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Hazmat Articles - DOT Poison Label Changes

New Poison Label Replaces
“Keep Away From Food” Label

Skull & Crossbones replaces St. Andrew’s Cross & Staff of Wheat on PGIII Poison Labels.

By Roy Marshall

On March 5, 1999, the Final Rule for Docket HM-215C was published, which included changing the label for poison/toxic materials that fall under the Packing Group III “PGIII” designation. In the past, on domestic shipments within the U.S. you had the option to use the KEEP AWAY FROM FOOD label instead of a POISON or TOXIC label. Use of this optional label allowed shippers and carriers to load Packing Group III poisons into the same vehicle with foodstuffs, feed, or other edible materials – as long as the packages were separated so that if the poison leaked it would not commingle with, or contaminate, any of the foodstuffs. If you used a regular POISON label with the skull & crossbones, you would not have this option; stricter segregation requirements applied.

The DOT, however, felt that this optional label, which included a staff of wheat with an X over it (see illustration) did not adequately convey the danger of these materials. Effective October 1, 1999, the DOT is removing the KEEP AWAY FROM FOOD label, and replacing it with the standard POISON label which has the skull and crossbones symbol at the top, with the number “6” at the bottom. The word Poison or Toxic may be displayed in the center of the label.

However, for domestic shipments only, DOT will allow shippers to use the POISON label with “PGIII” replacing the “Poison” or “Toxic” text. As an alternative, DOT will allow shippers to mark “PGIII” next to the POISON label. In either case, doing so will allow shippers, consolidators, and carriers to load PGIII poisons with foodstuffs subject to the limitations of the old KEEP AWAY FROM FOOD label, e.g., for highway see 49 CFR 177.841(e)(3). You can use up your supply of KEEP AWAY FROM FOOD labels [and placards] until the mandatory compliance date of October 1, 2003.

Roy Marshall is President of Regulations Training, Inc., and conducts courses on hazardous materials in both domestic and international transportation via air, highway, rail, and ocean. He can be reached at 1-800-317-0518. For more articles, information, and HAZMAT Web site links, visit RTI's Web site at www.hazardousmaterials.com.

Published in Chemical Distributor, November/December 1999 Copyright © 1999, National Association of Chemical Distributors, Arlington, VA
A publication of the National Association of Chemical Distributors [NACD].


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Roy Marshall
Regulations Training, Inc.
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