OOSC, Part III, Item 2. Placarding a. and b.

The current OOSC for Placards can be confusing based on how it is worded: 1. PLACARDING a. THE REQUIRED PLACARDS MUST BE DISPLAYED ON A TRANSPORT VEHICLE. b. NUMBER AND TYPE OF PLACARDS. An out-of-service condition exists when 50 percent or more of the required placards for a hazard class are missing or any placard(s) misrepresent(s) the HM/DG being transported. NOTE: For this out-of-service item to apply, HM/DG must be present.

The statement under a. could be taken as being an OOS condition on its own. a. THE REQUIRED PLACARDS MUST BE DISPLAYED ON A TRANSPORT VEHICLE. With the explanation of the 50% of placards missing or a placard misrepresenting in paragraph b. , paragraph a. can be interpreted on its own to mean that any required placard that is not displayed on a vehicle is OOS. There is really no valid reason for paragraph a. to be there. Paragraph b is really a description for the title under paragraph a. A further issue with paragraph b. is that some inspectors confuse the 50% to apply to both missing and misrepresenting placards when in reality it only applies to the missing placard. Any misrepresenting placard puts the vehicle OOS.

I suggest that the OOSC be reworded to remove the confusion as follows: 1. PLACARDING a. Number of Placards An out-of-service condition exists when 50 percent or more of the required placards for a hazard class are missing. b. Type of Placards An out-of-service condition exists when ANY placard(s) misrepresent(s) the HM/DG being transported. NOTE: For this out-of-service item to apply, HM/DG must be present.