New Minimum Size Requirements for Hazmat Package Markings Expected to Take Effect in 2013

Hazmat shippers will want to take note of new UN recommendations regarding minimum dimension requirements for package markings that could have an effect as soon as next year.

The 17th edition of the UN Recommendations on the Transport of Dangerous Goods – Model Regulations requires that the UN number marked on packagings must meet minimum size dimensions depending on the packaging capacity or weight. Chapter 5.2, Marking and Labelling, Paragraph 5.2.1.1, was revised by inserting a new sentence:

“The UN number and the letters ‘UN’ shall be at least 12 mm high, except for packagings of 30 litres or 30 kg capacity or less, when they shall be at least 6 mm in height and for packagings of 5 litres or 5 kg or less when they shall be of an appropriate size.”

This new requirement is expected to come into force via the upcoming editions of the International Civil Aviation Organization’s Technical Instructions on the Safe Transport of Dangerous Goods by Air (ICAO TI 2013-2014 edition), the International Maritime Dangerous Goods Code (IMDG Code Amendment 36), the European Road and Rail Regulations (ADR/RID) and the U.S. Hazardous Materials Regulations (HMR; 49 CFR, Part 100-180).  The ICAO TI typically does not provide for a transition period for implementing new requirements; if adopted by ICAO as is, the new minimum dimension requirements could take effect as soon as Jan. 1, 2013. The IMDG Code typically authorizes immediate voluntary compliance (e.g. from Jan. 1, 2013) with a one-year transitional period for new amendments (e.g. Jan. 1, 2014).  The ADR/RID typically authorize a six-month transition period (see Chapter 1.6 Transitional Measures) that would require compliance by June 30, 2013. PHMSA typically authorizes a one-year transition in their HM-215 series of rulemakings.  The HM-215L Notice of Proposed Rulemaking that should address this new requirement is expected to be published in the next few weeks.

It should be noted that this change only applies to the UN number and does not apply to the proper shipping name.

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Those that offer or prepare packagings for hazardous materials should be cognizant of these pending requirements in order to avoid potential shipping violations.  Labelmaster is currently in the process of increasing the minimum size of UN numbers on all affected hazmat labels to ensure they are fully compliant in advance of deadlines imposed by the various regulatory bodies.  Please contact us at 800-621-5808 if you have questions about these new requirements.

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  1. Desmond WAIGHT (DGSA - All classes by road/rail/inland waterway) said:

    UN Orange Book quite surprisingly added a start date for this new minimum size. (See UN 17th; note under 5.2.1.1)
    .

    ADR is scheduled to (change in Chapter 1.6 to add 1.6.1.25 setting mandatory date from 1.1.2014 ) in the already available list of agreed draft amendments (ECE/TRANS/WP.15/213). I expect others to follow this, where involves introducing a new minimum. IATA already has this minimum size requirement (see 7.1.5.5), but without the reduction possibility to less than 6 mm for under 5kg/l. IATA rules also apply to PSN.

  2. Desmond WAIGHT (DGSA - All classes by road/rail/inland waterway) said:

    UN Orange Book quite surprisingly added a start date for this new minimum size. (See UN 17th; note under 5.2.1.1)
    .

    ADR is scheduled to (change in Chapter 1.6 to add 1.6.1.25 setting mandatory date from 1.1.2014 ) in the already available list of agreed draft amendments (ECE/TRANS/WP.15/213). I expect others to follow this, where involves introducing a new minimum. IATA already has this minimum size requirement (see 7.1.5.5), but without the reduction possibility to less than 6 mm for under 5kg/l. IATA rules also apply to PSN.

  3. Pingback: PHMSA International Harmonization Rule HM-215L Further Aligns the Hazardous Materials Regulations with International Rules | Labelmaster Blog

  4. Pingback: PHMSA International Harmonization Rule HM-215L Further Aligns the Hazardous Materials Regulations with International Rules | Labelmaster Blog

  5. Dan Morris said:

    Does anyone know if this also applies to the CFR 49 as well? or only IMDG/IATA/ICAO?

  6. Dan Morris said:

    Does anyone know if this also applies to the CFR 49 as well? or only IMDG/IATA/ICAO?

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