Labeling
New Hazard Class Label Requirements

Red semi truck on highway

Updated Hazard Class Label Requirements

Stemming from the UN Sub-Committee of experts on the Transportation of Dangerous Goods 40th session, December 2011, and adopted by IMDG, IATA, and PHMSA (US DOT) in 2015. This change to all Hazard Class labels, became mandatory January 1, 2017 for air and ocean shipments. HM-215N issued on March 30, 2017 amended section 172.407 to allow an additional transition period to December 31, 2018 for ground shipments in the USA.

What’s Changed?

This inner line must be 2mm width and also remain at 5mm inside the outer edge even if a reduced size label is allowed.
Note, this is not mandatory for TDG (Canada ground, but will likely become mandatory in future), but customers who ship by ground and air, or ground, air, and ocean will want the consistency now.

Class 3 Label With thick border
New Border

Class 3 Label With thin border
Old Border

The width of the inner border was never previously defined. This change allows for consistency and the wider thickness to make the label more visible.

ICC The Compliance Center is your source for Hazard Class Labels. Our regulatory staff at ICC Compliance Center will be happy to help. Just contact us at 1.888.442-.628 (USA) or 1.888.977.4834 (Canada).

PHMSA Update
Finally . . . HM-215N

Final Rule HM-215N

At long last, HM-215N is officially in place. The Department of Transportation was published in the Federal Register on Thursday, March 30, 2017. This much-anticipated final rule harmonizes the 49 CFR regulations with the United Nations Recommendations on the Transport of Dangerous Goods—Model Regulations (UN Model Regulations), International Maritime Dangerous Goods Code (IMDG Code), and the International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions).

Some of the Notable Changes from HM-215N Include:

New entries in the hazardous materials table (HMT) including:

  • UN3527 Polyester Resin Kit, solid base material
  • UN3528 Engine, internal combustion, flammable liquid powdered or Machinery, internal combustion, flammable liquid powered
  • UN 3529 Engine, internal combustion, flammable gas powered or Engine, fuel cell, flammable gas powered or Machinery, internal combustion, flammable gas powered or Machinery, fuel cell, flammable gas powered
  • UN 3530 Engine, internal combustion or Machinery, internal combustion

Amended Proper Shipping names

UN 3151, Polyhalogenated biphenyls, liquid or Polyhalogenated terphenyls, liquid and

UN 3152, Polyhalogenated biphenyls, solid or Polyhalogenated terphenyls, solid by adding “Halogenated monomethyldiphenylmethanes, liquid” and “Halogenated monomethyldiphenylmethanes, solid”

New Special provisions including:

New special provision 422 is assigned to the HMT entries “UN 3480, Lithium ion batteries including lithium ion polymer batteries“; “UN 3481, Lithium ion batteries contained in equipment including lithium ion polymer batteries; “UN 3481 Lithium ion batteries packed with equipment including lithium ion polymer batteries“; “UN Continue Reading…

PHMSA Update
A Small Victory for Harmonization … For Now (HM-215N)

PHMSA Withdraws Final Rule

—PHMSA Update HM-215N

The Pipelines and Hazardous Materials Safety Administration (PHMSA) of the Department of Transportation (DOT) has withdrawn a Final Rule that was intended to be published in the Federal Register on January 26.

The Final Rule, HM-215N, would have updated the U.S. “Hazardous Materials Regulations” to reflect international standards. This was due to the new administration’s Regulatory Freeze executive memorandum, issued January 20, 2017.

Harmonization

HM-215N would have harmonized the 49 CFR regulations to the latest version of the UN Recommendations on the Transport of Dangerous Goods, the ICAO Technical Instruction’s on the Safe Transport of Dangerous Goods, the International Maritime Dangerous Goods Code.

New lithium battery label     New Lithium Battery Mark and Pictogram
New marks and labels introduced in the upcoming international regulations.

 

This delay has made it particularly confusing for shippers of lithium batteries, who have transitioned to the new handling mark, and hazard class 9 label, shown in these international regulations.

Usage

Last week, PHMSA issued a Notice that allows offerors and carriers to use the 2017-2018 versions of the international regulations without fear of enforcement. In addition, it is allowing users to mark and label packages in accordance with either the 2015-2016 or 2017-2018 IATA/ICAO and IMDG regulations.

This notice is limited to 49 CFR Parts 171.4(t) and (v). This notice is expected to be in place until HM-215N is release, or this notice is otherwise rescinded or otherwise modified.

For a full version of the Continue Reading…