Question:

Good morning I was on your web site looking for some information as it pertains to application of the class 9 lithium battery.

My questions is do we have to buy labels and hand apply it or can we direct flexo print the diamond to spec. we print a lot of UN Corrosive diamonds on corrugated and I would like to do so with this class 9.

We have a very bright white that we print and are able to over print the BK with no wet out keeping it very legible. Is this option ?

Thank you

Answer:

Thank you for contacting me. In short, it is not necessary to purchase labels and hand apply them to a package that requires the display of labels. The use of the word “labels” by the Hazardous Materials Regualtions of USDOT/PHMSA is unfortunate since it leads one to believe a separate adhesive-backed label (aka: a sticker) must be affixed to the package. The language at the beginning of 49 CFR 172.407 Label specifications reads, “…Each label, whether printed on or affixed to a package…” So, the label may be pre-printed on the packaging or it may be affixed.

§172.407 goes on to describe the specifications for a label’s durability, design, size, and color. As long as the label meets the design specificaitons of §172.407 it can be purchased or made by the shipper.

Read: HazMat Label Specifications

Additional specifications for and an image of the Class 9 Lithium Battery label are at §172.447.

Please contact me with any other questions.

Conclusion:

And that did it!

This answer applies to all hazard communication of the HMR, whether it be labels, marks, or even placards! Who made it and how doesn’t matter as long as it meets the specification for its design and the regulations for its display.