Georgia Public Service Commission — Hazardous Materials Safety Interpretation

Page 1U.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 2COMMISSIONERS: 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#