Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows of – the regulations.
- Q. Customer called and asked if their company name was required to be printed on the new lithium battery mark when shipping by ground within the U.S.
- A. No, that is not a requirement. Per 173.185 (c) (3) (i), it states the following must be printed on the label: The “*” must be replaced by the appropriate UN number(s) and the “**” must be replaced by a telephone number for additional information.
- Q. Regarding Canadian address/phone number, do you know how a wholesaler company can market in Canada without a Canadian address? For obvious reasons, there will be multiple suppliers that could be selling our products.
- A. This situation could be covered by the Hazardous Products Regulation (HPR) s. 5.9(2) or 5.15(1).
The requirement for having a label with the (Canadian) initial supplier identifier is invoked by the Act (HPA) s. 14b).
HPR s. 5.9(2) allows an employer to import with only the foreign supplier identifier on an otherwise compliant label if it’s for use in their own workplace.
HPR s. 5.15(1) exempts importers from having a compliant label as long as they can prove (5.15(2)) that they will ensure it’s labeled legally before it’s Continue Reading…