Inmark Packaging | Dangerous Goods
  • Home
  • Inmark U
  • News
  • Dangerous Goods Regulations Change Marking Requirements for 2014

News

Dangerous Goods Regulations Change Marking Requirements for 2014

Aug 1, 2014

Effective January 1, 2014, the International Civil Aviation Organization (ICAO) now requires that the marking of UN numbers on packaging be of a minimum height.

Per the International Air Transport Association (IATA) Dangerous Goods Regulations (DGR) 55th edition, the following changes have been implemented:

The marking of the UN/ID number and the letters “UN” or “ID” as specified in 7.1.4.1(a) must be at least 12 mm high, except for packagings of 30 L or 30 kg capacity or less, when they must be at least 6 mm in height and for packagings of 5 L or 5 kg or less when they must be of an appropriate size.

This enforceable requirement is in addition to IATA’s longstanding preferred requirement for marking height:

Package and overpack use markings should be at least 12 mm high, except for packages of 30 L or 30 kg capacity or less when they should have a minimum height of 6 mm.

In an effort to harmonize with the new international regulations, the Department of Transportation (DOT) has also implemented new UN/ID label height restrictions with a lengthy transition period, which will go into effect on January 1, 2017. According to the Code of Federal Regulations (CFR), these changes include:

49 CFR

§172.301 General marking requirements for non-bulk packagings.

(a) Proper shipping name and identification number. (1) Except as otherwise provided by this subchapter, each person who offers a hazardous material for transportation in a non-bulk packaging must mark the package with the proper shipping name and identification number (preceded by “UN”, “NA” or “ID,” as appropriate) for the material as shown in the §172.101 Hazardous Materials Table. The identification number marking preceded by “UN”, “NA”, or “ID” as appropriate must be marked in characters at least 12 mm (0.47 inches) high. Packages with a maximum capacity of 30 liters (8 gallons) or less, 30 kg (66 pounds) maximum net mass, or cylinders with a water capacity of 60 liters (16 gallons) or less must be marked with characters at least 6 mm (0.24 inches) high. Packages with a maximum capacity of 5 liters (1.32 gallons) or 5 kg (11 pounds) or less must be marked in a size appropriate for the size of the package.

(i) Transitional exception. For domestic transportation, until January 1, 2017, the identification number markings are not subject to the minimum size requirements specified in this paragraph (a)(1).

(ii) Exception for permanently marked packagings. For domestic transportation, a packaging manufactured prior to January 1, 2017 and permanently marked (e.g., by embossing or through a heat stamp process) with the appropriate identification number marking may continue in service until the end of its useful life regardless of whether the identification number markings meet the minimum size requirements specified in this paragraph (a)(1).

It is important to note that these new label requirements are based on the CAPACITY of the package, not on the weight of the dangerous goods being transported. This has created a problem with large packages containing dry ice since the “UN1845” on the standard dry Ice label might not be 12 mm, while the capacity might be over 30 kg and require the larger marking.

If you have any questions, or need further clarification on these new regulations, please contact your Inmark Packaging Consultant today, or e-mail us at Inmark@InmarkPackaging.com.