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Labels
  • Regulations for labels contain requirements for design, use, placement, prohibitions, and exceptions.

Labels are printed on or affixed to non-bulk packages containing hazardous materials. Labels are color- and symbol-coded to provide easy and immediate warning of hazardous materials inside the package. The Hazardous Materials Regulations (HMR) have specific requirements for design, use, placement, prohibitions, and exceptions for labels.

Labeling requirements apply primarily to non-bulk packagings. However, the following packages must also display labels if they are not placarded:

  • Bulk packagings with a volumetric capacity of less than 640 cubic feet (18 cubic meters), other than cargo tanks, portable tanks, or tank cars;
  • Portable tanks with less than 1,000 gallons (3,785 L) of capacity;
  • DOT Specification 106 or 110 multi-unit tank car tanks; and
  • Overpacks, freight containers, or unit load devices of less than 640 cubic feet (18 cubic meters) that contain a package for which labels are required.

Who is responsible for labeling, and what are the requirements?

Anyone offering or accepting a hazardous material for shipment must ensure the package is labeled according to applicable sections of the HMR.

Once a material has been classified and a proper shipping name has been selected, determining the appropriate labels is a fairly easy process:

  1. Locate the selected proper shipping name in Column (2) of the Hazardous Materials Table (HMT).
  2. Refer to Column (6) of the HMT for the appropriate label code(s).
  3. The first label code listed indicates the material’s primary hazard. Any additional label codes indicate subsidiary hazards.
  4. Using the label codes from Column (6) in the HMT, find the name of the label(s) required to be on the package in the label substitution table in 172.101(g).

Except for the 6.1 label code, the label codes are the same as the hazard classes or divisions, and only one label is possible. For example, a 2.3 label code is a 2.3 (poison gas) label, a 3 label code is a Class 3 (flammable liquid) label, and a 5.1 label code is a 5.1 (oxidizer) label.

For the 6.1 label code, there are two possible labels. If the material has an inhalation hazard, Zone A or B, a “Poison Inhalation Hazard” label is required. If the material does not have an inhalation hazard, Zone A or B, a “Poison” label is required.

Each package containing a hazardous material must be labeled with the label(s) prescribed in Column (6) of the Hazardous Materials Table.

If the material has more than one hazard, all applicable subsidiary labels may not be listed in the table, such as generic or not otherwise specified (n.o.s.) shipping names. If this is the case, subsidiary labels must be determined according to 172.402.

A Division 6.1 subsidiary label is not required on a package containing a Class 8 material that has a subsidiary hazard of Division 6.1 if toxicity of the material is based solely on corrosive destruction of tissue rather than systemic poisoning. Also, a Division 4.1 subsidiary label is not required on a package bearing a Division 4.2 label.