# Georgia Public Service Commission — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 99-0048
- **title:** Georgia Public Service Commission — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1999-05-06
- **effective on:** Not available
- **summary:** 99-0048 response to Georgia Public Service Commission concerning 172.504.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-99-0048.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-99-0048.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-99-0048
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990048.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
400 Seventh Street, S.W.
Washington, D.C.
20590
Research and
Special Programs
Administration
MAY * 6 1999
Captain Bruce Bugg
Reference No. 99-0048
Hazardous Materials Specialist
Georgia Public Service Commission
47 Trinity Avenue, SW
Atlanta, GA 30354-5701
Dear Captain Bugg:
This is in response to your letter of February 17, 1999, regarding clarification of §§ 172.504 and
ask whether mounting the front or rear placard on the fenders of cargo tanks, anywhere from even with
172.516 under the Hazardous Materials Regulations (HIVER: 49 CFR Parts 171-180). Specifically, you
the front of the cargo tank to as much as 24 inches from the end of the tank satisfies the requirements of
§§ 172.504 and/or 172.516.
The answer is no. Section 172.504 states that a transport vehicle must be placarded on each side and
each end. A placard located on the tank fender that "faces" the front of the tank is not "on" the front
end, and therefore, the placard does not comply with § 172.504. Additionally, the location of the
placard does not satisfy the visibility requirements of § 172.516(a).
I hope this answers your inquiry. If we can be of further assistance, please contact us.
Sincerely,
Schnithills
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
172.504
990048

<<<PAGE 2>>>

COMMISSIONERS:
OF...
BOB DURDEN
ROBERT (BOBBY) BAKER
STAN WISE
LAUREN "BUBBA" MCDONALD, JR
DEBORAH K. FLANNAGAN
EXECUTIVE DIRECTOR
1716
HAZARDOUS MATERIALS SPECIALIST
CAPT. BRUCE BUGG
(404)559-6627
Georgia Public Spruice Commissian
ATLANTA, GEORGIA: 30354-5701
47 TRINITY AVENUE, SW
george
(404)656-4501 or 1-800-282-581:
http://www.psc.state.ga.us
$ 172.56
February 17, 1999
99-6048
Mr. Edward Mazzullo
Office of Hazardous Materials Standards
US DOT - RSPA - DHM-10
10o SingEron, DC 20590-0001
Dear Sir:
993.-
This letter is to request a clarification of the visibility and display requirements for placards, especially on cargo tank motor
addition, 49 CFR §172.516 sets down certain other visibility requirements
vehicles. As you know, 49 CFR §172.504(a) requires placards be displayed "on each side and each end" of the vehicle. In
sometimes rear) placards are mounted on the fenders of the tanks, anywhere from even with the front of the cargo tank, to as
Our officers frequently encounter cargo tanks with placards mounted as depicted in the drawings below. The front (and
much as 24 inches from the end of the tank.
§172.516(c)(2). We feel this is particularly acute in case the cargo tank should roll over onto the side where the placard is
We have treated this type of placement as a violation of §172.504, and, depending upon how far back the placard sits.
mounted, since three of the four placards would then not be readily visible to an approaching person at ground level.
However, we have had numerous carriers question whether this mounting is indeed a violation. Therefore, we request your
clarification as to whether these front and/or rear facing placards mounted back from the front edge of the tank surface violate
the regulations.
Placard.
Side View
•
-1:241
Top View
•Fender
Front View
Placard
- 1-24• F
Placard
No Scale
-Sincerely,
GEORGIA PUBLIC SERVICE COMMISSION
Capt. Bruca Bagg
Hazardous Materials Specialist
TRANSPORTATION DIVISION: 1007 VIRGINIA AVENUE, SUITE 310, HAPEVILLE, GEORGIA, 30354-1325
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