A question, June 08, 2020:

Good morning Daniel,

We are planning to package and ship 1 gallon contains of Isopropyl alcohol 70% in boxes of 4 gallons per box.

We plan to mark the box with a label that describes the contents and the  4” flammable placard.

As long as the UN code (UN1219, Isopropyl alcohol, 3, PGII) and the  flammable pictogram are on the on the market label,  will this meet Dot regulations?

I appreciate your assistance.

It took me a week, but by June 15th I had a reply:

Thank you for contacting me. Please see below.

• What you describe will meet the package mark & labeling requirements of USDOT/PHMSA. (A picture would be helpful).
• However, there is more to the USDOT/PHMSA Hazardous Materials Regulations:
  • The packaging must be authorized by the regulations as indicated in column 8B of the Hazardous Materials Table, meet the DOT specification (i.e., UN Standard), and be closed per the closure instructions provided by the packaging manufacturer.
  • Class 3 HazMat label (not placard) must be displayed on the package.
  • ID # (12 mm high) & proper shipping name must be displayed as marks on the package.
  • Name of shipper or receiver marked on package.
  • Orientation arrows must be displayed on two opposite vertical sides of package.
  • Shipping paper which includes:
    • HazMat’s basic description
    • Total quantity of HazMat
    • Number and type of packaging
    • Emergency information
    • Shipper’s certification
  • Placards for Class 3 Flammable Liquid must be displayed on all four sides of the transport vehicle if the weight of the HazMat is more than (454 kg) 1,001 lbs.

And…

• • HazMat Employee training (initial & triennial) must be provided to any person with a direct affect on its safe transportation.

• Pictogram and description of contents are requirements of OSHA and not USDOT/PHMSA.

I left a vmail message as well. Please contact me with any other questions.

June 15, 2020. Satisfied with the answer:

Thanks for the information, Daniel.

Conclusion:

Often the questions I receive apply to only one aspect of the regulations. Not knowing the questioners level of knowledge of the Hazardous Materials Regulations I try to inform them of all of their responsibilities. It’s a lot to learn, remember, and keep straight. Periodic high-quality training (mine!) can help. My USDOT/PHMSA HazMat Employee training webinars are live, interactive, monthly, done in three (3) hours, and only $189/trainee.