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Which regime

In transit

Updated

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A third set of rules, and the standard tells you not to conflict with it.

The non-conflict requirement

Each container of hazardous chemicals leaving the workplace must be labeled in a manner which does not conflict with the requirements of the Hazardous Materials Transportation Act and the regulations issued under it by the Department of Transportation.

Which is a coexistence instruction

Not a hierarchy. Both sets of marks go on the container and neither may contradict the other, which in practice means knowing which mark belongs to which regime and not substituting one for the other.

And the transport side has its own reliefs

For a Class 3 flammable liquid the limited quantity provisions except a package from labeling unless it goes by aircraft, and from specification packaging in combination packagings, with inner limits of 0.5, 1.0 and 5.0 liters by packing group.

With a 30 kg cap on the package

Which for the larger containers on this shelf is a real constraint. A case of 4,731 mL jugs approaches it quickly, and the gross weight includes the outer packaging.

Specification packaging is where our shelf stops

Nothing in this catalog carries a UN specification marking, so for a quantity of a DOT hazardous material requiring specification packaging this is not the shelf. The same finding excluded the hazmat group entirely.

Section 14 of the sheet is the bridge

Transport information inside the safety data sheet is where the transport description for the material lives. It is the document a shipper will ask for first.

So three regimes meet on one container

The workplace label, or the consumer label, plus the transport marking, plus the sheet that describes both. Keeping them consistent is most of the administrative work in this category.

Three regimes, one container, and consistency is the work

The administrative burden in this category is not any single rule, it is keeping the workplace label, the transport marking and the sheet saying the same thing after every change.

References

29 CFR 1910.1200(f), Labels and other forms of warning. Paragraph (f)(1) lists the six required elements on a shipped container: product identifier, signal word, hazard statements, pictograms, precautionary statements, and the name, address and telephone number of the responsible party. (f)(2) requires them to accord with Appendix C for each hazard class and category, prominently displayed and in English; (f)(3) requires the signal word, hazard statements and pictograms to be located together; (f)(5) requires the label not to conflict with the DOT transport rules. law.cornell.edu
49 CFR 173.150, Exceptions for Class 3 (flammable and combustible liquids), the limited quantity provisions with inner packaging limits of 0.5 L, 1.0 L and 5.0 L by packing group and a 30 kg gross cap per package. law.cornell.edu
29 CFR 1910.1200(g), Safety data sheets, which requires a sheet for each hazardous chemical produced or imported, in English, with sixteen numbered sections in the order listed and the content of each set out in Appendix D, including section 14 Transport information and section 15 Regulatory information. law.cornell.edu
Written from federal regulation and from measured catalog data, not from a plant floor. Hazard classification is a technical exercise with appendices behind it, and nothing here classifies a chemical or writes a label. The point of these pages is to show which regime applies and what it asks for.