Placement of Hazardous Waste Labels
The proper placement of labels is important. Labels must be printed on or affixed to a surface (other than the bottom) of the package and located on the same surface of the package and near the markings, if the package dimensions are adequate.
Multiple Hazardous Waste Labels
When primary and subsidiary hazard labels are required, they must be displayed next to each other. The DOT recommends a six-inch space (150mm) between labels.
Hazardous Waste Labels and Overpacking
Whenever hazardous material packages are overpacked, the inner containers must be properly labeled in accordance with DOT shipping requirements for the hazardous material. The same applies to the overpack container.
Hazardous Waste Markings
Marking is a critical process in preparing hazardous materials for transportation. A marking on a hazardous materials package contains important information about the identification and dangers posed by the hazardous material. While there is no standardized hazardous waste marking format, both the DOT and EPA have specific requirements.
According to 49 CFR 172.304 markings must:
- Be durable
- Be in English
- Be printed on or affixed on the package surface or on a label, tag or sign
- Be displayed on a contrasting color background
- Not be obscured or covered up by other labels or attachments
- Not be located next to any other markings (such as advertisement) that would limit
Hazardous Waste Markings and Overpacking
Whenever hazardous material packages are overpacked, the inner containers and the overpack container must be properly marked in accordance with DOT shipping requirements for the hazardous material.
DOT Hazardous Waste Marking Requirements
49 CFR 172.301 identifies the general DOT marking requirements for a non-bulk package:
- Proper shipping name and identification number
- Technical names (if required)
- Special permit number
- Consignor’s or consignee’s name and address
- NON-ODORIZED marking on cylinders containing liquefied
petroleum gas (LPG) (if required)
Other DOT Non-Bulk Package Markings
Along with the hazardous waste marking requirements, there may be additional markings that are required. For example:
This End Up Marking
This marking is the package-orientation marking. It is applied to any package that holds inner containers of liquid hazardous materials. Inner packaging may be non-specification containers made of glass or earthenware, plastic or metal.
All packages having inner packages containing liquid hazardous materials must be packed with their closures upward and legibly marked with package-orientation arrows on two opposite vertical sides and with the arrows pointing in the correct upright direction. Arrows for purposes other than indicating proper package orientation may not be displayed on a package containing a liquid hazardous material.