PHMSA/DOT Update: Label Border Line Thickness

By May 16, 2018 September 12th, 2019 49 CFR, PHMSA, UN Recommendations

HM-215N Update: Clarification on 2mm label border line thickness

2mm Label Border Requirement Changed

As most hazardous goods professionals know, HM-215N was intended to harmonize the 49 CFR regulations with the United Nations Recommendations on the Transport of Dangerous Goods—Model Regulations (UN Model Regulations), International Maritime Dangerous Goods Code (IMDG Code), and the International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions).

Among many other mandates, the final ruling ultimately revised §172.407 (c)(1)(iii), which changed the required width of the solid line forming the inner border of hazard class labels to a minimum of 2mm thick allowing for a transition period for domestic transportation to be in effect until December 31, 2018 in a final rule published in March of 2017.

“Approximately” vs “At Least”

Although this ruling intended to improve consistency in labeling specifications worldwide, the language has caused confusion at the international level, and The United Nations Subcommittee of Experts recently adopted new language to clarify the width of the line may be “approximately” 2 mm instead of “at least” 2mm.

As a result, earlier this year in response to the industry’s request for clarification, the International Civil Aviation Organization (ICAO) and the International Maritime Organization (IMO) rescinded the requirement for label borders to be at least 2mm in thickness.

This action will officially take effect on January 1, 2019. However, US enforcement inspectors currently still have been referring to the requirement set forth by the HM-215N final ruling. As a result, COSTHA asked the PHMSA to clarify to clear up any potential confusion moving forward.

PHMSA’s Response

Recently, COSTHA received a response letter from PHMSA. Specifically, COSTHA addressed concerns about recent amendments that mandated the specific inner border line width of at least 2mm as adopted in the HM-215M Final Rule on January 8, 2015.

PHMSA’s response acknowledged that the implementation of the amendment that specifying a minimum width inadvertently posed unintended consequences” as COSTHA pointed out.

In the letter, PHMSA noted that the issue was discussed at the United Nations Sub-Committee of Experts on the Transport of Dangerous Goods meeting in July 2017, where it was agreed that “specifying a minimum thickness for line width was not necessary for safety reasons”. PHMSA supported this action at the UN that eventually led to the current actions by ICAO and IMO.

The interpretation letter issued indicates that revisions to 49 CFR will be included in the next international harmonization rule (HM-215) to be issued later this year.

COSTHA’s Original Letter to PHMSA

PHMSA’s Response letter to COSTHA

Michael Zendano

Michael Zendano

Michael Zendano started with ICC Compliance Center back in 2016 with several years in the packaging field as a Quality Control Manager. In addition, he has 8 years experience in teaching. Michael works at the Niagara Falls Office as the Packaging/Regulatory specialist where he manages packaging projects and procedures and is a member of the Institute of Packaging Professionals (IOPP) and The Chemical Packaging Committee (CPC) . Degrees: M.S. Science of Education.

One Comment


    Are you serious , after I threw all those labels out and purchased hundreds of dollars in new labels , now this ruling has rescinded the rule ? So am I correct by saying , we can use the old labels?