The basics of bulk package marking requirements, part 1

Like everything else that's done with hazardous materials transportation, start with your shipping papers. Determine the hazardous materials that are being transported and how much you're hauling. It can't be emphasized enough (you'll see shipping papers as a common theme throughout this website), that shipping papers are the backbone of hazmat transportation. With your shipping papers in hand, you can proceed to walk around your transport vehicle, portable tank or IBC double check compliance.

Basic UN identification number Display

Taking  a look at 172.302 you'll find the general marking requirements for a bulk package. If the package is 1,000 gallons or more, the package must be marked on all 4 sides with the UN number. If the package is less than 1,000gallons, the package must be marked on two opposing sides. Keep in mind that if the package is less than a 1,000 gallons, and that package is placed inside a transport vehicle (box trailer for example) and the UN numbers are no longer visible, the transport vehicle must be marked on all 4 sides. Depending on what the package is, you can find those rules in 172.326 and 172.331.

UN Number Display Requirments

There are 3 ways that UN numbers can be displayed. The most common way we see most UN number displayed are on placards. The identification number displayed on the placard must correspond to the primary hazard class of the hazardous material.

Keep in mind that the ID number is not technically part of the placard, so the size requirments on how ID numbers are to be displayed are found in the marking section of the regulations and not the placarding section. ID numbers on placards have size requirments for display, and you can read all about them in 172.322. The background of the ID number has to white. Below is an example of how NOT to put ID numbers on a placard

The UN number pictured on the above placard are simply stickers on a regular corrosive placard and do not meet the size or background requirements for UN numbers. You will very quickly gain the attention of an inspector or officer for this kind of UN number display! Would this be an out of service violation? No as long as the ID number did not misrepresent the hazard. However, it is still a violation that would be noted on the inspection report (at the very least).

UN numbers can also be displayed on an orange panel. Keep in mind that there are requirements for how big the orange panel has to be, the size and text of the numerals, and even what kind of material it should be made of.

The third and way to display a UN number marking, is the white sqare on point. It has the same outside dimensions as a placard, but is not considered to be a placard. So placarding rules (and hazmat endorsement requirements) do not apply to this marking. The white square on point display is commonly used with the word "HOT" above the UN number for elevated temperature materials.

We've talked about the basic display of UN numbers, but depending on what you're hauling, there may be some addional requirments. Here are a couple that apply to Cargo Tanks.

Cargo Tank markings

What a cargo tank is hauling will dictate many of the marking requirments that are applied to it. For example, if it's hauling diesel, you will only need the UN number. If the material is a gas (such as Refrigerant Gases, n.o.s.), it must be marked with the proper shipping name also. If the material is 'Poisonous by Inhalation', that must also appear on two opposing sides of the cargo tank.

If the cargo tank in question is an MC330 or MC331 (like the cargo tanks used for transporting propane for example) the markings "QT" or "NQT" must be near the specification plate of the cargo tank. QT stands for "Quenched and Tempered", which is a process used in the fabrication of the steel to make the tank. This process makes the steel more brittle. NQT of course, stands for "Non Quenched and Tempered" steel.