36 AM Attachments: Interpretation request.doc 21-0077 Good morning Alice, Please see the request for a letter of interpretation attached. The corresponding images are also attached. The address is listed on the letter head for the interpretation request. Please contact our office with any questions. Thank you, Sarah (HMIC) From: Jeff McLaughlin <Jeff.McLaughlin@oakh.com> Sent: Monday, July 19, 2021 6:14 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Cc: Jeff McLaughlin <Jeff.McLaughlin@oakh.com>; Tom Mueller <Tom.Mueller@oakh.com> Subject: Interpretation request CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Good afternoon, Please see the attached interpretation request and examples. Thank you, Jeff Jeff McLaughlin Pacific Northwest Safety Supervisor Jeff.McLaughlin@oakh.com Phone 509-228-8397/Fax 509-535-0435/Cell 406-899-3085 Oak Harbor Freight Lines, Inc. "Bringing Peace of Mind Since 1916"#