A label that travels once
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For certain solid materials the label does not have to travel with the goods
Solid metal such as a steel beam or a metal casting, solid wood, or plastic items not exempted as articles due to their downstream use, or shipments of whole grain.
The required label may be transmitted at the time of the initial shipment
And need not be included with subsequent shipments to the same employer unless the information on the label changes.
Which attaches the obligation to a relationship rather than to a package
One manufacturer, one employer, one transmission. The second and hundredth shipments carry nothing new, and the trigger for a fresh label is a change in the information rather than a new consignment.
This library has now cataloged four persistence horizons and this is the shortest
Most container rules need a label to last until the package is empty. This one needs it to exist once.
The wool products rule sits at the other practical end of distribution
A label of such durability as to remain attached to the product and its package throughout any distribution, sale, resale and until sold and delivered to the ultimate consumer. Resale named explicitly.
And the care labeling rule runs longest of all
A permanent label that will not become separated from the product and will remain legible during the useful life of the product. Measured against the garment rather than against a span of time.
Four rules, four answers, and the difference is who needs to read it when
A professional buyer receiving repeat shipments needs the information once. A consumer washing a shirt in five years needs it then. The drafting follows the reader.
The transmission route is flexible and the rule says so
The label may be transmitted with the initial shipment itself, or with the safety data sheet that is to be provided prior to or at the time of the first shipment.
And the exception is fenced tightly in the next paragraph
It is only for the solid material itself, and does not apply to hazardous chemicals used in conjunction with, or known to be present with, the material and to which employees handling the items in transit may be exposed. The examples given are cutting fluids and pesticides in grains.
Cutting fluids, named in the rule
Which is a reminder that the thing on the pallet and the thing on the thing on the pallet are two separate questions, and only one of them gets the relaxed treatment.
One more paragraph stands the rule down for another agency
Where a pictogram required by the Department of Transportation appears on a shipped container, the pictogram specified in this standard’s appendix for the same hazard is not required. Two agencies, one symbol, no duplication.