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Marking
- Two different hazardous materials (i.e., different shipping names and identification numbers) in non-bulk packages are loaded onto a motor vehicle at one facility in quantities exceeding an aggregate gross weight of more than 4,000 kg (8,820 lbs.) for each material. Must the motor vehicle display the identification number for each material?
- Is an identification number marking required on a transport vehicle or freight container containing non-bulk packages of materials poisonous by inhalation?
- What are the requirements for marking a transport vehicle or freight container containing lading which has been fumigated?
- May the International Maritime Dangerous Goods Code (IMDG) label for limited quantity shipments, with the UN identification number for the material in a white square-on-point diamond, be used to meet the marking requirements for limited quantity shipments under § 172.315 of the HMR?
- What markings are required on overpacks?
- Where must the markings describing a hazardous material appear on the package?
- Can markings used to describe a hazardous material be handwritten?
- What are the size requirements for markings?
- Two different hazardous materials (i.e., different shipping names and identification numbers) in non-bulk packages are loaded onto a motor vehicle at one facility in quantities exceeding an aggregate gross weight of more than 4,000 kg (8,820 lbs.) for each material. Must the motor vehicle display the identification number for each material?
No. The identification number marking display applies only when 4000 kg (8,820 pounds) or more of a single hazardous material (i.e., one shipping name and identification number) in non-bulk packagings are loaded at one loading facility. See § 172.301(a)(3) and the following examples
- ID# Required
- > 4000 kg (8,820 pounds) of hazmat at one loading facility; and consists of only one hazardous material with the same proper shipping name and identification number.
- ID# NOT Required
- < 4000 kg (8,820 pounds); or not all the same hazardous material on vehicle.
- Is an identification number marking required on a transport vehicle or freight container containing non-bulk packages of materials poisonous by inhalation?
When a transport vehicle or freight container is loaded at one loading facility with more than 1,000 kg (2,205 pounds) of non-bulk packagings containing a single hazardous material (i.e., marked with the same proper shipping name and identification number) that is poisonous by inhalation in Hazard Zones A or B, the identification number for that material must be displayed on the transport vehicle or freight container, as prescribed in § 172.313(c).
When a transport vehicle or freight container is loaded at one loading facility with more than 1,000 kg (2,205 pounds) of non-bulk packagings containing a single hazardous material (i.e., marked with the same proper shipping name and identification number) that is poisonous by inhalation in Hazard Zones A or B, the identification number for that material must be displayed on the transport vehicle or freight container, as prescribed in § 172.313(c).
- What are the requirements for marking a transport vehicle or freight container containing lading which has been fumigated?
A. A transport vehicle or freight container in which the lading has been fumigated with any material, or is undergoing fumigation, is considered a package containing a hazardous material, unless it has been sufficiently aerated so that it does not pose an unreasonable risk to health and safety. Fumigated transport vehicles or freight containers may not be offered into transportation or transported unless they prominently display a fumigant marking (see §§ 172.302(g) and 173.9) that can be seen by any person attempting to enter the interior of the transport vehicle or freight container.
![](https://webarchive.library.unt.edu/eot2008/20080916113931im_/http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/danger.gif)
- May the International Maritime Dangerous Goods Code (IMDG) label for limited quantity shipments, with the UN identification number for the material in a white square-on-point diamond, be used to meet the marking requirements for limited quantity shipments under § 172.315 of the HMR?
A. Yes. As specified in § 172.315, except for transportation by aircraft, marking the package with the identification number inside a white square-on-point configuration identifies the material as a limited quantity and fulfills the requirements of § 172.301(a)(1). If a shipper uses this method to identify packages containing limited quantities, the shipper is not required to mark the proper shipping name or technical name on the outer package. The letters “RQ” must be marked in association with the limited quantity marking when the package contains a reportable quantity of a hazardous substance. The name(s) of the hazardous substance must be marked, in parentheses, in association with the identification number on the package. If the material contains two or more hazardous substances, the names of at least two hazardous substances, including the two with the lowest reportable quantities (RQs), must be marked on the package. For a hazardous waste, the waste code (e.g., D001), if appropriate, may be used to identify the hazardous substance.
![](https://webarchive.library.unt.edu/eot2008/20080916113931im_/http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/un1263.gif)
- What markings are required on overpacks?
A. Section 173.25(a)(4) requires an overpack to be marked with the word “OVERPACK”, unless the specification markings on the inside packages are visible or the packages inside the overpack are not required to be specification packages. The overpack must also be marked with the proper shipping name, identification number, and orientation arrows, when applicable, and be labeled as required for each hazardous material contained therein, unless the markings and labels for each hazardous material in the overpack are visible.
- Where must the markings describing a hazardous material appear on the package?
A. As specified in § 172.304, markings must be durable, in English, printed on or affixed to the surface of a package using a label, tag, or sign. The markings must be displayed on a sharply contrasting background and must be unobscured by labels or attachments and must be located away from any other marking (such as advertising) that could substantially reduce their effectiveness.
- Can markings used to describe a hazardous material be handwritten?
A. Yes, provided the handwritten markings satisfy the applicable HMR requirements for size, location, durability and display. See § 172.304.
- What are the size requirements for markings?
A. For non-bulk packagings, markings may vary in size provided they are clearly visible. Except as otherwise provided by the HMR, markings on bulk packagings must have a width of at least 6.0 mm (0.24 inch) and a height of at least 100 mm (3.9 inches) for rail cars; have a width of at least 4.0 mm (0.16 inch) and a height of at least 25 mm (one inch) for portable tanks with capacities of less than 3,785 L (1,000 gallons) and intermediate bulk packagings (IBCs); and, have a width of at least 6.0 mm (0.24 inch) and a height of at least 50 mm (2.0 inches) for cargo tanks and other bulk packagings. See § 172.302(b).
For UN specification non-bulk packagings and IBCs, the specification markings must be at least 12.0 mm (0.47 inches) in height except that for packagings of less than or equal to 30 L (7.9 gallons) capacity for liquids or 30 kg (66 pounds) capacity for solids the height must be at least 6.0 mm (0.2 inches). For packagings having a capacity of 5 L (1 gallon) or 5 kg (11 pounds) or less, letters and numerals must be of an appropriate size. See §§ 178.3 and 178.703.
For DOT specification cylinders, the specification marking must be at least 0.25 inch, or as space permits (see § 178.35(f)).
Additional size requirements for specification markings on cargo tanks, portable tanks, tank cars and UN specification cylinders are as follows:
- Cargo tanks: see Part 178, Subpart J
- Portable tanks: see Part 178, Subpart H
- Tank cars: see Part 179.
- UN cylinders: see § 178.71(o).
Last Updated: Mar 26, 2008
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