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How Small Is Too Small for Hazmat Markings?

Posted on 8/19/2014 by Robert Clarke

In 2013, domestic and international regulatory agencies (DOT, IATA, and IMO) implemented regulations to standardize the size of markings on packages of hazmat. Standardization across national borders, modes of transportation, and industry sectors streamlines compliance, reduces confusion, and increases the safety, security, and efficiency of international hazmat transportation. During this process, the one element that was not standardized was the implementation date.
 
US Hazardous Material Regulations
 
Markings on Non-bulk Packages: To harmonize domestic rules with international standards, starting January 1, 2017, the United States Department of Transportation will enforce minimum size requirements for identification number markings on non-bulk packages. This requirement does not apply to other markings on the package, such as the Proper Shipping Name and shipper’s or receiver’s name and address. The new size requirements for identification number markings are: 
 
  • At least 12 mm in size for packages larger than 30 kg or L
  • At least 6 mm in size for packages greater than 5 and up to 30 kg or L
  • At least 6 mm in size for cylinders less than or equal to 60 L water equivalent
  • Of an adequate size for smaller packages
Hazmat package with UN specification ID number

Until January 1, 2017, the minimum size for markings is optional. Also, packages that are permanently marked, by embossing or otherwise, before 2017 can remain in use without meeting the size requirements until the end of their useful service life.
[49 CFR 172.301(a)(1)]
 
IATA’s Dangerous Goods Regulations (IATA DGR)
 
Marking Size on all Packagings: Effective January 1, 2014, the IATA DGR instituted minimum size requirements for markings on packagings. The identification number markings must be:
 
  • At least 12 mm in size for packages larger than 30 kg or L
  • At least 6 mm in size for packages greater than 5 and up to 30 kg or L
  • Of an adequate size for smaller packages
For overpack and other package markings, such as the Proper Shipping Name and the shipper’s and consignee’s name and address, the minimum sizes are: 
 
  • At least 12 mm in size for packages larger than 30 kg or L
  • At least 6 mm in size for packages less than or equal to 30 kg or L
[IATA DGR 7.1.4.4]
 
IMO’s Dangerous Goods Code (IMDG Code)
 
Marking Size on all Packagings: Effective January 1, 2014, the IMDG Code instituted minimum size requirements for identification number markings on packagings. This requirement does not apply to other markings on the package, such as the Proper Shipping Name and the shipper’s or receiver’s name and address. The identification number markings must be:
 
  • At least 12 mm in size for packages larger than 30 kg or L
  • At least 6 mm in size for packages greater than 5 and up to 30 kg or L
  • At least 6 mm in size for cylinders less than or equal to 60 L water equivalent
  • Of an adequate size for smaller packages
 
Cylinders with a capacity of less than or equal to 60 liters that were marked prior to January 1, 2014 can continue to be used until the next or periodic inspection but must be in compliance with the 6 mm minimum size requirement by July 1, 2018 at the latest.
[IMDG 5.2.1.1]
 
If you are not currently operating according to the above regulations, it is advisable to make the required changes to your operations. Abiding by the rules is important for several reasons:
 
  • DOT inspectors can come to your company at any time to ensure compliance-
  • Fines for hazmat shipping violations are now as high as $75,00 per day, per violation.
  • Easily visible markings aid the efficient processing of your packages by carriers.
  • Markings provide important information to first responders in the event of an incident in transit.
  • Avoid costly processing delays.
  • Maximize customer satisfaction.
Be confident your team has the knowledge and skills to prepare your hazmat shipments for ground, air, and ocean transport at the Multimodal Hazmat Shipper Workshops, presented nationwide. These interactive, engaging workshops cover the latest domestic and international hazmat shipping regulations and are designed to satisfy the applicable training standards for hazmat employees. 

Tags: DOT, hazmat shipping, IATA, IMDG, marks and labels

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