OOSC, Part III, Item 4. Transport Vehicle Markings, a. ID Numbers Displayed on a Transport Vehicle

Part III: North American Standard Hazardous Materials Out-of-Service Criteria, Item 4: Transport Vehicle Markings, paragraph a. The Required ID Numbers Must Be Displayed On A Transport Vehicle. Vehicle marking requirements in 49 CFR Part 172 Subpart D: Marking, vary on whether the marking has to be displayed ON the transport vehicle itself, or on a bulk package that is on the transport vehicle. Paragraph a., above, is misleading in that it appears that all markings must be displayed physically ON the transport vehicle.

It is the opinion of this writer that Item 4.a., as written, tends to mislead roadside inspectors into improperly citing violations of 49 CFR Part 172 Subpart D, and placing vehicles OOS when markings were properly displayed on the bulk packagings themselves.

The request is to modify 4.a. to properly address the OOS condition to read: 4. Markings a. ID Numbers Must Be Displayed As Required. This verbiage is my recommendation; however, similar wording could be considered. The intent of the change is to direct roadside inspectors to apply the marking requirements in 49 CFR Part 172 Subpart D correctly.