PHMSA to Address 2-mm Border Rule for Hazmat Labels

On May 8, 2018 the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a letter of interpretation in which the Director of Standards and Rulemakings clarifies that DOT will rescind or otherwise un-do a requirement for all hazmat labels to feature a 2-millimeter solid line forming the inner border.

Background on the 2-mm Hazmat Label Border Line Rule

Published in January 2015, Final Rule HM-215M made numerous updates and changes to the Hazardous Materials Regulations (HMR) to harmonize US rules with new international standards. Among these changes was the addition of exacting requirements for hazmat labels to 49 CFR 172.407, specifically:
 

• Each diamond label must be at least 100 mm on each side;
• Each side must have a solid line inner border 5 mm inside and parallel to the edge; and
• The width of the solid inner border line must be at least 2 mm.

In March 2017, PHMSA delayed the effective date of these new requirements until December 31, 2018.

Removal of the 2-mm Border Line Requirement

After hearing concerns from hazmat shippers and industry stakeholders, international authorities recognized that the 2-mm inner border line on hazmat labels has no effect on transportation safety.
Therefore, the International Civil Aviation Organization (ICAO) decided to remove the 2 mm border line requirement from the ICAO Technical Instructions in April 2018, effective in the 2019-2020 edition.  

Now, PHMSA is following suit and assuring shippers that the burdensome 2-mm border line requirement will be addressed in an upcoming rulemaking. 2018 is a “harmonization year” for PHMSA, meaning a rule to adopt new or updated international standards is already on the docket for this year.
 

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Tags: DOT, hazmat shipping, marks and labels, new rules, PHMSA