In the July 20th, 2011 edition of the US Federal Register, the United States Department of Transportation’s (USDOT) Pipeline & Hazardous Materials Safety Administration (PHMSA) published a final rule under [Docket No. PHMSA–2009–0151 (HM–218F)] under which the agency, among many other things, set forth new specifications and requirements governing the appearance of the Class 9 Hazard label. In a nutshell, PHMSA removed the horizontal line that enclosed the bottom of the vertical stripes on the label:
Old Hazard Class 9 label: This is what a pre-7/20/2011 label looked like (other than size)
Current Hazard Class 9 label: Under the new provisions in US 49 CFR 172.446, the appearance of the label was recast, thus (other than size)
Note the removal of the horizontal line. This was done in order to conform US transport regulations in this area more closely to those of the United Nations Model Regulations (UNMR). The appearance of the “new” label matches that of the UNMR. There was also some anecdotal evidence within the DG industry that the US labels were running into trouble or delay in the EU, so the action may have been intended in part to help smooth the path for US trade in that sector.
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Along with the mandate for the new style label came direction on how long the old style label could be used, in order to allow drawdown of stock. This is commonly called the transition period, and in the rule PHMSA set October 1st, 2014 as the date that the old style label would no longer be authorized for use. As this date approaches, there seems to be a certain increase in the anxiety level of shippers as a variety of information sources report on the upcoming deadline. Some people are misconstruing the approaching date as the date at which yet another new Class 9 label is to make its appearance, not understanding that the “new” label has been authorized for use (i.e. as “voluntary compliance”) and indeed in common use since the late summer of 2011. At Labelmaster, Class 9 labels were modified almost immediately to reflect the new requirements, for example. Here is a link to our product page in this category:
http://www.labelmaster.com/shop/labels/hazmat-labels/hazard-class-9
Here is a link to the final rule which implemented this requirement and provided guidance on the currently authorized transition date:
http://www.gpo.gov/fdsys/pkg/FR-2011-07-20/pdf/2011-17687.pdf
At time of writing, there are efforts underway in the DG industry to seek an extension of the transition date from PHMSA beyond October 1st, 2014, to allow further depletion of remaining stocks, particularly of pre-labeled packaging. To date this effort has not prompted action from PHMSA; however, it is not unknown for there to be what amounts to last minute reprieves related to this type of activity, so the final outcome of any decision to provide a further extension remains to be seen.
It is also important to note that the corresponding Class 9 Placard for domestic service has had no change implemented to its appearance, and remains the same as it has been. Here is an example of a compliant domestic placard (except for size). The corresponding international placard, however, does approximately mirror the appearance of the label, thus (except for size):
Current Hazard Class 9 Placard — U.S. Domestic
Current Hazard Class 9 Placard — International
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