1. Labeling Instructor Dialogue:
In this module, we will look at the requirements and inspection procedures for labeling.
Labeling

2. Instructional Goal
Upon completion of this module, Inspectors will be able to apply their knowledge of labeling requirements for bulk and non-bulk packaging to determine compliance with the HMR.
Content:
Upon completion of this module, Inspectors will be able to apply their knowledge of labeling requirements for bulk and non-bulk packaging to determine compliance with the HMR.

3. Objectives Determine applicability of labeling
Determine exceptions to labeling
Compare labels on HM packages to column 6 of the HMT
Verify proper placement of labels on HM packages
Verify specification requirements for HM labels
Content:
Determine applicability of labeling
Determine exceptions to labeling
Compare labels on HM packages to column 6 of the HMT
Verify proper placement of labels on HM packages
Verify specification requirements for HM labels

4. Topics In this module, we will learn about the following topics:
Labeling Applicability
Inspection Procedure
Content:
In this module, we will learn about the following topics:
Labeling Applicability
Inspection Procedure

5. Labeling Applicability
Instructor Dialogue:
Let’s start with a quick overview of labeling.
Labeling Applicability

6. HM Labels Applied to outside of the package
Communicate the presence of HM
Based on primary and subsidiary hazard class/division
Content:
Packages containing HM are usually required to have certain labels applied to the outside of the package. Labels on the outside of HM packages communicate the presence of HM inside. Labeling decisions are based on the primary and subsidiary hazard class/division of the HM within the package.
For example:
Acme Carriers is transporting 200 pounds of dry trichloroisocyanuric acid, dry in a non-bulk package. This HM is a Division 5.1 material and the package must be labeled an "Oxidizer" label.
Part 172
Subpart E

7. General Requirements Certain packages require labels
Design and requirements outlined in (b)
Labels must be near the proper shipping name
Multiple labels should be adjacent to each other
Content:
Each person who offers for transportation or transports an HM in certain packages or containment devices, must label the package or containment device with labels specified for the material.
The following require labels:
Non-bulk packages
Bulk packaging, other than a cargo tank, portable tank, or tank car, with a volumetric capacity of less than 640 cubic feet, unless placarded
Portable tank of less than 1000 gallons capacity, unless placarded
DOT Specification 106 or 110 multi-unit tank car tank, unless placarded
Overpack, freight container, or unit load device, of less than 640 cubic feet, which contains a package for which labels are required, unless placarded or marked
Instructor Note:
Instruct the students to access Part (b). Inform them that this table outlines the references for label designs and requirements. Review some of the label designs that are contained within the regulations.
HM labels must be on the same surface and near the proper shipping name.
If multiple labels apply, the labels should be adjacent to each other.
Part

8. Exceptions Part 172.400a Instructor Note:
Flask or container with 2.1, 2.2, 2.3
Military explosives
DOD supervision
Mounted compressed gas cylinder
Certain placarded containers
Overpack or unit load device
Low specific activity
Small and limited quantities
Subsidiary hazard label
Poisonous by inhalation
Instructor Note:
Instruct the students to access Part a and briefly review the exceptions from labeling. Ask the students to provide some of the listings.
Content:
The exceptions from labeling are defined in Part a.
Part a

9. Inspection Procedure Instructor Dialogue:
Let’s take a look at labeling inspection procedures.
Inspection Procedure

10. Inspection of Labels Identify HM Observe Labels
Check for Primary and Subsidiary Labels
Check Requirements and Exceptions
Verify Label Location
Verify Label Specifications
Content:
Inspection of labels consists of the following tasks:
Identify the HM being transported by examining the shipping papers
Observe labels that are present (if any) on the package
Refer to Column 6 HMT for required primary and subsidiary labels
Check HMR for requirements and exceptions that apply
Verity that labels are properly located on the package
Verify that required label specifications are met
Part 172
Subpart E

11. Identify HM Remember to use the shipping paper to discover any HM
Locate in HMT
Content:
The first step is to identify the HM using the shipping paper. Be sure to locate the material in the HMT in preparation for the next steps.
Part 172
Subpart E

12. Observe Labels
Look at the HM package and observe if labels are displayed correctly on the package
Content:
The second step for labeling compliance is to look at the HM package and observe what labels are displayed on the package. There are 25 possible labels that may appear on packages of HM defined in (b). It is usually very easy to locate the label(s) on packages of HM. However, the locations vary from package to package and will be discussed as we continue this module.
Note: The old Division 5.2 label may be used until January 1, 2014 for transportation by highway. (See (f)).
Part 172
Subpart E

13. HMT Labels For each HM, refer to Column 6 in the HMT for:
Primary hazard labels
Subsidiary hazard labels
Content:
The third step in the labeling inspection is to refer to Column 6 in the HMT for the HM discovered in the inspection. Column 6 will outline the primary and subsidiary labels that are required to be displayed for the HM. The first label specified in Column 6 HMT is the primary hazard label for the HM. Any additional entries identify subsidiary hazard labels of the HM.
Instructor Note:
For an example, have the students look up Acetic anhydride and give you the labels specified, which are 8 for the primary and 3 as the subsidiary.
Part 172
Subpart E

14. Requirements and Exceptions
If the HMT requires a label, check to see if there are any exceptions.
Content:
If Column 6 of the HMT indicates that the HM package requires a label, the next task is to check the package against the exceptions outlined in (a). If the package meets an exception, then a label is not required.
Part 172
Subpart E

15. Verify Label Location Printed on or attached to a visible surface
Located on the same surface and near the proper shipping name
Multiple labels must be adjacent
Contrasting background
Clearly visible e
Content:
If labels are required for the material, the next step in the labeling inspection is to verify that the labels are displayed in the correct location.
Labels that appear on packages of HM must conform to the following:
Printed on or attached to a surface (other than the bottom) of the package or containment device containing the HM
Located on the same surface of the package and near the proper shipping name marking, if the package dimensions are adequate.
When primary and subsidiary hazard labels are required, they must be displayed next to each other. Placement conforms to this requirement if labels are within 6 inches of one another
Each label must be printed on or affixed to a background of contrasting color, or must have a dotted or solid line outer border
Labels must be clearly visible and not obscure markings or attachments.
The package on the screen represents a correctly labeled box of Phosphorus pentasulphide.
Part 172
Subpart E

16. Verify Labels (cont) Tags may be used in three specified cases:
No radioactive material and smaller than label
Cylinder
Irregular surface
Content:
A label may be printed on or placed on a securely affixed tag, or may be affixed by other suitable means to:
A package that contains no radioactive material and which has dimensions less than those of the required label
- OR -
A cylinder
A package which has such an irregular surface that a label cannot be satisfactorily attached
For example:
Acme Carriers is transporting a cylinder of compressed Helium. The required label (Non-Flammable Gas) may be printed on a tag and securely attached to the cylinder as shown in the picture on the screen.
HELIUM
COMPRESSED
UN 1046
Part

17. Verify Labels (cont) Sometimes duplicate labeling is required
Must be on at least two visible sides or ends
Content:
Usually, a required label must be displayed only once on a package. There are times, however, that the label must be displayed twice on a package. This is referred to as duplicate labeling. Duplicate labeling indicates that two labels appear on the package and the labels are the same.
Labels must be displayed on at least two sides or two ends (other than the bottom) for the following:
Packages with a volume of 64 cubic feet or more
Non-bulk packages containing a radioactive material
DOT 106 or 110 multi-unit tank car tanks (labels must be displayed on each end)
Portable tanks with less than 1,000 gallon capacity
Freight containers with a volume over 64 cubic feet but less than 640 cubic feet (one label must be displayed near the closure)
An intermediate bulk container having a volume of 1.8 m3 (64 cubic feet) or more
If placarded in accordance with Subpart F, labeling not required.
Part 172
Subpart E

18. Label Specifications Ensure compliance with: Durability Design Size
Color
Instructor Note:
Have the students access Part and review the specifications outlined in the content. When you discuss the design, have the students access Parts to to familiarize themselves with where the specifications are.
Content:
The final task in the inspection for labeling compliance is to verify that the labels meet the required specifications for:
Durability
Design
Size
Color
Certain label modifications are authorized if they meet the requirements of Prohibited Labeling Packages may not display labels unless they properly represent the HM. Packages labeled in accordance with international regulations are exempted.
Part 172
Subpart E

19. Comprehension Check Which of the following require labeling?
Non-bulk package?
Compressed gas cylinder permanently mounted on a transport vehicle?
Portable tank with a 500 gallon capacity with a placard?
DOT Specification 106 multi-unit tank car with no placard?
Content:
Which of the following require labeling?
Non-bulk package?
Compressed gas cylinder permanently mounted on a transport vehicle?
Portable tank with a 500 gallon capacity with a placard?
DOT Specification 106 multi-unit tank car with no placard?
Instructor Note:
Allow the students to find the answers and provide feedback. The answers are:
Non-bulk package? Yes
Compressed gas cylinder permanently mounted on a transport vehicle? No
Portable tank with a 500 gallon capacity with a placard? No
DOT Specification 106 multi-unit tank car with no placard? Yes

20. Comprehension Check
Using Column 6 the HMT and the Label Table in (b), indicate the labels and the label design section(s) required for:
Dimethyl sulfate (UN 1595)
Hexafluoroacetone (UN2420)
Content:
Using Column 6 the HMT and the Label Table in (b), indicate the labels and the label design section(s) required for:
Dimethyl sulfate (UN 1595)
Hexafluoroacetone (UN2420)
Instructor Note:
Allow the students to find the answer and provide feedback.
The answers are:
Dimethyl sulfate (UN 1595): labels; 6.1 and 8, label designs; and
Hexafluoroacetone (UN2420): labels; 2.3 and 8, label designs; and

21. Comprehension Check
Do the following packages of Kerosene (UN 1223) and Selenic acid (UN 1905) have the correct labels? Use the HMT.
Content:
Do the following packages have the correct labels? Use the HMT.
Instructor Note:
Allow the students to find the answer and provide feedback.
The answers are:
Kerosene UN1223; yes the label is correct
Selenic acid UN1905; no, it should be labeled with 8 corrosive

22. Summary Instructor Dialogue:
Let’s review what you have learned in this module.
Summary

23. Summary Students should now be able to:
Determine applicability of labeling
Determine exceptions to labeling
Compare labels on HM packages to column 6 of the HMT
Verify proper placement of labels on HM packages
Verify specification requirements for HM labels
Content:
Students should now be able to:
Determine applicability of labeling
Determine exceptions to labeling
Compare labels on HM packages to column 6 of the HMT
Verify proper placement of labels on HM packages
Verify specification requirements for HM labels
Instructor Note:
Ask the students to recall and or reiterate some key items covered in the module for the different Parts and their applicability. Take a show of hands and insist the students provide some recollections from what they learned. Guide the conversation as it develops to ensure there is general understanding among the class before moving on.