Metropolitan Environmental, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 400 Seventh Street, S.W. 20590 Research and Administration Special Programs JUL / 1999 Mr. Thomas W. Moline Ref. No: 99-0163 Safety Director Metropolitan Environmental, Inc. P.O. Box 378 Celina, OH 45822 Dear Mr. Moline: This is in response to your letter of June 21, 1999, requesting clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you provide a scenario where the trailer of a tractor trailer combination is shaped into a point in the front. You ask whether the trailer may have the front placard displayed at a 45° angle. The answer is yes. As provided by § 172.516(a) each placard on a motor vehicle must be readily visible from the direction it faces except from the direction of another motor vehicle to the it is coupled. Therefore a placard displayed on the front of the trailer of a transport vehicle is not required to be "readily visible" as long as it remains attached to another motor vehicle. I hope this information is helpful. Sincerely, Subor Hillip. Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 990163 172.516#

Page 2Metropolitan Environmental Inc. P.O. Box 378, Celina, OH 45822 419/586-6638 lavalle 9 172.516 June 21, 1999 99-0163 Mr. Edward Mazzullo Director, OHMS RSPA, USDOT DHM-10 400 7* Street SW Washington DC 20590-0001 Dear Mr. Mazzullo, On June 17, 1999, a commercial motor vehicle operated by my company, Metropolitan items written up by the inspector was a violation of 49CFR177.823 that discusses the Environmental, Inc., was stopped in South Carolina for a DOT inspection. One of the correct way to transport HazMat. Specifically mentioned in the citation is that the placard on the front of the trailer being hauled was "displayed at an angle, should face forward." The placard was displayed at a 45-degree angle to the front of the trailer. The South Carolina inspector, Mr. Lavender, was contacted and asked about the violation. He stated that 172.516 is the section specifically checked for placarding and that this section states that the placard "must be readily visible from the direction it faces." He further stated that RSPA interpretations of this section state that the placard must face straight ahead. He then advised me to contact RSPA if I needed further clarification. I checked the interpretations for 172.516 and found nothing to substantiate his claim. i then called your center and asked for an interpretation. The gentleman I talked to was very helpful and did some research before answering that the front placard is the only one of the four required which has an exemption which states it must be readily visible "except from the direction of another motor vehicle... to which the motor vehicle is coupled." He and I both interpret this to mean that the placard, in this situation, was adequate when placed at the 45-degree angle.#

Page 3I request a written interpretation for our records and to use in our contact with the Sought Carolina authorities. If you have any questions or would like to discuss this matter, please contact me at (800) 334-9139. Sincerely; Thomas i moline Thomas W. Moline Safety Director Metropolitan Environmental, Inc. TWM#