Identification numbers

Scope

Shippers and carriers of hazardous materials are responsible for including identification numbers on shipping papers and package markings.

Regulatory citations

• 49 CFR 172.332 — Identification number markings

Key definitions

• None

Summary of requirements

Within the hazardous materials table. Column 4 of the hazardous materials table (HMT) lists the United Nations (UN) and North American (NA) identification numbers assigned to each proper shipping name from Column 2. Those preceded by the letters “UN” are appropriate for both international and domestic transportation. Those preceded by the letters “NA” are for domestic transportation and not for international transportation — except to and from Canada. Those preceded by the letters “ID” are associated with proper shipping names recognized by the ICAO Technical Instructions.

The NA9000 series of identification numbers are for use with proper shipping names that are not appropriately:

• Covered by the international regulations or
• Addressed by the international standards for emergency response information purposes

Non-bulk packaging. For non-bulk packages, identification numbers must be marked in association with the proper shipping name. Identification numbers are not required on packages which contain only limited quantities or ORM-D materials. 172.301

The identification numbers must be at least 0.47 inches (12 mm) high. On smaller packages, 8 gallons (30 L) or less, 66 pounds (30 kg) maximum, or cylinders with a water capacity of 16 gallons (60 L) or less, the numbers must be at least 0.24 inches (6 mm) high. For even smaller packages, capacity of 1.32 gallons (5 L) or 11 pounds (5 kg) or less, the size of the numbers must be a size appropriate for the size of the package.

The size requirements for ID number markings are not mandatory until January 1, 2017. Packagings manufactured and permanently marked before January 1, 2017, with ID numbers not meeting the size requirements, may continue to be used until the end of their useful life.

Although the regulations do not specifically state where on a packaging the marking shall be placed, they do require such marking to be “durable, in English and printed on or affixed to the surface of a package or on a label, tag, or sign; must be displayed on a background of sharply contrasting color; must be unobscured by labels or attachments; and must be located away from any other marking (such as advertising) that could substantially reduce its effectiveness.” 172.304

Large quantities of non-bulk packagings. A transport vehicle or freight container containing only a single hazardous material in non-bulk packages must be marked, on each side and each end with the material’s identification number, subject to the following:

• Each package must be marked with the same proper shipping name and identification number;
• The aggregate gross weight of the hazardous material is 4,000 kg (8,820 lb) or more;
• All of the hazardous material is loaded at one loading facility; and
• The transport vehicle or freight container contains no other material, hazardous or non-hazardous.

This does not apply to Class 1 materials, Class 7 materials, or non-bulk packagings for which identification numbers are not required (such as limited quantities or ORM-D). 172.301

A transport vehicle or freight container loaded at one loading facility with 1,000 kg (2,205 lb) or more of non-bulk packages containing material that is poisonous by inhalation (in Hazard Zone A or B), having the same proper shipping name and identification number, must be marked on each side and each end with the identification number for the material. If the transport vehicle or freight container contains more than one inhalation hazard material that meets this requirement, it must be marked with the identification number for only one material. That one identification number is determined by the following:

• For different materials in the same hazard zone, the identification number of the material having the greatest aggregate gross weight.
• For different materials in both Hazard Zone A or B, the identification number for the Hazard Zone A material.

The four-digit identification number may be displayed on an orange panel, placard, or white square-on-point .

Bulk packaging. Hazardous materials identification numbers must be displayed on bulk packagings such as portable tanks, cargo tanks, and tank cars. The four-digit identification numbers may be displayed in one of several ways:

• On an orange panel measuring 160 mm (6.3 inches) by 400 mm (15.7 inches) with a 15 mm (0.6 inches) black border. The numerals are to be in 100 mm (3.9 inches) black Helvetica Medium on an orange background. 172.332
• Across the center of the primary hazard placard in 88 mm (3.5 inches) black Alpine Gothic or Alternate Gothic No. 3 numerals on a white background 100 mm (3.9 inches) high and approximately 215 mm (8.5 inches) wide and is outlined with a solid or dotted line border. 172.332
• For hazardous materials in hazard classes that do not require placards, the identification number must be displayed on either an orange panel or on a plain white square-on-point configuration with the same outside dimensions as a placard. 172.336

Identification numbers must be displayed on each side and each end of a bulk packaging that has a capacity of 3,785 L (1,000 gal.) or more. Bulk packagings with lesser capacities only need the identification numbers displayed on two opposing sides. 172.302

Special provisions. When the identification number is to be displayed on a Combustible placard, the entire background below the white background for the ID number must be white during transportation by rail and may be white during transportation by highway. Thus, mandatory by rail, permissible by highway. 172.332

If hazardous materials having different identification numbers are transported in portable tanks, tank cars, or cargo tanks having more than one compartment, then identification numbers are not required on the ends of the tanks. The identification numbers on the sides of such tanks must be displayed in the same sequence as the compartments containing the materials they identify. 172.336