{"operation":"document","citation":"98-0426","title":"American Crop Protection Association — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-04-29","effective_on":null,"summary":"98-0426 response to American Crop Protection Association concerning 172.516.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0426.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0426.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0426","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980426.pdf","body":"<<<PAGE 1>>>\n\n:\nU.S. Department\nof Transportation\n400 Seventh Street, S.W\nResearch and\nWashington, D.C.\n20590\nSpecial Programs\nAdministration\nAPR 2 9 1998\nMr. Thomas J. Gilding\nDirector, Environmental Affairs\nAmerican Crop Protection Association\n1156 Fifteenth Street, N.W., Suite 400\nWashington, D.C. 20005\nDear Mr. Gilding:\nThis responds to your letter, dated April 20, 1998, concerning the display of placards on motor\nvehicles. You asked whether the display of four placards above a vehicle on a single assembly,\nwith one placard visible from the front, one from the rear, and one from each side, would comply\nwith the placarding requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts\n171-180).\nThe answer to your question is no. When placarding is required by § 172.504 of the HMR, a\ntransport vehicle must be placarded \"on each side and each end.\" The placard holder that you\n:\ndescribe in your letter does not meet the requirement in § 172.504 for placarding on each side\nand each end of a transport vehicle.\n:\nI hope this information is helpful. If you have further questions, please do not hesitate to contact\nthis office.\ni\nSincerely,\nI. All\nThomas. Allan\nun\nSenior Transportation Regulations Specialist\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\n07/20/98\nMON 09:25 FAX 202 463 0474\nACPA\n4002\nAmerica\nn\nGorsky\ncrop\n172.516\n:\nProtection\nAssociation\nApril 20, 1998\nMr. Thomas Allan\nU.S. Department of Transportation\nResearch and Special Programs Administration\nOffice of Hazardous Materials Standards\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nDear Mr. Allan:\nThe American Crop Protection Association (ACPA), in coordination with the\nMid-America Crop Protection Association (MACPA), Southem Crop Protection\nAssociation (SCPA), and Western Crop Protection Association (WCPA), requests a\nwritten interpretation concerning the display of placards on motor vehicles, as specified\nin 49 CFR 172.504(a) and 172.516(a). We have a prototype of a proposed placard\nholder that could be used on motor vehicles in the crop protection industry with a Gross\nVehicle Weight Rating or a Gross Combination Weight Rating of 26,000 Ibs. or less\nwhich are not equipped with placard holders.\nThe proposed placard holder consists of four placard holders mounted to an assembly\nwhich is approximately 18\" long X 18\" wide. This assembly could be mounted on the\nvehicle in a variety of ways (e.g., with a mounting bracket, which would either be\nattached to the back of the vehicle's headwall, to the bed, top or side of the vehicle; a\nspring loaded post extending above the top of the vehicle; or mounted on a luggage or\npipe rack). Placards would be readily visible from the front, back, and both sides, as\nrequired in 49 CFR 172.516(a).\nIt is somewhat less clear whether display of placards in the proposed manner would\ncomply with the requirement for vehicles to be \"placarded on each side and each end\"\nas specified in 172.504(a). We believe that the proposed method of displaying placards\nis equivalent to or superior to placement of placards on the ends and sides of vehicles.\nThe placards would be easy to see, actually attracting attention due to their high\nplacement and unique holder. Hazard communication objectives would be clearly\naccomplished.\n11Ften Street, WASte 400• Washington, DC 20005• (202) 296-1585 • FAX (202) 463-0474\nwww:http://www.acpa.org\n\n<<<PAGE 3>>>\n\n04/20/98 MON 09:25 FAX 202 463 0474\nACPA\n2003\n-\n•\nFor smaller motor vehicles in the agricultural chemicals industry, particularly at the\ndealer and grower level, it is often difficult to comply with the DOT vehicle placarding\nrequirements. Most pickup trucks do not have placard holders, and self-adhesive or\ntaped placards can damage the paint on the sides of a truck.\nPlease provide a written interpretation indicating whether or not the display of all four\nplacards above a vehicle on a single assembly, with one placard visible from the front,\none from the rear, and one from each side, is in compliance with the 49 CFR\n172.504(a) and 172.516(a) placarding requirements.\nWe appreciate your consideration of this request. If you have any questions, please\ncontact me at (202) 872-3873.\nRespectfully submitted,\nThomas J. Gilding\nDirector, Environmental Affairs","truncated":false,"body_characters":4259}