Regulation

172.401(c) and 172.407(f)

Regulation summary

Sections 172.401(c) and 172.407(f) establish the general requirements for prohibited labeling and label specifications.

Question/dilemma

In this scenario, a carrier requests clarification of the hazardous materials regulations (HMR) applicable to receiving packages from overseas that may stay in inventory before reoffering the packages (in this case, packages containing batteries) into transportation. The labels on the packages display the word “corrosive” in both English and Japanese. The carrier asks if the packages may be reoffered into transportation with the Japanese words on the labels.

In this interpretation, PHMSA addresses the HMR applicability of prohibited labeling in reference to foreign language.

Interpretation Summary

In interpretation Ref. No. 10-0042, PHMSA advises that except for materials poisonous by inhalation, labels conforming to specifications in the UN Recommendations on the Transport of Dangerous Goods may be used in place of the corresponding label under the HMR 172.401(c) and 172.407(f).

• These labels may contain text indicating the hazard in the language of the country from which a shipment originates and may continue to be displayed when they are reoffered into transportation, regardless of the length of time the packages are held in inventory.
• With respect to English wording on labels, for Classes 1, 2, 3, 4, 5, 6, and 8 hazardous materials, text indicating a hazard is not required on a primary or subsidiary label.
• However, the text may continue to be displayed when the package is reoffered into transportation.
• Therefore, the Japanese wording is acceptable on labels when the shipment is received from overseas.