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Hazardous Materials: Labeling

9 questions in the bank cover this topic. Everything below is drawn from the sources those questions cite.

Sources: 49 CFR 172.313, 49 CFR 172.401, 49 CFR 172.402, 49 CFR 172.406

What you need to know

172.405(c), referenced at 172.313(d), permits PG III adjacent to the POISON label.

It signals the least severe of the three packing groups within Division 6.1.

For a packaging containing a Division 6.1 PG III material, “PG III” may be marked adjacent to the POISON label.

49 CFR 172.313

172.401(a) requires both conditions.

A label that does not match the contents is prohibited, because a false label misdirects responders as badly as no label at all. The package must contain that hazardous material.

no person may offer for transportation and no carrier may transport a package bearing a label specified in this subpart unless: (1) The package contains a material that is a hazardous material, and (2) The label represents a hazard of the hazardous material in the package.

49 CFR 172.401

172.401(b) bars look-alikes.

A company logo in a diamond on a colored background could read as a hazard label at a distance, which is exactly the confusion the rule prevents. Color, design or shape can each cause the confusion.

No person may offer for transportation and no carrier may transport a package bearing any marking or label which by its color, design, or shape could be confused with or conflict with a label prescribed by this part.

49 CFR 172.401

172.401(d) requires all three conditions together.

The not-visible condition matters: a labeled empty package hidden inside a trailer misleads nobody, but one on an open flatbed would. All three conditions must hold together, and the loading and unloading must be done by the shipper or consignee.

The provisions of paragraph (a) of this section do not apply to a packaging bearing a label if that packaging is: (1) Unused or cleaned and purged of all residue;

49 CFR 172.401

172.402(b) puts it in the lower corner of both primary and subsidiary labels.

Note a subsidiary label carries the number too, so the number alone does not tell you which hazard is primary.

The appropriate hazard class or division number must be displayed in the lower corner of a primary hazard label and a subsidiary hazard label.

49 CFR 172.402

172.402(a)(1) points to column 6 for primary and subsidiary labels.

Column 3 is where Forbidden appears under 173.21(a), so the two columns answer different questions.

Shall be labeled with primary and subsidiary hazard labels as specified in column 6 of the § 172.101 table

49 CFR 172.402

172.406(a)(1)(i) excludes the bottom.

A label nobody can see without lifting the package is no use to a handler deciding how to treat it.

Be printed on or affixed to a surface (other than the bottom) of the package or containment device containing the hazardous material

49 CFR 172.406

172.406(a)(1)(ii) keeps the label and the shipping name together where size allows.

Seeing the hazard symbol and the material's name in one glance is faster and less error-prone than hunting for both.

Be located on the same surface of the package and near the proper shipping name marking, if the package dimensions are adequate

49 CFR 172.406

172.406(a)(1)(iii) places them opposite each other so one is visible from any approach.

If the package is too small to fit two without overlap, one is acceptable provided it does not overlap itself.

In the case of cylindrical packages containing radioactive materials, which require two identical labels, these labels must be centered on opposite points of the circumference and must not overlap each other.

49 CFR 172.406

Check yourself

Answers are in the practice test for this topic.