A common question raised in Lion’s hazmat workshops lately is how the DOT’s recent change to the order of elements for basic descriptions will affect marking and labeling procedures for packages. Read on for answers to this common question and a refresher on the package marking and labeling requirements.
As of January 1st, 2013, the order of elements describing a hazardous material on a shipping paper must be: Identification number, Proper Shipping Name, hazard class or division, and packing group (if applicable). These new requirements are listed at 49 CFR 172.202. For more information about this change, see our October Newsletter article
. It is important to note that this rule change affects shipping papers only, and not any description or markings displayed on the outside of a package.
The general and specific requirements for the content and placement of markings on bulk and non-bulk packagings can be found at 49 CFR 172, Subpart D, but none of these provisions specify a particular order of elements for the marked information. Although there is no specific order set for markings on a package, certain requirements for marks and labels still apply.
Marking Non-bulk Packages
In general, non-bulk packages of hazardous material must be marked with three pieces of information:
- Proper Shipping Name,
- Identification number, and
- Either the consignee’s or consignor’s name and address, i.e., the “to” or “from” address.
Additional markings may be required in special circumstances. You may need to also include information like technical names of chemicals shipped under generic shipping names, orientation arrows for liquids in combination packages, or the letters RQ for hazardous substances, just to name a few of the most common additions. Marking the packing group on the package is not required. [49 CFR 173.301]
Marking Bulk Packages
For bulk packagings, the minimum marking requirement is the identification number of the material marked on two or four sides [49 CFR 172.302, and 172.328–172.331]. In many cases, the package must also be marked with the Proper Shipping Name. Additional information may be required for certain materials or shipments [49 CFR 172.326]. Marking the packing group on the package is, again, not required.
Display of Markings
There are a number of general requirements for package markings. All markings must be:
- Durably placed on the surface of the package,
- Printed in English,
- Displayed on a contrasting background,
- Un-obscured by labels or attachments, and
- Located away from other markings (such as advertising) that could substantially reduce their effectiveness.
Minimum Size Requirements
For bulk packages, the identification number, Proper Shipping Name, and other required markings must be at least:
- 6 mm (0.24 in.) wide and 100 mm (3.9 in.) high for rail cars,
- 4 mm (0.16 in.) wide and 25 mm (1 in.) high for IBCs and portable tanks, and
- 6 mm (0.24 in.) wide and 50 mm (2.0 in.) high for cargo tanks and other bulk packagings.
The DOT recently amended the HMR to harmonize with international standards by mandating minimum size requirements for markings on non-bulk packages [78 FR 987; January 7, 2013
- Packages with a maximum capacity of 5 L (1.3 gal.), or 5 kg (11 lbs.) or less “…must be marked in a size appropriate for the size for the package.”
- Packages with a maximum capacity of 30 L (8 gal.) or less, or 40 kg (66 lbs.) maximum gross weight, or cylinders with a water capacity of 60 L (16 gal.) or less must be marked with characters at least 6 mm (0.24 in.) high.
- Larger packages must be marked in characters at least 12 mm (0.47 in.) high.
For domestic transportation, these minimum size requirements will not be mandatory until January 1, 2017.