General Marking Requirements for Non-Bulk Packagings of HazMat

PHMSA HazMat Transportation Regulations

General Marking Requirements for Non-Bulk Packagings of HazMat

Daniel Stoehr
February 25, 2013

The shipper of a hazardous material (HazMat) must ensure the correct hazard communication methods are used to identify the potential hazards posed by the material offered for transportation.  The four hazard communication methods required by the US DOT when offering a hazardous material for shipment are:

  • Shipping Papers
  • Placards
  • HazMat Labels
  • Markings

Of these four, HazMat Labels and Markings are the methods a HazMat Employee is most likely to encounter during routine job duties since these are applied to the HazMat packaging itself.  This article will address the general marking requirements for a non-bulk packaging of a hazardous material offered for transportation in commerce (49 CFR 172.301).

First we’ll address a few key terms:

(49 CFR 171.8 – Definitions)  Marking means a descriptive name, identification number, instructions, cautions, weight, specification, or UN marks, or combinations thereof, required by this subchapter on outer packagings of hazardous materials.

  •  Bulk Packaging is defined at §171.8 as well, it means a HazMat packaging with a capacity of >119 gallons for a liquid, >882 pounds and >119 gallons for a solid, and >1,000 pounds water capacity for a gas.  So a non-bulk packaging has a capacity equal to or less than any of those thresholds.

Unless excepted elsewhere in the Hazardous Material Regulations (aka:  HMR found at 49 CFR 171-180) the markings of a non-bulk packaging of a hazardous material must include:

  • The proper shipping name for the material as indicated in column 2 of the hazardous materials table (§172.101).  If the HazMat to be shipped is a hazardous waste, the proper shipping name should be preceded by the word “Waste” unless “Waste” appears elsewhere in the proper shipping name, eg. Hazardous Waste Solid, n.o.s.  However, if the package bears the marking required by the US EPA at 40 CFR 262.32, then the word “Waste” does not need to be used.
  • The four digit identification number for the hazardous material preceded by “UN”, “NA”, or “ID” as appropriate.  The identification number is found in column 4 of the hazardous materials table.
  • Except for a Division 6.2 material (Infectious Substance or Etiological Agent), and only if required by §172.203(k), the technical name must be marked on the packaging in parenthesis and in association with the proper shipping name.
  • Except as provided in §173.23, a non-bulk HazMat packaging must be marked with the applicable special permit number preceded by either “DOT-SP”, or “DOT-E” if the package is authorized by an exemption issued prior to 10.01.07.  Of course, this marking is not required if the shipment doesn’t utilize a special permit.  Read a past article of mine to learn more about special permits, approvals and other exceptions to the HMR.
  • The name and address of the consignor (shipper) or consignee (destination or receiver).  It is not necessary to identify which entity is the consignor and which is the consignee, though it could likely prove helpful.  This requirement does not apply if the packaging is
    • Transported by highway and will not be transferred from one motor carrier to another, or;
    • “Part of a carload lot, truckload lot or freight container load, and the entire contents of the rail car, truck or freight container are shipped from one consignor to one consignee.”

Additional Requirements:

  • If the markings from a previous shipment are legible and still meet the requirements of the HMR, then the packaging does not need to be remarked for subsequent shipments.  The marking requirements for empty packagings are found at §173.29 or for more information read my article:  US DOT Requirements for the Shipment of Empty HazMat Packagings.
  • Unless excepted in §172.301, cylinders of unoderized Liquified Petroleum Gas (LPG) must be marked “NON-ODORIZED” or “NOT-ODORIZED”.

These are just the general requirements for markings on a non-bulk packaging of a hazardous material; there may be more depending on the type of the material and how it is shipped.  Additional marking requirements apply to shipments of the following:

  • Marine Pollutants
  • Poison Inhalation Hazards
  • Hazardous Substances (rep0rtable quantities of)
  • More…

My training addresses the requirements of the US DOT for the transportation of hazardous materials (which includes hazardous waste) and those of the US EPA for the management of hazardous waste (also: used oil, universal waste, and many recyclable materials).  Contact me for a free training consultation.