New Penn Motor Express — Hazardous Materials Safety Interpretation

Page 1U.S. Department 1200 New Jersey Avenue SE of Transportation Washington. DC 20590 Pipeline and Hazardous Materials Safety Administration JUN 9 ?011 Mr. Thomas Gerhold Safety Manager New Penn Motor Express 625 S. 5th Avenue Lebanon,PA 17042-0630 Ref. No.: 11-0100 Dear Mr. Gerhold: This responds to your April 13, 2011 letter requesting clarification ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the display and visibility of placards. In your letter, you provide a picture of a straight truck with placard holders in place on the sides and ends of the cargo body. Specifically, you ask ifplacards placed in the placard holders in front of the cargo body but behind the passenger compartment of the truck would satisfy the placard visibility requirements of the HMR. The answer is no. Section 172.516( a) states that each placard on a motor vehicle must be clearly visible from the direction it faces, except from the direction of another transport vehicle to which the motor vehicle is coupled. For purposes of the HMR, a "transport vehicle" is a cargo-carrying vehicle such as an automobile, van, tractor, truck, semi-trailer, tank car or rail car used for the transportation of cargo by any mode. In this case, the cargo carrying portion of the motor vehicle is not "another transport vehicle," because it is part ofa single transport vehicle (straight truck). The picture provided in your letter illustrates that the placard on the front of the cargo body of the straight truck is not visible from the front of the transport vehicle because it is clearly obstructed from view by the passenger compartment. A placard placed on the front bumper or similar location in accordance with § 172.516(b) would satisfy the visibility requirement of § 172.516(a). I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, B~~~~ Ben Supko Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Date: 04113/2011 &dt~~leutb S '7Z .5 If, La) 'Placa roflnq 11-o~O{)' 717.274.'5593 newpenn.co rn TO: Mr. Charles E. Betts FROM: Thomas Gerhold Subject: HMR; 49CFR 172.516,(a) Dear Mr. Betts We are writing you today to request clarification ofthe requirements under the Hazardous Materials Regulations (HMR; 49 CFR Part 172.516 (a)) Applicable to the visibility and display ofplacards. Accompanying this letter are pictures ofour Sterling Straight Truck. Our question is; Does the front placards attached to the cargo body ofthis truck and behind the driver's cab satisfy/meet the requirements ofthe above mentioned section ofthe HMR 49 CFR? Looking forward to hearing from you soon. You may reply via email or by mailing your response to my attention at the address provided below. r~&1 Thomas Gerhold Safety Manager New Penn Motor Express 625 S. 5th Avenue Lebanon, Pa 17042-0630 E-Mail tgerhold@newpenn.com PH: 800-285-5000 X 4234 FAX: 717-270-4606 regional expertise: leaders in next-day delivery I quality handling lon-time performance#

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