Package markings

Scope

The individual who prepares non-bulk packages of hazardous material for transport is responsible for marking the package. In most cases, the responsibility for marking bulk packagings, freight containers, and transport vehicles rests with the individual initiating the shipment.

Regulatory citations

• 49 CFR 172.301 — General marking requirements for non-bulk packagings
• 49 CFR 172.303— Prohibited markings
• 49 CFR 172.304 — Marking requirements
• 49 CFR 172.326 — Portable tanks
• 49 CFR 172.328 — Cargo tanks
• 49 CFR 172.330 — Tank cars and multi-unit tank car tanks
• 49 CFR 172.331 — Bulk packagings other than portable tanks, cargo tanks, tank cars and multi-unit tank car tanks
• 49 CFR 172.514(c)(4) — Bulk packagings
• 49 CFR 172.606 — Carrier information contact
• 49 CFR 173.25 — Authorized packagings and overpacks

Key definitions

• None

Summary of requirements

Marking requirements. The marking must be:

• Durable, in English, and printed on or affixed to the surface of a package or on a label, tag, or sign;
• Displayed on a background of sharply contrasting color;
• Unobscured by labels or attachments; and
• Located away from any other markings, such as advertising, that could substantially reduce its effectiveness.

• Proper shipping name (including technical names, as appropriate).
• Identification number (size requirements mandatory January 2017. See Identification numbers.)
• DOT-SP (followed by the special permit number), if the packaging is authorized under a special permit.
• Consignee’s or consignor’s name and address, except when the packaging is transported:
  1. By highway only and will not be transferred from one motor carrier to another, or
  2. As part of a carload lot, truckload lot or freight container load — and the entire contents of the rail car, truck or freight container are shipped from one consignor to one consignee.

Additional non-bulk markings.

1. Orientation arrows shall be marked on each combination packaging having inner packagings containing liquid hazardous materials, or single packaging fitted with vents, or open cryogenic receptacles intended for the transport of refrigerated liquefied gases. Mark on two opposite sides with arrows pointing in the correct upward direction — except as provided in 172.312(c).
2. “INHALATION HAZARD” shall be marked in association with the required label(s) or shipping name on each packaging containing materials that are poisonous by inhalation. (172.313(a))
3. “POISON” shall be marked by embossing or other durable means on each non-bulk plastic outer packaging used as a single or composite packaging for Division 6.1 materials. (172.313(b))
4. Packaging that contains a Division 6.1, PG III material, may be marked “PG III” adjacent to the POISON label. (172.313(d)) The PG III marking may also be placed on a POISON label. See Labeling for more information on label modifications.
5. The EX-number for each substance, article or device that is a Class 1 explosive must be marked on the package — except as provided in 172.320.
6. Packagings which contain a reportable quantity of a hazardous substance must be marked with the letters “RQ” in association with the proper shipping name. (172.324) SeeHazardous Substances for more information.
7. A package containing a limited quantity of hazardous materials must display the square-on-point limited quantity marking. A package displaying the limited quantity marking is not required to be marked with the proper shipping name or identification number, unless the material is a hazardous substance or hazardous waste.
   1. Packages meeting the requirements for air transport must display the square-on-point “Y” limited quantity marking. A package displaying the “Y” limited quantity marking is required to be marked with the proper shipping name and identification number when transported by air. See limited quantity markings for more information.
   2. Before January 1, 2021, packagings that contain a material classed as “ORM-D” may be marked with the ORM-D marking. Starting on January 1, 2021, only the appropriate square-on-point limited quantity marking may be used. See Consumer Commodity (ORM-D) for more information.
8. Non-bulk packagings which contain marine pollutants and are offered for transportation by vessel must be marked with the marine pollutant marking and the name of the component(s) in parentheses which make the material a marine pollutant, if not identified in the shipping name (172.322). See Marine Pollutant for more information.
   
9. Proper shipping names marked on non-bulk packages of hazardous waste are not required to include the word “waste” if the package bears the EPA marking prescribed by 40 CFR 262.32.

See Identification Numbers for information on displaying identification numbers for large quantities of non-bulk packages.

Marking overpacks. Each overpack must be:

• Marked with the proper shipping names and identification numbers of the materials contained within, unless the markings on the inside packages are visible.
• Marked with the word “OVERPACK” indicating that the inner packages comply with prescribed specifications (when specification packagings are required), unless the specification markings on the inside packages are visible.
• If containing packages subject to the orientation marking requirements, marked with orientation arrows on two opposite vertical sides, with the arrows pointing in the correct upward direction.
• If containing packages of limited quantity materials or ORM-D materials,be marked “OVERPACK,” unless all required markings are visible through the overpack.
• If containing excepted quantities, be marked with the required markings for the inside packages, unless all the required markings are visible through the overpack. Overpacks of excepted quantities are not required to be marked “OVERPACK.”

Bulk marking requirements. Unless specifically excepted, all bulk packagings of hazardous materials must be marked with the identification number(s) of the contents. These numbers, unless otherwise provided, must be marked:

• On each end and each side of a packaging having a capacity of 3,785 L (1,000 gal) or more.
• On two opposite sides of a packaging with a capacity of less than 3,785 L (1,000 gal).
• On each end and each side of a tube-trailer motor vehicle.

If the identification number markings on a portable tank or cargo tank are not visible, the transport vehicle or freight container used to transport the tank must also be marked with the numbers, on each side and each end.

When a tank is permanently installed within an enclosed cargo body of a transport vehicle or freight container, the identification number marking need only be displayed on the sides and ends of the tank that are visible when the enclosed cargo body is opened or entered.

When a bulk packaging is labeled instead of placarded, the identification number markings may be displayed on the bulk packaging in the same manner as would be required for a non-bulk packaging.

Portable tanks. In addition to displaying the applicable identification number (as described above), portable tanks must be marked with:

• Material’s proper shipping name — on two opposite sides, and
• Owner or lessee’s name.

Cargo tanks. In addition to the identification number, cargo tanks — except for certain nurse tanks — which are used to transport gases must be marked on each side and each end with the proper shipping name or appropriate common name of the gas.

• Example: CARBON DIOXIDE, REFRIGERATED LIQUID, OR REFRIGERANT GAS

Tank cars. In addition to the identification number, tank cars — when required by a special provision to the Hazardous Materials Table or by Part 173 — must be marked on each side with the proper shipping name or appropriate common name.

Multi-unit tank car tanks. In addition to the identification number, multi-unit tank cars must be marked on each side with the proper shipping name or appropriate common name.

Additional markings

1. Bulk packagings that contain materials poisonous by inhalation must be marked “INHALATION HAZARD” in association with any required labels or placards, or shipping name. This marking must be on two opposing sides. (172.313) See Poison Inhalation Hazard for more information on this topic.
2. Bulk packagings containing an elevated temperature material must be marked on two opposing sides with the word “HOT.” (172.325) However, bulk packagings that contain molten aluminum or molten sulfur must be marked “MOLTEN ALUMINUM” or “MOLTEN SULFUR” respectively, instead of the word “HOT.” The word “HOT” must be in black or white Gothic lettering on a contrasting background. The marking must be displayed on the packaging itself or in black lettering on a white square-on-point configuration that is the same size as a placard. See Elevated Temperature Materials for more information on this topic.
3. A bulk packaging (3,785 L (1,000 gallons) or more) that contains a marine pollutant must be marked on each side and each end with the marine pollutant marking. A bulk packaging (less than 3,785 L (1,000 gallons) must be marked on two opposing sides with the marine pollutant marking. Except for transportation by vessel, a bulk packaging that bears a label or placard is not required to display the marine pollutant marking. See Marine Pollutant for more information on this topic.
   
4. Each truck body or trailer, rail car, or freight container containing lading that has been fumigated or treated with any material, must have a FUMIGANT marking displayed so that it can be seen by any person attempting to enter the vehicle or container. See Fumigant Marking for more information on this topic.

Carrier information contact. When a trailer transporting hazardous materials (that require shipping papers) is separated from its motive power and parked at certain locations, the carrier has the option of marking its telephone number on the front of the trailer or attaching certain information to the trailer. See Carrier Information Contact for more information on this topic.

Prohibited markings. No packaging may be marked with a proper shipping name or identification number unless the packaging contains the identified material or its residue.