J. J. Keller & Associates, 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 August 29, 2024 Mr. Michael Atkinson Editor-Hazardous Materials Trans J. J. Keller & Associates, Inc. P.O. Box 368 Neenah, WI 54957-0368 Reference No. 24-0056 Dear Mr. Atkinson: This letter is in response to your June 19, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the visibility and display of placards. Specifically, you ask whether a placard holder that your company produces would be considered similar to the recommended placard holder displayed in Appendix C to Part 172 based on drawings you have provided of the holder. You state that you have received feedback from customers who used a previously produced placard holder that the placards would get stuck and would be ripped, torn, or bent—rendering them unusable; therefore, your company modified the placard holder to include finger indentations to allow the user to push and pull the placard with their fingers to reduce damage. You also included a picture of your proposed placard holder in use. As stated in § 172.516(d), the means used to attach a placard may not obscure any part of its surface other than the borders except for a placard holder similar to that in Appendix C to Part 172. It is the opinion of this Office that based on the picture of the placard holder you have provided (along with the drawings), the placard holder would be acceptable because it is similar to the placard holder provided in Appendix C to Part 172. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Eamonn Patrick Acting Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Larson 24-0056 From: INFOCNTR (PHMSA) To: Dodd, Alice (PHMSA) Cc: Hazmat Interps Subject: FW: Request for Interpretation - Visibility and display of placards Date: Wednesday, June 26, 2024 1:29:35 PM Attachments: image002.png image003.png Placard Holder LOI.pdf Placard Holder Specifications.pdf Hi Alice, Please see the attached interpretation request. Let us know if you need anything, Janaye From: Atkinson, Michael L <MAtkinson@jjkeller.com> Sent: Wednesday, June 19, 2024 3:16 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Request for Interpretation - Visibility and display of placards 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. To whom it may concern, Attached is our request for a formal letter of interpretation regarding the visibility and display of placards. Michael L Atkinson Editor - Hazardous Materials Trans P.O. Box 368, Neenah, WI 54957-0368 matkinson@jjkeller.com | 920-722-2848 Ext. 2830 J. J. Keller & Associates, Inc. | JJKeller.com Confidentiality Warning: This email and any files transmitted with it may be confidential and are intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error, please notify the sender immediately and delete this original message and any copy of it from your computer system. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this email is strictly prohibited. Disclaimer: This email may contain information that is intended to lend technical knowledge and support to the recipient. Laws, regulations, and best practices change, and the#

Page 3observations and comments drawn today may not apply to laws, regulations, or best practices as they may be in the future. Any recommendations made by J. J. Keller staff are offered in strictly an advisory capacity and are not to be construed as legal advice. Recipients seeking legal advice should consult with legal counsel. J. J. Keller & Associates, Inc. P. O. Box 368, Neenah, WI 54957-0368#

Page 4June 19, 2024 Standards and Rulemaking Division Pipeline and Hazardous Materials Safety Administration, Attn: PHH-10 U.S. Department of Transportation East Building 1200 New Jersey Avenue, SE Washington, DC 20590-0001 infocntr@dot.gov Request for Interpretation To whom it may concern, Pursuant to 49 CFR §105.20, this letter is being submitted by e-mail to request an interpretation of the Hazardous Materials Regulations regarding the visibility and display of placards in 49 CFR §172.516(d). Specifically, would the attached placard holder be considered “similar” to the recommended placard holder contained in Appendix C to Part 172, and therefore meet regulatory requirements? Background Through comments and feedback, a top issue our customers face is placards getting stuck in the placard holders. Oftentimes, the placards end up ripped, torn, or bent, rendering them unusable. Our solution was to slightly modify the recommended placard holder to include two half-circle finger indentations that allow the user to both push and pull the placard at the same time to reduce damage. Please see the placard holder image below and the attached placard holder specifications:#

Page 5• Michael Atkinson DOT Hazardous Materials Editor matkinson@jjkeller.com 2#

Page 6D C B A .25 .25 R.25 4 10.8 10.8 4 R.75 3.9 5.0 3.9 3 A A 3 .50 13.9 2 1 REVISIONS REV DESCRIPTION BY DATE ECN A INITIAL RELEASE - - - D .15 OPENING SECTION A-A SCALE 1 : 1 C B DIMENSIONS ARE AFTER PLATING BREAK ALL SHARP EDGES CHAMFER TAPPED HOLES 90° X THD DIA. MACHINED SURFACES ARE 125 RMS THREAD LENGTH = MIN FULL THREADS MATERIAL / FINISH SEE NOTES TOLERANCES UNLESS OTHERWISE SPECIFIED: UNITS: IMPERIAL INT. DATE J. J. KELLER & ASSOCIATES, INC. DRAWN CBC 06/17/2024 .X N/A ANG. .5 ° CHECKED .XX N/A FRAC. 1/16 ENG APPR. TITLE: SLIDE-IN PLACARD HOLDER - INTERPRETATION PROPRIETARY AND CONFIDENTIAL THE INFORMATION CONTAINED IN THIS DRAWING IS TO BE TREATED AS TRADE SECRET AND CONFIDENTIAL TO J. J. KELLER & ASSOCIATES. ANY REPRODUCTION IN PART OR AS A WHOLE WITHOUT THE WRITTEN PERMISSION OF J. J. KELLER & ASSOCIATES IS PROHIBITED. .XXX N/A PROFILE .01 .XXXX N/A INTERPRET GEOMETRIC TOLERANCING PER: ANSI Y14.5-1994 THIRD ANGLE PROJECTION 3D CAD MODEL INFORMATION INFORMATION FOR FORM, FIT AND FUNCTION ARE SPECIFIED. - REFER TO 3D CAD MODEL WHICH IS CONSIDERED BASIC - UNLESS OTHERWISE SPECIFIED: THE PART SUPPLIED TO J. J. KELLER & ASSOCIATES IS SUBJECT TO VALIDATION AGAINST THE 3D CAD MODEL. A DWG. NO. 2302101-001-001-INT REV A SCALE: 1:3 DO NOT SCALE ( ) DRAWING SHEET 1 OF 1 2 1#