In the general placarding requirements of 49 CFR 172.504(a) of the USDOT/PHMSA Hazardous Materials Regulations (HMR), it states that when required each bulk packaging, freight container, unit load device, transport vehicle, or rail car “must be placarded on each side and each end”. Simple enough, right?
It becomes more complicated when we consider the visibility and display of those placards on a motor vehicle such as a straight truck or semi-trailer truck.
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- Straight truck
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- Transport Vehicle (aka: Motor Vehicle)
This article will explain the requirements of 49 CFR 172.516(a) and (b) for the visibility and display of placards on a motor vehicle.
Before we begin…
Understanding the regulations and this article will be a lot easier if you know that a motor vehicle is a type of transport vehicle and that each separate cargo-carrying body (e.g., trailer, rail car) is a separate transport vehicle. Please read this article if necessary: FAQ: What is a transport vehicle?
The display of placards on a motor vehicle:
The display of placards on a motor vehicle is addressed at §172.516(a). (I have added emphasis):
Each placard on a motor vehicle and each placard on a rail car must be clearly visible from the direction it faces, except from the direction of another transport vehicle or rail car to which the motor vehicle or rail car is coupled. This requirement may be met by the placards displayed on the freight containers or portable tanks loaded on a motor vehicle or rail car.
As noted earlier in this article, §172.504(a) requires a transport vehicle to be placarded on each side and each end. Easy. And §172.516(a) mandates that the placard be clearly visible from the direction it faces. That means the displayed placard should be clearly visible to a person standing at each side and each end of the motor vehicle.
However, also at 172.516(a), it indicates the requirement for the displayed placard to be visible does not apply if its visibility is restricted by the presence of another transport vehicle making up the motor vehicle (remember: each cargo-carrying body is a separate transport vehicle).
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172.516(b) further clarifies the requirements for the visibility of placards displayed on a motor vehicle:
The required placarding of the front of a motor vehicle may be on the front of a truck-tractor instead of or in addition to the placarding on the front of the cargo body to which a truck-tractor is attached.
A tractor-trailer combination fits the definition of two separate transport vehicles, whereas a straight truck is a single transport vehicle. Therefore, a placard on the front of a trailer in a tractor-trailer combination may be obstructed by the presence of the tractor or truck without violating 49 CFR 172.516(a) (LOI 05-0063). Similarly, the front and rear facing placards on a trailer that is part of a multi-trailer load may be obstructed by the presence of additional trailers without a violation.
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- Transport Vehicle (aka: Motor Vehicle)
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- Each trailer is a separate transport vehicle. The two trailers and the tractor together are the motor vehicle.
Placards on the cargo-carrying portion of a transport vehicle (straight truck) are OK even if not on the front of the vehicle as long as they are clearly visible from the direction they face. (LOI 09-0055). However the front facing placard on a straight truck would be in violation of this part if it was not visible from the front. (LOI 04-0164).
Acceptable display of placards on a straight truck
Though not required, mounting the placard on the front of the truck-tractor (indicated as an option at §172.516(b)) is the best way to comply with §172.516(a). (LOI 08-0098)
If you wish for the front facing placard on a tractor-trailer combination to be visible to the front, you may mount the placard on the front of the tractor or rig. 49 CFR 172.516(b) allows for the front facing placard of a HazMat shipment to be affixed to the front of the truck-tractor instead of or in addition to the placarding of the front of the semi-trailer. This would also satisfy the requirements of 49 CFR 172.516(a). Note however, that if the tractor and trailer become separated, say if the HazMat shipment is stored incidental to transportation, then a front facing placard would be required for the trailer.
You may also be interested in this article on the General Display Requirements for Placards.
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Compliance with the Hazardous Materials Regulations of the US DOT begins with training. I provide training for HazMat Employees as required by 49 CFR 172, Subpart H. I also provide RCRA Training for Hazardous Waste Personnel as required by 40 CFR 262.17(a)(7) for a large quantity generator of hazardous waste.