{"operation":"document","citation":"98-0215","title":"American Trucking Associations — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-10-27","effective_on":null,"summary":"98-0215 response to American Trucking Associations concerning 172.606.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0215.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0215.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0215","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980215.pdf","body":"<<<PAGE 1>>>\n\n•\nU.S. Department\nof Transportation\n400 Seventh Street, S.W.\nSpecial Programs\nResearch and\nWashington, D.C.\n20590\nAdministration\nOCT 27 1998\nMr. Paul Bomgardner\nAmerican Trucking Associations\nRef. No. 98-0215\n220 Mill Road\nAlexandria, VA 22314-4677\nDear Mr. Bomgardner:\nThis is in response to your letter regarding the requirements for carrier information contact specified in\n49 CFR 172.606, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You\nenclosed two (2) photographs of an inspection plate attached to a motor vehicle.\nThe motor carrier requirements prescribed in 49 CFR 396.17 prescribe an inspection report for\ncommercial motor vehicles, including trailers and semi-trailers. You stated that many motor carriers\nchoose to comply with this requirement by attaching a plate to the motor vehicle which contains\ninformation required in an inspection report, including the name address of the motor carrier, and may\ninclude the motor carrier's telephone number. You asked if the requirement in 49 CFR 172.606, for\nmarking the carrier's telephone number on a motor vehicle, can be met by display of the carrier's\ntelephone number on an inspection plate, as shown in the enclosed photographs.\nThe answer is no. The provisions in 49 CFR 172.606 require that the telephone number (for carrier\nnotification and information contact) of the motor carrier must be marked on the motor vehicle on the\nfront exterior near the brake hose and electrical connections, or on a label, tag, or sign attached to the\nmotor vehicle near the brake hose or electrical connections. As shown in the enclosed photographs,\nthe inspection plate on the vehicle is displayed on the side and not near the brake hose or electrical\nconnections. Therefore, such display do not meet the requirements in 49 CFR 172.606.\nI hope this satisfies you inquiry.\n:\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nÁMERICAN TRUCKING ASSOCIATIONS\n2200 Mill Road • Alexandria, VA 22314-4677\nSafety Department\n98-0215\nFax (703) 683-1934\n(703) 838-1847\nJuly 24, 1998\nMr. Alan I. Roberts\nEngrum\nAssociate Administrator for Hazardous Materials Safety\n1R2.606\nResearch and Special Programs Administration\nU.S. Department of Transportation\nDHM-1\n400 Seventh Street, SW\nWashington, DC 20590\nRe: Carrier Information Contact: 49CFR Part 172 Section 172.606(b)(1)\nAl\nDear Mr. Roberts:\nThe intent of this letter is to seek an exception through interpretation to the\nrequirement in section 172.606(b)(1) to \"mark the transport vehicle with the telephone\nnumber of the motor carrier on the front exterior near the brake hose and electrical\nconnections on a label, tag, or sign attached to the vehicle at the brake hose of electrical\nconnection.\" Specifically, American Trucking Associations, Inc. (ATA) is seeking a\nfavorable interpretation from Research and Special Programs Administration (RSPA)\nthat would allow use of an existing marking in lieu of the marking specifically required\nin section 172.606(b)(1).\nMotor carriers are required in section 396.17 of 49 CFR to perform a periodic\ninspection of every commercial motor vehicle, including trailers and semi-trailers. In\nconjunction with the inspection, documentation is required to be carried on the motor\nvehicle either in the form of a copy of the inspection report or by displaying a sign or\ntag on the vehicle which contains certain information based on the inspection.\nIncluded in the required information is the name and address of the motor carrier or\nother entity where the inspection report is maintained.\nWhile many motor carriers elect to carry a copy of the inspection report and\nothers provide the minimum amount of information required on an attached sign or\ntag, there are motor carriers who go beyond the requirements and provide additional\ninformation such as their telephone number. A prime example of a motor carrier that\ndoridovide aditional information is Warkins Moror Lines, Inc. of Lakeland,\n1\n\n<<<PAGE 3>>>\n\n..\n-\nWatkins has elected to secure a metal plate which contains their telephone\nnumber in addition to the required information to the right front side of all their\ntrailers. The positioning of the metal inspection plate serves both Watkins and the\nenforcement community well since most weigh and inspection stations are built to\nview the right sides of passing vehicles. Photographs of the inspection plate and its\nposition on the trailer are attached.\nOn behalf of Watkins Motor Freight and other motor carriers who use similar\nmarkings, ATA requests that RSPA allow their use to satisfy the marking requirement\nin section 172.606(b)(1). We believe that use of the inspection plate for the purpose of\nmotor carrier identification is in keeping with the intent of the marking requirement\nin the hazardous materials regulations. Additionally, we believe that it's location near\nwould not be compromised.\nthe tront of the trailer will cause no confusion on the part of responders and that safety\nAs the requirement to display the marking in section 172.606 takes effect on\nOctober 1, 1998, we request an answer to this request at your earliest convenience. If\nyou should have any questions or wish to discuss this request, please contact the\nundersigned at: 703-838-1849. Thank you for your consideration in this matter.\nPaul t\nPaul Bomgardner\nDirector, Hazardous Materials Policy\ncc:\nHoward Fitzgerald\nCorporate Safety Director\nWatkins Motor Lines, Inc.\n- -\n2\n\n<<<PAGE 4>>>\n\nWATKINS\n16144\nтл9.г.\n\n<<<PAGE 5>>>\n\n-\nG7.7A\n-\n- мінцадентим","truncated":false,"body_characters":5560}