{"operation":"document","citation":"99-0025","title":"Industrial Consulting Services — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-04-14","effective_on":null,"summary":"99-0025 response to Industrial Consulting Services concerning 172.516.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0025.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0025.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0025","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990025.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S.Department\nNashington, D.C. 2059\n00 Seventh Street, S.W\nResearch and\npecial Program\ndministratio\nAPR 1 4 1999\nMr. Randy L. Holloway\nIndustrial Consulting Services\nRef. No. 99-0025\nP.O. Box 990\nMiddleton, ID 83644\nDear Mr. Holloway:\nThis is in response to your letter dated January 10, 1999, regarding the requirements for visibility and\ndisplay of placards on a transport vehicle as prescribed in the Hazardous Materials Regulations (HMR;\n49 CFR Parts 171-180).\nYou asked what is the meaning of the phrase \"substantially reduced\" as used in 49 CFR 172.516(c)(6),\nregarding visibility of placards, and whether it would be a violation of the HMR to use duct tape located\napproximately 1/4 inch over the black inner border of the placard, although the symbol, identification\nnumber and hazard class are visible. You also asked whether a small amount of \"road spray\" may be\non the placard and not be in violation of the HMR.\nSection 172.516 requires that a placard must be displayed in a location clear of appurtenances and\ndevices such as ladders, be located in a position so that dirt or water is not directed to it from the\nwheels of the transport vehicle and be visible from the direction it faces. In addition, the requirements\nspecify that the visibility of the placard will not be \"substantially reduced\" due to damage, deterioration,\nor obscurement by dirt or other matter.\nAlthough, you did not provide any photographs or drawings of the placards, based on the information\nyou provided, it is the opinion of this Office that the duct tape (used to affix the placard to the motor\nvehicle) which covered the black solid line inner border is a violation of the requirements in 49 CFR\n172.516(c)(6). In addition, if the placard is located on the motor vehicle where it is liable to be\ncovered with dirt, snow, mud or other matter (e.g., \"road spray\"), it is a violation of HMR.\n1725|6\n990025\n\n<<<PAGE 2>>>\n\nThe phrase \"substantially reduced\" is not defined in the HMR; however, its intent is to prohibit a\nplacard on a motor vehicle whose format and legibility is diminished, such as by placing duct tape over\nthe black solid line inner border (a required part of the placard design), or a placard that is damaged,\ndeteriorated, or obscured, such as by \"road spray\".\nI hope this satisfies you inquiry.\nSincerely,\nDentillio\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards","truncated":false,"body_characters":2447}