The Council on the Safe Transport of Hazardous Articles (COSTHA) recently shared an interpretation from Mexican transportation authorities that makes it clear that Mexico expects hazmat labels to be placed with the "vertex upwards," I.e., as a square-on-point, or a square at a 45-degree angle, as required by the UN Model Regulations 22.214.171.124.1.2.
Mexico requires the diamond orientation even if the package is too small to fit a 100 mm x 100 mm hazmat label.
Mexico’s interpretation differs from US DOT’s in that the HMR does not prohibit shippers to place hazmat labels in a square orientation
when placing a label “correctly” is not possible. Catch an expert-led workshop to satisfy DOT hazmat training mandates in July! The Hazmat Ground Shipper Certification Workshop comes to New Jersey, Boston, Hartford, Philadelphia, Williamsburg, Baltimore, Charlotte, Orlando, Atlanta, Nashville, Memphis, Mobile, Jacksonville and more this summer!
Mexico Less Lenient With Labels
Mexico’s dangerous goods Normas Oficiales Mexicanas
(NOMs) lays out the nation’s requirements for hazmat shippers and carriers. COSTHA recently requested clarification of NOM-003-SCT/2008
(in Spanish), which prescribes standards for hazardous materials labels. Point 8.1.2 of the NOM states
“Las etiquetas tendrán Ia forma de un cuadrado. colocado con un vértice hacia arriba,” which translates to “The labels will have the shape of a square, placed with the vertex up.”
COSTHA asked whether Mexican authorities would allow a hazmat label to be placed in a square orientation on packages too small to accommodate the diamond orientation Mexican transport authorities responded as follows:
“For the above, answering your question I inform you that based on the basics of the identification of products considered dangerous, it is necessary that the pictograms are displayed in the form of a diamond, since the emergency personnel is familiar with this identification and may act if appropriate and necessary, for this reason you cannot place the labels in square orientation.”
(Translation from the original Spanish, available here.)
Alternative Hazmat Labeling Options for Small Packages
On packages too small to fit a hazmat label in a diamond orientation, the UN Model Regulations allow shippers to use a reduced-size label so that the label may be placed in accordance with the rules. PHMSA also allows a reduced size labels on small packages (49 CFR 172.407(c)(1)(i)).
PHMSA offers additional options for labeling too-small hazmat packages at 49 CFR 172.406(b),
such as affixing the label to a securely affixed tag or affixing it by other suitable means. These alternative labeling methods are allowed for packages that do not
contain radioactive materials (Class 7) and are smaller than the 3.9-inch-by-3.9-inch (100 mm-by-100 mm) minimum label size. Shippers may also use alternative labeling means on packages with “irregular surface to which label cannot be satisfactorily affixed.” Given Mexico’s strict interpretation of the hazmat labeling requirements, your best bet may be to invest in reduced-sized labels or larger packagings if you ship dangerous goods south of the border.
IATA issued guidance to relax its DG label standards earlier this year.
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