DOT Basic Descriptions: Shipping Papers vs. Marks and Labels

Posted on 3/19/2013 by Ross Kellogg

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.

Get up to speed with all recent changes to the Hazardous Materials Regulations with Lion's Hazmat Ground Shipper Certification (DOT) online course for training that's effective, reliable, and available 24/7.

Tags: DOT, hazmat shipping, marks and labels, papers, shipping

Subscribe To Lion News

Get the latest in EH&S news & updates delivered to your inbox weekly.

Email Address

Find a Post

Compliance Archives

Lion - Quotes

The instructor was very dedicated to providing a quality experience. She did her best to make sure students were really comprehending the information.

Stephanie Venn

Inventory Control Specialist

Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus.

John Brown, CSP

Director of Safety & Env Affairs

Lion courses are the standard to which all other workshops should strive for!

Brody Saleen

Registered Environmental Health Specialist

The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!

Chelsea Minguela

Hazmat Shipping Professional

Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!

Stephanie Weathers

SHE Specialist

The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable.

Mary Sue Michon

Environmental Administrator

The instructor was very knowledgeable and provided pertinent information above and beyond the questions that were asked.

Johnny Barton

Logistics Coordinator

Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat.

Genell Drake

Outbound Lead

Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again.

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

Download Our Latest Whitepaper

Use this guide to spot which tanks and substances are regulated under EPA's Underground Storage Tank program, and which are excluded as of October 2018.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.