Frequently Asked Questions on Hazardous Waste Labels and Hazardous Materials DOT Labels

Hazardous Waste Labels

• Should I use a paper or a plastic hazardous waste label?

• Do your vinyl [Hazardous Waste labels] labels have a writable surface? Can we use a pencil? Or, do we need to use a pen or marker?

• Some of the labels do not seem to stick well on our older drums, when they are wet or dirty. Do you have any suggestions?

Hazardous Materials DOT Labels

• What are the DOT Hazard Classes?

• What are the Federal Regulations for Hazardous Materials Labeling?

• In determining when and how to label a package of hazardous materials who has responsibility?

• When did 215A do into effect?

• Our drums seem to have more than one hazard. In this case, which label should takes preference?

• What is the history behind the DOT labels?

• What are the rules HM-181, HM-215 and why are these rules important for us? What are the size specifications for these hazardous materials labels?

• When should ORM labels be used?

Should I use a paper or a plastic hazardous waste label?

In most cases, we recommend that you use a plastic or vinyl hazardous waste label material.

We have heard about an event that occurred with a paper hazardous waste label (not one of ours). The paper label failed and, allegedly, the 55 gallon drum (which used to contain hazardous materials) became a convenient pit for a barbecue grill. Similarly, we have heard about a case wherein a hazardous waste drum became a trash can for the neighborhood.

Given risk, we encourage you to order the most durable label possible. Plastic labels are far more resistant to water, sun and chemicals than paper labels. Labels are a first line defense against these dangers.

In all cases, though, test the label, the label adhesive and your marker.

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Do your vinyl [Hazardous Waste labels] labels have a writable surface? Can we use a pencil? Or, do we need to use a pen or marker?

You must use a pen or permanent marker. They are not pencil writable.

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Some of the labels do not seem to stick well on our older drums, when they are wet or dirty. Do you have any suggestions?

Preparation is critical. Sticking a hazardous waste label onto a poorly prepared surface is like trying to paint a dirty gutter — the label is just not going to stay stuck for very long. Remember how important all the scrapping was when you repainted your house! For the best results, we recommend using a cleaning solution and a Scotchbrite pad. Remove oils. Rough up the surface slightly. You will be amazed at how much difference a simple cleaning will make.

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In determining when and how to label a package of hazardous materials who has responsibility?

The shipper, typically has this responsibility. The shipper needs to:

• Check that the material can be shipped (and is not forbidden)

• Determine the material's Hazard Class.

• For materials with more than one hazard, select the primary and subsidiary hazards.

• Choose the NOS ["Not Otherwise Specified"] shipping name which best characterizes the material.

Examples of N.O.S. names are the generic chemical name (for example, "Alcohols, toxic"), the generic use of the chemical (for example, "Refrigerant Gas") or the a description of the generic hazards of the material (for example, "Flammable Liquid").

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When did 215A do into effect?

The UN and DOT rules changed as of October 1, 1996. An important excerpt from rules regarding this type of labeling is shown as follows:

OSHA is hereby issuing a final rule that requires employers who receive a package, transport vehicle, freight container, motor vehicle or rail freight car which contains a hazardous material and which is required to be marked, placarded, or labeled in accordance with the U.S. Department of Transportation's (DOT) Hazardous Materials Regulations, to retain the markings, placards, and labels on the package, transport vehicle, freight container, motor vehicle or rail freight car. Such markings, placards and labels generally must be retained on packages until the packaging is sufficiently cleaned of residue and purged of vapors to remove any potential hazards and retained on transport vehicles, freight containers, motor vehicles or rail freight cars until hazardous material which requires the marking or placarding is removed therefrom. This rule is issued pursuant to section 6(b) of the Occupational Safety and Health Act of 1970 (the Act) and in accordance with section 29 of Public Law 101-615, the Hazardous Materials Transportation Uniform Safety Act of 1990 (HMTUSA).

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Our drums seem to have more than one hazard. In this case, which label should takes preference?

In most cases, the rules of "Hazard Precedence" outline which hazard must take the lead. For example, poisonous gas hazards (Division 2.3) takes precedence over the corrosive hazard described in Class 8. See the question below. Please consult with your legal and hazmat expert, of course.

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What is the history and background behind our need to be so careful with DOT labels?

The first law requiring labeling of hazardous materials on railroads was passed in 1910 based on the continual transportation of explosives. The labeling changed very little over the next 60 years, until, after a number of highly publicized accidents during transport, Congress finally passed the Hazardous Materials Transportation Act in 1975. This soon led to the brief consolidation of regulations under the Hazardous Materials Regulations Board. However, during the remainder of the 70s and 80s, numerous regulatory changes have been taking place over the years and it has been an ongoing challenge to simplify and consolidate them.

Recently, the DOT and UN have both made standard that seems to be successful and the consistency has certainly risen. The two sides began to cooperate together when the DOT accepted the recommendation by the UN that labeling standards and "performance packaging" with HM-181 is now reaching a conclusion with HM-215A. The UN distributes their recommendations worldwide, and though they do not have the power of regulations, they have a great influence in it because of their worldwide distributions. They are adopted by various countries, such as the acceptance of HM-215A in the U.S. Their recommendations have now spread so that they cover virtually all international modal regulations, including the International Maritime Dangerous Goods Code (IMDG Code) for international sea transport and the ICAO instructions for international air transport.

The U.S. DOT's HM-215A was issued on December 29, 1994 and it brought the US regulations in line with the UN recommendations. By October 1, 1996 all DOT specification packaging may no longer be used. By October 1, 2001 all HM-181 placards specified in the December 1990 rule will need to be replaced by those meeting the HM-215A rules.

In studying the changes made over the last 20 years, important trends for labels have arisen from them:

• Regulations have been consolidated. Consistency has been the goal of every regulatory change, and finally, it seems that has come to fruition. This consistency has been accomplished by acquiring different local and sate regulations that work together, by aligning our standards with those of other countries, and by attempting to simplify the different labeling requirements for each mode of transportation. At one point the Coast Guard, the FAA, the Federal Highway Administration and the Federal Railway Administration each had their own marking requirements.

• U.S. DOT label designs are now also international labels. As the acceptance of the eighth edition of the UN Recommendations passes, these labels can be used for international shipments.

• DOT labels now show much more information as well. It has added the ID number, the N.O.S. shipping name and the constituent names.

Thanks to electronic data files, the DOT symbols can now be found integrating with MSDSs as well as many shipping papers.

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What are the rules HM-181, HM-215 and why are these rules important for us? What are the size specifications for these hazardous materials labels?

These labels should be at least 3.9" (100mm) long. Plus they need to have a solid inner border line that is 0.2" to 0.25" (5-6.3mm) from the outer edge of the label. Many labels now show the UN/NA ID number, the generic description of the material and the technical name of the chemical.

Here is some background on these two citations. First, let's start with some history. Hazardous materials regulations have grown considerably over the last thirty years. In the first iterations, many believed that these regulations were far too complex and inflexible. To some, these standards did not easily incorporate the new non-bulk packaging methods. And they did not always agree with the international U.N. recommendations. As a result, the DOT's RSPCA group proposed a sweeping array of sweeping changes, as can be seen in docket HM-181.

Understand, though, that not all recent changes are"HM-181 regulations" There are many, other, related dockets. These regulations were eventually passed and can be found in the Hazardous Materials Regulations, 49 CFR parts 172 to 180. These are the important source documents for DOT shipping labels. HM-215AS is the final rule and aligns U.S. regulations with the UN Recommendations.

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When should ORM labels be used?

ORM (Other Regulated Materials) labels are used under very specific circumstances. There are generally very precise regulations on how to package and ship certain hazardous materials so that the danger of the material is as small as possible. However, when looking at the US Department of Transportation's (DOT) hazardous materials table, there is a column (column 8A) that specifies whether or not materials have exceptions to those rules, and whether or not they do not have to follow every regulation that the DOT sets. When looking in column 8A, you will see numbers for many of the materials on the table. Those numbers stand for the section that you must go to in order to view what requirements are asked for to transport that material using ORM labels. The section that you find the requirements will look like: 173.(the number in the column). An example of this is Acetaldehyde ammonia. In column 8A, the number is 155, that means that the requirements set in section 173.155 Class 9 (miscellaneous hazardous materials) are what need to be followed in order for Acetaldehyde ammonia to be transported with an ORM label. In this case, the requirements are as follows:

Unless offered or intended for transportation by aircraft, Acetaldehyde ammonia is excepted from labeling when transported in a limited quantity. As a solid, the net capacity of the inner packaging should not be over 5.0 kg (11 pounds) each, and should then be packed strong on the outer packaging.

Once these requirements are met, the packages must meet another requirement so that it is considered a "consumer commodity." A consumer commodity is simply a material that is packaged and distributed with the intent to sell through retail services, or to be consumed by an individual for personal care or for household use, for example, drugs and medicines. If this is true of your package, then you may use an ORM label in order to ship your materials.

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