Here are the top 4 questions last week:
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.
Worded Label Requirements
- Q. Are worded labels required for use in US transport?
- A. Based on 172.405(a), except where prescribed, wording is optional on US hazard class labels.
Placement of UN Number, Shipping Name and Hazard Class Label
- Q. Can you put the “ISH” information (shipping name, UN number and hazard label) on the top of a package (e.g. box)?
- A. That depends. Different regulations express it differently, but the key message is that the information must be easily located and read; and with few exceptions in proximity to each other on the same surface of the package. All common regulations (49 CFR, Canadian TDGR, IATA DGR, IMDG Code) have a general requirement for legibility.
49 CFR requires the information to be clearly visible on a surface other than the bottom [172.304(f) and 172.304(a)(i)]- so the top could be allowed if the configuration resulted in it being clearly visible.
IATA DGR and the IMDG Code do not specify top/bottom but only require the information to be “readily visible” [IATA 184.108.40.206(a); IMDG 220.127.116.11.1, 5.2.2,1.6].
TDGR, however, is a little more prescriptive- requiring the information to be “on any side … other than the side on Continue Reading…