The question (11.24.17):
Daniel,
I enjoyed watching some of your YouTube videos this week while researching Limited Quantity ground shipments and packaging requirements. (What is the Limited Quantity Exception?) You mentioned a couple times in your videos that orientation arrows are required on all limited quantity packages that contain liquids in inner packagings. I then read the below link on your website (Package Orientation Arrows on HazMat Packaging) and saw the below images of the orientation arrows for the antifreeze. The arrows appear to be blue instead of black or red as per 172.312. This also reminded me of a product that I’ve purchased in the past <<packaging name>> from <<packaging supplier>>, which also has blue orientation arrows, yet they say that their product is “Limited Quantities Tested”. I’ve sent an email to <<packaging supplier>> for clarification but wanted to ask you as well since it relates to your web posting. Are blue arrows allowed as long as they are also on a contrasting background?
Thanks,
My answer the same day:
Thank you for contacting me and thank you for viewing my videos.
**Note about the YouTube videos: In order for my channel on YouTube to be authorized I must have at least 10,000 public views. Anything you can do to encourage others to view my channel would be great.**
In answer to your question: the Hazardous Materials Regulations of USDOT/PHMSA at 49 CFR 172.312 (a)(2) require the orientation arrows to be either black or red and must be on a background that is white or other suitable contrasting background.
So, while the background does not have to be white and may be “…other suitable contrasting background”. The arrows must be “…either black or red…” Any other color for the arrows is a violation of the HMR.
I contacted the HazMat Info Line and they confirmed this interpretation.
Please don’t hesitate to contact me if you have any other questions about orientation arrows or the limited quantity exception.
Conclusion:
I admit, I was a bit surprised that the USDOT/PHMSA Hazardous Materials Regulations clearly limit the color of the orientation arrows to either black or red when it is not uncommon to see them displayed as blue. Just another example of a company violating the HMR due to its ignorance of its requirements.
As a shipper or carrier of hazardous materials, don’t let your ignorance lead to a violation. Contact me to answer your questions and to provide the training necessary for HazMat Employees.