In Part 1, we highlighted the OSHA HazCom 2012/GHS Training Deadline and in Part 2, we highlighted the PHMSA DOT Final Rule, and in the third part in our Year-end Compliance series, we discuss the Hazardous Materials Marking requirement change.
With regards to hazardous material shipments in non-bulk quantity, shippers must mark their hazmat packages with the appropriate proper shipping name and corresponding identification number. The identification number is preceded with one of the following: UN, ID, or NA. A fairly recent change to the hazardous materials shipping regulations mandated a change to the text size of the identification number and analogous 4-digit number.
Specifically, the amended marking regulations denote that non-bulk packages conform to the following minimum requirements:
- The identification number marking preceded by “UN”, “NA”, or “ID” as appropriate must be marked in characters at least 12 mm (0.47 inches) high. Packages with a maximum capacity of 30 liters (8 gallons) or less, 30 kg (66 pounds) maximum net mass, or cylinders with a water capacity of 60 liters (16 gallons) or less must be marked with characters at least 6 mm (0.24 inches) high. Packages with a maximum capacity of 5 liters (1.32 gallons) or 5 kg (11 pounds) or less must be marked in a size appropriate for the size of the package.
- Remember that the new text size requirement does not cover nor affect the proper shipping name marking size. International and air shipments must comply with the new requirements on January 1st, 2014.
Make note that the U.S. regulations offer a transitional domestic exception. US DOT will allow relief from the new text size regulation until January 1, 2017. There is also an exception for permanently marked packagings. For domestic transportation, a packaging manufactured prior to January 1, 2017 and permanently marked (e.g., by embossing or through a heat stamp process) with the appropriate identification number marking may continue in service until the end of its useful life regardless of whether the identification number markings meet the minimum size requirements.
Though I agree with the comment that “Remember that the new text size requirement does not cover nor affect the proper shipping name marking size. ” it should be remembered that there is a requirement for the PSN to be “readily visible and legible”. This means a judgement call
The “readily visible and legible” this still also applies to the UN Number marking – so the minimum size of UN number now specified may not meet the requirement in all cases (though usually will).
IATA Commercial Requirements 7.1.5.5.2 is interpreted by airline handling agents as applying to the Proper Shipping Name and in the United Kingdom have been rejecting undersized characters in the Proper Shipping Name for some years (With a rejection fee of course).