Help Finding this New Regulation?

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  #1  
Old 08-17-2009, 07:59 PM
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Default Help Finding this New Regulation?

Ok, here's the deal-- I'm hauling a haz-mat load to California. One of the placards keeps coming off the passenger side- out of the placard holder. I have duct tape.

The "safety man" at our company says as of the 1st of this year-2009 there's a new rule that you can't use duct tape to secure a placard- that you can only use clear tape.

Ok, I've known about the "clear tape" trick for many....many years now. Use of "clear packing tape" to avoid the issue of "obscuring any of the placard"-- with duct tape you can only cover 1/2in up to the border line around the outside of the placard.

So, this evening I pull into the yard and get several 'extra' placards- and was told to remove the duct tape.

I get to St. Clair, Mo Weight Station(Scale) and I'm again missing a single placard.

Sgt. Westerhoff & I would really like to know WHERE THIS NEW REGULATION CAN BE LOCATED! (The no duct tape regulation).

Anyway, he got a chuckle out of that story.. and we're both "researching" this now. Cause other wise-- Had I been missing 2 placards-- I'd have been in trouble. But I was on top of it-- with several extras-- and now these are duct taped in place.

Westerhoff noted that with "safety men" like these that make up stuff-- who needs enemies. They are gonna get driver's in trouble telling them to remove the only tape available and to buy "packing tape" instead.

If anyone can find this regulation-- I'd appreciate you directing me to it.
 
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Old 08-18-2009, 01:27 AM
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These are the only ones I can see that might apply. There was a provision scattered throughout the HM regs that stated that the placard must have a visible black border of a certain size. Perhaps that is where the issue comes in?

Applicability, General Requirements, and North American Shipments

§171.2 General requirements.

(l) No person may alter, remove, deface, destroy, or otherwise unlawfully tamper with any marking, label, placard, or description on a document required by Federal hazardous material transportation law or the regulations issued under Federal hazardous material transportation law. No person may alter, deface, destroy, or otherwise unlawfully tamper with a package, container, motor vehicle, rail car, aircraft, or vessel used for the transportation of hazardous materials.


Labeling

§172.406 Placement of labels.

(f) Visibility. A label must be clearly visible and may not be obscured by markings or attachments.


Marking

§172.304 Marking requirements.
(a)(3) Must be unobscured by labels or attachments; and
 
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Old 08-18-2009, 03:31 AM
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Russ...Ask Mr. Safety Man to issue you a handfull of the square, clear plastic sheets, for placing in the placardholder. Those work great. Tell him you couldn't afford packing tape for his holders.


But you did the right thing! Mr. DOT Officer probably felt pretty good, getting to be nice to you, and getting a chuckle about Mr. Saftey!! :clap:

IF I use duct tape, I only use it sparingly, to avoid covering as much of the placard as possible. There are some DOT out there ( Colorado ) that don't like to see the tape at all.
 
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Old 08-18-2009, 04:04 AM
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Originally Posted by Orangetxguy
Russ...Ask Mr. Safety Man to issue you a handfull of the square, clear plastic sheets, for placing in the placardholder. Those work great. Tell him you couldn't afford packing tape for his holders.


But you did the right thing! Mr. DOT Officer probably felt pretty good, getting to be nice to you, and getting a chuckle about Mr. Saftey!! :clap:

IF I use duct tape, I only use it sparingly, to avoid covering as much of the placard as possible. There are some DOT out there ( Colorado ) that don't like to see the tape at all.
I just want mr. Safety to show me the specific wording that says no duct tape.... Rev might be right about the general rule that's being "interperted" about the no defacing, altering, etc. I'll look through the latest Q&A Guidance again. Might be in there. As for Mr. Dot being a nice guy-- yeah, they so far been pretty fair there at St. Clair. The regs clearly state- you have to be missing two or more 50% of your placards before they can cite you/ place you out-of-service. Or you must be missing any 2 placards from a single side. But- if you're missing 1- you better have a extra ready to replace.

I used to carry all that junk in the truck- but my recent interest in changing companies prompted me to drastically reduce the amount of personal effects carried on-board. I've saved many of the placards from 15years of doing this, and I even used to carry not only the packing tape- but the fancy packing tape "gun" to apply it easy. The problem with packing tape is it stops sticking at a higher temp than duct tape. Of course, neither works below 20 degrees.
 
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Old 08-25-2009, 04:55 PM
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Beware the Safety Man:

Good ones are more valuable than gold!

the rest have vivid imaginations, authority figure hang ups and a hard time providing sources to their wild ideas.

Without business cards, you might have a hard time identifying them as someone important....
 
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Old 08-26-2009, 01:09 AM
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Rev.Vassago is right nothing about duct tape best i could find is

§172.516 Visibility and display of placards

(c)(1) Be securely attached or affixed thereto or placed in a holder thereon. (See appendix C to this part.)

(d) Recommended specifications for a placard holder are set forth in appendix C of this part. Except for a placard holder similar to that contained in appendix C to this part, the means used to attach a placard may not obscure any part of its surface other than the borders

doesn't say you can't use duct tape but just to drive mr safety nuts get some white duct tape (or what ever color will match your trailers)
 
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Old 08-26-2009, 07:15 PM
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Where have they gone? There used to be posters on the forum, whom were posting their experiences as they got started, as well as some whom were just regular BSer's. Where have they gone??

Couldn't resist quoting OrangeTex's Signature Line..

Now, please join with me in one more round of that ole Peter, Paul and Mary Song...

"Where have all the flowers gone...
"Lone time passing...

"Oh where have they gone....
 
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Old 08-27-2009, 12:28 AM
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Originally Posted by headborg
Where have they gone? There used to be posters on the forum, whom were posting their experiences as they got started, as well as some whom were just regular BSer's. Where have they gone??

Couldn't resist quoting OrangeTex's Signature Line..

Now, please join with me in one more round of that ole Peter, Paul and Mary Song...

"Where have all the flowers gone...
"Lone time passing...

"Oh where have they gone....
Anyone in particular you're missing?
 
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Old 08-29-2009, 12:27 PM
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"... securely attached ..."

The regulation leaves us to determine how to accomplish this. The government has no interest in being prescriptive in how you go about doing this, or how we might invent new ways of doing it tomorrow.

A surround of duct tape is a fine and proper way to achieve regulatory compliance - it does attach the placard securely, and there is no refusal of using duct tape in regulation.

If the taping surface is prepared well, I might suggest that a good quality 3M duct tape might out perform the popular standard issue aluminum placard holder in the "securely attached" department under a variety of harsh weather conditions.

No reason for the tape to overlap the placard any more than the same 1/2 inch or so that one of those aluminum placard holders will.

Shoot your safety man and hide the body, nobody will come looking for him.
 
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