What are labels?

We've all seen them - The diamond shaped stickers or printing on boxes that look like mini placards. Labels are simply a communication tool designed to help communicate the hazard that's inside a package.  For the most part, labels for primary hazards as well as subsidiary hazards (or secondary) must appear on packages.

When to Label

Unlike most hazmat regulations, labeling is fairly straight forward and is one of the shorter sections in the hazardous material regulations. According to the regulations, each person who offers or transports hazmat shall label the package as required. Here are the general labeling requirements found in 172.400:

1. Non-bulk packages. (read the difference between Bulk and Non-bulk)
2. Bulk packages other than a cargo tank, portable tank, or tank car with a volumetric capacity of less than 640 cubic feet, unless placarded. An example would be an intermediate bulk container, or IBC.
3. Portable tank of less than 1000 gallons capacity, unless its placarded.
4. DOT specification 106 or 110 multi-unit tank car tank. These tanks are to haul gases, and are referred to in the industry as 'tonners' or one ton cylinders.
5. An overpack, freight container or unit load device, of less than 640 cubic feet, which contains a package for which labels are required, unless placarded or marked. A common example would be a pallet containing small packages of hazmat shrink wrapped.

If a package containing hazmat falls within any of those (and there are no exceptions!) and it meets one or more hazard class definitions it must have a label. How would you know what label? This is where being familiar with the 172.101 table comes in. A package must be labeled in accordance with column 6 of the hazmat table (172.101).

Labeling exceptions

Labeling exceptions are pretty straight forward (thankfully!) and are found in 172.400a of the regs.

Dewar Flask that meet the requirements of 173.320. What is a dewar flask? Dewar flasks are essentially thermos bottles that are using primarily for transporting cryogenic liquids.

Cylinders that are not overpacked or are marked with CGA-7 labels (Compressed Gas Association).

The common shoulder label on cylinders that you see.

Department of Defense materials such as ammunition and other hazardous material that is loaded and unloaded by the direct supervision of DOD.

Compressed Gas Cylinders that are permanently mounted on a transport vehicle.

Freight container, aircraft unit load device or portable tank which is placarded or conforms to 172.512 (placarding). Just like we mentioned above.

Overpack or unit load device in or on which the labels from each hazmat in the overpack/load device are visible.

Low specific activity and surface contaminated objects of radiological material.

Limited quantities and small quantities as applicable in section 173.

Material poisonous by inhalation may be excepted if the package  is in a closed transport vehicle and meets the conditions set in 171.23(b)(11) which are international requirements.

Subsidiary label for a corrosive material (class 8) that has a secondary (subsidiary) hazard of division 6.1 (poison) if the toxicity of the material is based solely on corrosion of tissue rather than systemic poisoning. Is that confusing or what!

Here is my opinion as the editor of the site: This is for materials that are highly corrosive. If the material will burn you by corrosion, they're not worried about you poisoning yourself by ingestion or skin contact. Therefore, the class 8 label is enough to warn you and the subsidiary 6.1 label is not required.

These are just the basics of labeling. Keep in mind that labels have other display and size requirements that make them 'official' labels. Again, labels look like small placards, but are not broken down into two tables like placards. Check out the label table to see what labels go with each hazard class/division.