HAZMAT Markings for Non-bulk Packages
By Roy Marshall
President, Regulations Training, Inc.
A critical component in the U.S. Department of Transportation's (DOT) hazardous materials communication requirements is package markings. Markings allow for identification of the product during storage, handling, and transportation, and, most importantly, markings allow for quick identification of the hazardous material should a leak occur. Markings are also another item on the HAZMAT inspector's check list.
The two most important marking requirements for non-bulk packages are the proper shipping name and the identification number as either of these allow personnel to access response information in the Emergency Response Guidebook. If technical names are required on the shipping paper, they should be marked on the package, in parentheses, near the proper shipping name. Shipper or consignee's name and address should be included unless the package is 1) transported by highway only and will not be transferred from one motor carrier to another or 2) part of a truckload moving from one shipper to one consignee. Each package authorized under an exemption must be marked with "DOT-E" followed by the exemption number. With few exceptions, most liquids in combination packages must be marked with "package orientation markings" - the double up arrows - on two opposite vertical sides.
Other Marking Requirements
The letters "RQ" must be marked on any package containing a reportable quantity of a hazardous substance - listed in Appendix A to the Hazardous Materials Table. If the shipment will be transported by vessel, the marine pollutant mark should be placed on any non-bulk packages containing a marine pollutant - listed in Appendix B to the Hazardous Materials Table. Don't overlook the regulation regarding large quantities of a single hazardous material. This applies whenever you load 8,820 lbs. or more of non-bulk packages of a single hazardous material into a truck or freight container that contains no other material (hazardous or otherwise). If all the packages are marked with the same proper shipping name and identification number, then you must put the four digit identification number on all four sides of your transport vehicle. Let's say you load 9,000 lbs. of Acetone in non-bulk packages into one truck - all at one facility. You would have to place a Flammable placard on all four sides of the vehicle AND put the identification number for Acetone - 1090 - on all four sides. You could place the number in the center of each Flammable placard or you could place the "1090" on an "orange panel" next to your Flammable placard. For certain hazardous materials, e.g., miscellaneous hazardous materials in Class 9, you can put the four digit identification number in the center of a blank white placard - technically called a plain white "square-on-point display configuration."
Note: If you ship more than 2,205 lbs. of a material "poisonous by inhalation," you may also be subject to marking the identification number on the four sides of your transport vehicle. See section 172.313.
Marking Errors to Avoid
* Proper shipping name and identification number are not located on the same surface of the package as the labels - a requirement if the package is large enough for all items to fit on the same surface. See 49 CFR 172.406(a)(1)(ii).
* Proper shipping name and identification number are not located away from other markings. Package handlers or emergency response personnel should be able to readily identify the hazardous material by these markings. If they are hard to find among other package markings, it may be a violation. See 49 CFR 172.304(a)(4).
For all the details on these requirements, see 49 CFR Part 172 Subpart D. This subpart also includes additional marking requirements for materials "poisonous by inhalation," explosives, radioactive materials, and more. And, as always, watch for new regulations and changes which may affect the marking of your HAZMAT packages.
Published in Chemical Distributor, May/June 2001 Copyright © 2001, National Association of Chemical Distributors, Arlington, VA
A publication of the National Association of Chemical Distributors [NACD].
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