{"operation":"document","citation":"25-0105","title":"Trophy Trucking Services, LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2025-12-09","effective_on":null,"summary":"25-0105 response to Trophy Trucking Services, LLC concerning 172.504, 172.516.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0105.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0105.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0105","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2025-12/250105.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nDecember 9, 2025\nMatt Ramirez\nWest Texas Regional Safety\nManager Trophy Trucking Services,\nLLC 100 Glenborough Drive\nSuite 408\nHouston, TX 77067\nReference No. 25-0105\nDear Mr. Ramirez:\nThis letter is in response to your July 25, 2025 email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to visibility and display of\nplacards. You described a scenario and provided photographs of a pickup truck equipped with\na gooseneck hitch,1 also known as a neck-over hitch, and used to tow a trailer (i.e., a cargo\nbody) carrying hazardous materials. All hazardous materials are loaded onto the trailer and\nplacards are affixed on both sides and rear of the trailer. The forward-facing placard is affixed\nto the front bumper of the pickup truck. Furthermore, you seek clarification of previously\nissued letter of interpretation Reference No. 16-0166R2 with respect to reference to a “fifth\nwheel” and a pickup truck equipped with a ball and hitch. Specifically, you ask if a pickup\ntruck with a gooseneck hitch would be considered a “truck-tractor”3 for purposes of\ndisplaying a placard on the front of the motor vehicle as prescribed by §§ 172.504(a) and\n172.516(b).\n1 A gooseneck hitch is a truck bed hitch that connects to a gooseneck trailer using a hitch ball.\n2 https://www.phmsa.dot.gov/regulations/title49/interp/16-0166r.\n3 A truck-tractor is a self-propelled commercial motor vehicle designed and/or used primarily for drawing other\nvehicles.\n\n<<<PAGE 2>>>\n\nYes. Based on the information and photographs provided, the pickup truck with the gooseneck\nhitch may be considered a “truck-tractor” for purposes of § 172.516(b). Therefore, the required\nplacarding for the front of the motor vehicle may be on the front of the pickup truck instead of or\nin addition to placarding on the front of the trailer (i.e., the cargo body).\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards and Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nHorne, T.\n25-0105\nMatt Ramirez\nWest Texas Regional Safety Manager\nTrophy Trucking Services, LLC\n100 Glenborough Drive Suite 408\nHouston, TX 77067\nmramirez@trophytrucking.com\nDate: 7/25/2025\nPipeline and Hazardous Materials Safety Administration\nOffice of Pipeline Safety\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nSubject: Request for Additional Clarification in\nInterpretation 16-0166R\nTo Whom It May Concern,\nI am writing to respectfully request additional clarification regarding\nPHMSA Interpretation 16-0166R, specifically related to the reference of\n“whether the pickup truck in your scenario has a fifth wheel and would\nbe considered a \"truck-tractor,\" or has a traditional \"ball and hitch.”\nTrophy Trucking Services, LLC seeks clarification to address a recent\nviolation and ensure compliance.\nBackground and Context: Our driver was operating a 2019 Chevrolet\nSilverado 3500 towing a trailer with a gooseneck, also known as neck-\nover, hitch configuration, secured in the truck bed. The hazardous\nmaterials were loaded solely on the trailer, and placards were affixed\non both sides and the rear of the trailer, with the forward-facing placard\n\n<<<PAGE 4>>>\n\nplaced on the front bumper of the truck, consistent with our\nunderstanding of § 172.516(b). During an inspection, the driver\nreceived a violation because the forward-facing placard was not affixed\nto the front of the trailer itself. The reporting agency stated the 2019\nChevrolet Silverado 3500 does not qualify as a truck-tractor, and\ntherefore, the trailer, as a separate transport vehicle, must\nindependently bear a forward-facing placard.\nRelevant Details: The trailer is secured just forward of the rear axle via\na gooseneck hitch, rendering the truck bed unusable for carrying cargo.\nThe hazardous materials are Division 1.4 explosives and are\ntransported solely on the trailer. The trailer is not detached during\ntransport nor delivery, and the operation occurs on public highways.\nThe placards on the trailer’s sides and rear meet the visibility and\nattachment requirements of § 172.516(a) and (c). Importantly,\ngooseneck hitches functionally eliminate the truck bed’s cargo-carrying\ncapacity, much like a fifth wheel hitch does. This physical constraint\naligns with the criteria often used to differentiate truck-tractors from\nother vehicle types. While fifth wheel hitches can be installed in one-ton\nclass pickup trucks, they are more commonly used to tow recreational\nvehicle (RV) trailers. In contrast, gooseneck hitches are the standard in\nboth agricultural and commercial heavy-duty hauling, offering superior\nstrength, durability, and performance in severe service applications.\nThe interpretation states “whether the pickup truck in your scenario\nhas a fifth wheel and would be considered a \"truck-tractor,\" or has a\ntraditional \"ball and hitch.” We seek clarification on whether gooseneck\nhitch configurations are similarly considered indicative of a truck-\ntractor designation. These terms are interchangeable and describe a\nhitch type mounted in the truck bed, typically located just forward of\nthe rear axle. Vehicles equipped with gooseneck hitches are frequently\npurchased and operated by commercial entities using one-ton class\npickup trucks for the purpose of hauling significant cargo. These\nconfigurations are not incidental but are standard and customary in\ncommercial cargo transport settings.\nWe would also like to note the phrase “traditional ball and hitch\n\n<<<PAGE 5>>>\n\nconnection” can be easily misinterpreted. In common usage, this phrase\noften refers to a rear-mounted ball hitch affixed to the bumper or frame,\nused for light-duty trailers. This type of configuration differs\nsubstantially from a gooseneck-style ball hitch, which is mounted in the\nbed of the truck and designed for commercial-grade towing. Clarifying\nthis distinction within the interpretation would help prevent\nmisunderstandings and ensure consistency in enforcement and\ncompliance.\nTo aid in your review, I have attached photographs of a typical\ngooseneck (neck-over) hitch configuration. These images clearly show\nhow the hitch occupies the truck bed space, rendering it unusable for\ngeneral cargo and aligning functionally with the characteristics of a\ntruck-tractor.\nWe respectfully request PHMSA’s interpretation as to whether this type\nof vehicle and hitch configuration is considered a “truck-tractor” under\nthe regulatory guidance reflected in 16-0166R.\nThank you for your attention to this matter. Should you require\nadditional details or wish to discuss further, please feel free to contact\nme directly at mramirez@trophytrucking.com.\nSincerely,\nMatt Ramirez\nWest Texas Regional Safety Manager\nTrophy Trucking Services, LLC\nAttachments:\n- Photo Documentation: Gooseneck/Neck-over Hitch Configuration\n\n<<<PAGE 6>>>\n\n\n\n<<<PAGE 7>>>\n\n\n\n<<<PAGE 8>>>","truncated":false,"body_characters":7103}