Prohibited Placard Display
Pipeline and Hazardous Materials Safety Administration · Dec 12, 2022 · Reference No. 22-0106
Interprets: 49 CFR § 172.502(a)(2)
Reggie’s quick take
A company asked whether a flip placard showing its plain white "blank" side counts as prohibited placarding under § 172.502(a)(2). The agency said no. A blank white flip placard does not count as prohibited placarding, and neither does an empty placard holder frame. The letter does not address any other display situations.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
December 12, 2022
Reference No. 22-0106
This letter is in response to your October 6, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to prohibited display of placards. Specifically, you ask whether a flip placard displaying “blank” white panels constitutes prohibited placarding in accordance with 172.502(a)(2). When turned to the “blank” side, a flip placard maintains the square-on-point design (i.e., shape of a placard) but does not display any hazard communication information.
The answer is no, display of a “blank” white flip placard does not constitute prohibited placarding. Similarly, an empty placard holder frame also does not constitute prohibited placarding.
I hope this information is helpful. Please contact us if we can be of further assistance.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.