The UN International Harmonization of the 49 CFR hazardous material and waste shipping regulations are driving me crazy. I am talking about the diamond shaped Department of Transportation, hazard class labels, required on containers of hazardous material and hazardous waste. See last October, I wrote a blog telling everyone, not to throw out the older DOT hazard class labels just yet, if their inner border lines were only 1mm wide, even though the DOT and the UN or United Nations Committee of Dangerous Goods Experts were now requiring the border line be increased to 2mm.
See. I knew about the label’s inner borders, were beefed up to 2 mm wide, as I had mentioned in my October blog “It’s a Thin Line” (Link to blog - https://www.hazmat-tsp.com/robsblog/2018/10/31/it-is-a-thin-line ). But, I should have more, carefully read the label revisions in the Final rule in the November 7, 2018 Federal Register, (Link- to https://www.govinfo.gov/content/pkg/FR-2018-11-07/pdf/2018-23965.pd page 55806).
The November Federal Register stated that the labels with the 1 mm lines were still authorized, but only domestically until the end of their service life, which would authorize both a 1mm or 2mm inner border line, on the label “But only if the packages were labeled before January 1, 2017”. So, If they aren't stuck, your out of luck.
“For domestic transportation, a packaging labeled prior to January 1, 2017, and in conformance with the requirements of this paragraph in effect on December 31, 2014, may continue in service until the end of its useful life.”
Also, be aware, when reducing labels on smaller containers. Instead of having to maintain the 5 mm label edge to inner border, the whole label can be reduced proportionately in size.
“If the size of the package so requires, the dimensions of the label and its features may be reduced proportionally provided the symbol and other elements of the label remain clearly visible”.
I should have known about the label changes and updated you, It is important to frequently and thoroughly read any and all proposed and final rule changes, that affect your company’s compliance , in the current e-regs, (https://gov.ecfr.io/cgi-bin/ECFR ). Or, at the very least, go to our website where Lisa, goes through the Hazardous Material, (DOT), Hazardous Waste, (EPA) and Hazardous Substance and Chemical, (OSHA) regulations every day, then posts all of the proposed and final rules for both you and me, (https://www.hazmat-tsp.com/new-blog). They change all the time.
Thank you for your support and readership
Robert J. Keegan
Publisher and President
Hazardous Materials Publishing Company