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An Overview of Hazmat Label Requirements

By August 6, 2018 No Comments

The packaging and shipping of hazardous materials are highly regulated across various industries for all modes of transportation. The regulations are extensive, starting with the definitions of what is a hazardous material, including the type of packaging required and how that packaging must be labeled to clearly inform everyone that may come in contact with that package through its transit what’s contained inside. This article is intended to be an overview of the types of classifications of labels, design and placement. It is a regulatory obligation of each and every shipper to assure that the materials deemed hazardous are packaged properly and that includes being affixed with proper labeling or placards.

Please note that this summary is informational only and is not intended to be used as a guide to compliance.

Hazmat Label Classifications

Hazmat labels are divided into nine classes and defined with government standards 49 CFR 172.411 through 172.448, where CFR stands for Code of Federal Regulations1, 49 refers to the title and 172 denotes the part within the title.

  • Class 1 – Explosives – 172.411 – These will include items such as fireworks, ammunition and ignitors as they are materials designed to explode under the proper conditions.
    • This category is further subdivided into 1.1, 1.2, 1.3, 1.4, 1.5 and 1.6 for each specific classification.
  • Class 2 – Gases – 172.415-172.417 – Materials such as natural gas, compressed air, methane and fire extinguishers are regulated with these standards as they are all gases compressed to very high levels of pressure and can become potentially dangerous in certain conditions.
    • This category is subdivided into three: 2.1 (flammable), 2.2 (non-flammable) and 2.3 (poisonous).
  • Class 3 – Flammable liquids – 172.419 – This will include items such as paints, kerosene and gasoline that are flammable under proper ignition conditions.
  • Class 4 – Flammable solids – 172.420, 172.422, 172.423 – Items such as oily fabrics, metal powders, carbon and matches are included in these three codes where can provide hazardous environments under specific conditions whether it be near an ignition source, wet or even spontaneously combustible.
    • This class is subdivided into 4.1 (flammable solid), 4.2 (spontaneously combustible) and 4.3 (dangerous when wet)
  • Class 5 – Oxidizers and organizer peroxides – 172.426 and 172.427 –Items such as hydrogen peroxides, chlorates and nitrates can be classified within these CFR codes where an inert environment is essential to keep these materials stable.
    Oxidizers are further subdivided into section 5.1 and organic peroxides into section 5.2.
  • Class 6 – Toxic substances – 172.429, 172.430, 172.432 – These types of items include acids, medical waste and dyes. They can be poisonous to people or very toxic when handled by people.
    This class is subdivided into 6.1 and 6.2.
  • Class 7 – Radioactive substances – 172.436, 172.438, 172.440, 172.441, 172.450 – These include materials that contain radioactive matter such as medical isotopes, fission products and nuclear waste. The scale can be quite different between medical isotopes and nuclear waste but all are classified under Class 7.
  • Class 8 – Corrosives – 172.442 – These can include batteries, paints and fuel cell cartridges where the makeup of the materials can cause quick corrosion.
  • Class 9 – Miscellaneous hazards – 172.446 – These are materials that do not fit into the other eight classes and currently include lithium-ion batteries, vehicles and dry ice. Please read the standard for further clarification.

Hazmat Label Requirements and Specifications

Hazmat label requirements and specifications are defined through government agencies EPA (Environmental Protection Agency) and DOT (Department of Transportation), specifically, 49 CFR part 172.407 subpart E1. The EPA sets forth standards for environmental protection to the public and the DOT ensures that anything that is being transported from an industrial or commercial point of view is regulated to ensure safety to the people of the United States. The requirements are bucketed into the following categories:

  • Durability
    • The packaging must withstand a 30-day exposure to conditions typical of transport of the labeled package which could involve high or low temperature, humidity and precipitation.
      • To pass the test, the package must show no deterioration or significant change in color.
    • Design
      • The printing, inner border and symbol of each label must be identical as shown in 49 CFR 172.411 through 172.448.
    • Size
      • The shape must be a diamond (square on point) and have dimensions of 3.9 in (100 mm) on each side.
      • Each side must have a solid line inner border 5 mm inside and parallel to edge.
      • The width of the solid line border must be at least 2 mm.
      • Cargo Aircraft-Only
        • The sign must be a rectangle measuring at least 3.9 in. (110 mm) in height and 4.7 in. (120 mm) in width.
        • The words “CARGO AIRCRAFT ONLY” must be shown in letters at least 0.25 in. (6.3 mm) in height.
      • The hazard class number or division number must be at least 0.25 in (6.3 mm) and not greater than 0.5 in. (12.7 mm).
        • For SPONTANEOUSLY COMBUSTIBLE or DANGEROUS WHEN WET labels, the words “spontaneously” and “when wet” must be shown in an appropriate font size.
      • Color
        • The label background must be the same as prescribed in 49 CFR 172.411 through 172.448.
        • All symbols, text, numbers and borders must be black except:
          • White may be used if the background is green, red or blue.
          • White must be used for text and class number for CORROSIVE.
          • White may be used for ORGANIC PEROXIDE symbol.
        • All colors must withstand a 72-hour fadeometer test (ASTM G23-69 or 26-70) without a significant change in color.
        • The color must fall within color tolerances specified in Appendix A of 49 CFR 172.407.
        • The color standards will adhere to the Pantone color guide noted below and will be tested via spectrophotometer for a proper color match.
          • Red – Pantone 186U
          • Orange – Pantone 151U
          • Yellow – Pantone 109U
          • Green – Pantone 335U
          • Blue – Pantone 285U
          • Purple – Pantone 259U
        • Specified label colors must extend to edge of label except for CORROSIVE, RADIOACTIVE YELLOW-II, and RADIOACTIVE YELLOW-III, which must extend only to the inner border.
      • Identification
        • The labeling must include the name of the manufacturer.
        • It should be printed outside the solid-line inner border with a maximum font size of 10-point.
      • Exceptions
        • Except for materials poisonous by inhalation, a label meeting the UN Recommendation (to Hazmat labeling), IBR 171.7, may be used in place of the label standards set by 172.407.
      • Trefoil symbol
        • RADIOACTIVE WHITE-I, RADIOACTIVE YELLOW-II AND RADIOACTIVE YELLOW-III labels must meet the standards of Appendix B of CFR 172.407.

Hazmat Label Placement

Placement of labels on hazmat materials is defined within United States federal regulation 49 CFR 172.406. The Code of Federal Regulations guides the shipment of hazmat materials using part 172.46 within title 49. The guidelines set forth by this standard are:

  • Placement
    • The label must be printed on or affixed to a surface of the package or containment.
    • The label must be located on the same surface of the package and near the shipping name marking.
    • If primary and subsidiary hazard labels are required, they must be displayed with 6 inches of each other.
  • Duplicate Labeling
    • Necessary for:
      • Packaging with a volume of 64 cubic feet or more
      • Non-bulk packaging that contains radioactive material
      • DOT 106 or 110 multi-unit tank car tanks
      • Portable tanks that carry less than 1,000 gallons
      • Freight or aircraft containers with a volume of 64-640 cubic feet
      • Intermediate bulk containers with a volume of 64 cubic feet or more
    • Visibility
      • The labels must not be obscured by markings or attachments.
      • The label colors must contrast the background they have been printed or affixed to.

What Types of Packaging Must be Labeled?

Per 49 CFR 172.400, listed below are the types of packages where hazmat labels are necessary if the package contains hazardous material. Exceptions to this standard can be found in 49 CFR 172.400a.

  • Non-bulk packaging
  • Bulk packaging, unless a cargo tank, portable tank or tank car with a volumetric capacity of less than 640 cubic feet
  • Portable tank less than 1000-gallon capacity
  • DOT 106 or 110 multi-unit tank car tank
  • An overpack, freight container or unit load device less than 640 cubic feet volume

For more information about a shipper’s obligations, click here.