What if My Hazard Class Labels Won’t Fit on My Box?
Choosing the correct UN packaging can be complicated enough. When you keep in mind that not only does your packaging have to be compliant per the various dangerous goods regulations, but it must also be large enough to accommodate all your hazard class labels, it can be overwhelming at times. In addition to the UN specification marking, orientation arrows (when shipping liquids), the appropriate addresses, and the UN number/proper shipping name of your dangerous goods, hazard class labels also must fit on your UN packaging. Generally speaking, hazard class labels must be a minimum of 100MM (3.9 inches) per side and placed square on point (diamond shaped) on your packaging near the proper shipping name and UN number. However, if your packaging isn’t large enough to accommodate a hazard class label with those specifications, there are some exceptions per the regulations below that may help.
If you are shipping domestically within the U.S., hazard class label specifications are located at 172.407(c), where it says that each diamond (square-on-point) label must be at least 100 mm (3.9 inches) on each side with each side having a solid line inner border approximately 5 mm (.2 inches) inside and parallel to the edge. However, it also says that 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. This means if your packaging is too small for the required hazard class labels, you are allowed to shrink the labels if they are visible and in proportion to the specifications. In addition, I also found a PHMSA interpretation which says that The Hazardous Materials Regulations allow the label to be placed square-on-side when square-on-point (diamond shape) is not practicable, meaning if there isn’t enough space on your packaging.
If you are shipping domestically within Canada, similarly to the 49CFR, the label specifications are located at 4.7 where it states that labels and placards must be displayed on a means of containment as they are illustrated in the appendix to this Part, that is, a square on a point and that each side of a label must be at least 100 mm in length with a line running 5 mm inside the edge.
However, unless you are shipping a Class 7, Radioactive Material, if the hazard class label together with the shipping name, technical name, and UN number, cannot be displayed because of the irregular shape or size of the small means of containment, each side of the label may be reduced in length by the same amount to the point where the label, together with the shipping name, technical name, and UN number, will fit that small means of containment. But in this case, TDG sets a limit and says it must not be reduced to less than 30 mm.
If you are shipping by air internationally, in section 188.8.131.52.2 of IATA, it states that hazard class labels must be in the form of a square set at an angle of 45° (diamond shaped) and the minimum dimensions must be 100 × 100 mm. There are some exceptions if you are shipping infectious substances with some hazard labels, but otherwise, you cannot reduce the size of the labels. However, per 184.108.40.206.5 it says unless the package dimensions are inadequate, the label(s) must be affixed at an angle of 45° (diamond shaped), meaning if your package is too small to place your hazard labels square on point you technically can place them on the packaging square on side. Keep in mind different carriers may possibly not allow this, but from a regulatory standpoint it is compliant.
If you are shipping by sea internationally, the IMDG Code does give you the option of reducing the hazard class label size at 220.127.116.11.1.1.3, where it says If the size of the package so requires the dimensions may be reduced proportionally, provided the symbols and other elements of the label remain clearly visible. However, labels must always be placed on the packaging square on point (diamond shaped).
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