DOT Labeling Requirements: When Does a Hazmat Package Need Labels?

Are you a shipper or driver that needs a quick primer on DOT labeling requirements? In this short guide I give you the basics you need to know.

Hazardous materials labels contain a lot of information for those who have handle and transport hazmat.

Here’s the thing;

Making sure that your packages are properly labeled really isn’t all that hard. Are there exceptions to labeling rules?

Of course!

DOT Labeling Requirements

Requirements for DOT labels on hazmat packages are specified in 49 CFR 172.400 (subpart E). Unless otherwise excepted, labels are required on all hazmat packages as specified on the hazardous materials table.

Here’s some good news;

Dealing with DOT label regulations is a lot easier than dealing with placarding rules.

Labeling for hazmat is pretty straightforward – unless the material is excepted, you must put labels on a packaging for both the primary and subsidiary hazard.

If you deal with hazmat on a regular basis or you’ve read my hazmat placarding guide, you know just what I’m talking about.

What Are DOT Labels?

DOT hazmat labels are the basic identifier for hazardous materials contained in packages, packagings and overpacks that must meet specific design rules.

Labels look like smaller versions of placards; They are diamond shaped and are color matched just like a placard. Think of them as the placards smaller but still as important sibling.

In addition to the colors, they have pictograms (a fancy word for pictures) of the hazard, a border, and most important – the hazard class that the material belongs in on the bottom at the ‘home plate’ position.

All of this is designed to give you an indication of the hazards that are contained inside the package.

Hazmat label design requirements:

Hazmat labels have to look a certain way, be resistant to a variety of weather conditions and must be durable.

Size: Labels are diamond shaped or square on point with each side at least 3.9 inches (100mm in metric). The hazmat label can be larger (for example 5 inches) it just can’t be smaller than the given size.

Inner Border: Labels must have an inner border that is a solid line that is 5mm from the outermost edge of the label to the outside of the solid line that forms the inner border. The border line must be 2mm in width.

Hazard Class/Division: The materials hazard class or division number must appear at the bottom of the DOT label and be at least .25 inches (6.3mm) tall but not more than .5 inches (12.7mm)

Text or wording on the label: When text appear on labels they must be at least .3 inches (7.6mm) in height. Hazmat that is Spontaneously Combustible or Dangerous When Wet, the text must be shown with letters at least .2 inches (5.1mm) in height.

Symbols or Pictograms: There are no exact size requirements for the symbols that appear, they just need to be of proportionate size on the label.

Color on Label: Because coloring is one of the biggest ways to communicate the hazard inside the package the rules start to get a bit picky.

Colors have to be conformance with 49 cfr 172.411 through 172.448 and the color standards in the Pantone formula guide. Your can check out Pantone right here for more info.

For example, the red on a flammable label must use Pantone 186 U coloring.

For more specifics on the use of colors for DOT labels, refer the rules in 172.407.

Why Do hazmat labels matter?

Nobody likes surprises, specially if you’re dealing hazardous materials! Labels are one the several ways to communicate a hazard that USDOT requires.

Here’s just a few ways that labels help out:

They warn first responders – Label help to not only warn emergency responders of hazards but also give them a clue to mitigation and clean up.

Universal Communication – No matter what language you speak, labels can break down the barrier. Everyone speaks ‘skull and crossbones’!

Helps Carriers – Carriers have to sometimes place hazmat in certain locations on a vehicle, building or aircraft. Labels help with separation DOT separation rules.

Help Employers – Labels help employers communicate hazards to employees.

Special Handling – Sometimes hazardous materials packages require special handling for shipping. DOT labels helps to clarify rules and make shipping a much safer process.

Where should DOT hazmat labels be placed?

So where do you put your labels on your hazmat package? It’s easy, here’s a very simple checklist:

1: Be affixed or printed on any side of the package except the bottom of the packaging or containment device.

2: Labels must be placed on the same side of the package as the proper shipping name of the hazardous material or the UN number.

See, super easy!

Exceptions to label placement

We’re dealing with hazmat rules, so we have to deal with exceptions. Don’t worry, these label placement exceptions actually make a little sense.

Labels can be attached to a package With a securely attached tag:

A package that has NO radioactive material and the package is smaller that the label.
Cylinders (if they don’t already have an approved CGA-7 neck label)
Packages that have irregular surfaces and a label can be adequately attached.

More DOT label attachment rules:

Multiple labels

If you have to label for both a primary and a subsidiary hazard class or divisions, these labels must be displayed next to each other within 6 inches (150mm).

If you don’t know where to find the materials primary and subsidiary hazard class, go the the 172.101 hazmat table and look at column 6. You can find the table here.

Duplicate labels

Generally, you’re only supposed to have one set of labels displayed on a package.

That being said, you’ll need to display labels on at least two sides or two ends (and not the bottom) for packages:

A volume of 64 cubic feet or more
Non bulk packages that contain radioactive material. If you can’t remember bulk vs non read my post on hazmat bulk packaging.
DOT 106 or 110 multi-unit tank car tanks. Labels must be on each end.
Portable tanks less than 1000 gallons capacity
Freight containers or unit load devices with a volume of 64 cubic feet or more.
Intermediate Bulk Containers (IBC’s) that have a volume of 64 cubic feet or more.

This drum is a good example of having to label a hazmat package for multiple hazards.

The Label Table For DOT Hazmat Labels

Unless the rules have specifically exempted the particular package, packaging or containment device, labels are required for a hazardous material in accordance with the label table in 172.400.

Labels are required for hazardous materials that meet one or multiple hazard classes or divisions as defined in the rules.

To use this table, find the hazard class or division in the left hand column. You’ll see the name of the label, which does matter in more advanced shipping scenarios.

The third column takes you to the rule that will show you what that label should look like.

Click here to view the label table

What are the exceptions to the labeling rules?

The dreaded ‘E’ word that anyone who deals with hazardous materials rules never wants to hear. For labeling requirements, it’s a good news/bad news the thing.

I’ll give you the bad news first, which you already know: DOT labels have several exceptions that need to be checked when you’re determining what labels need to be placed on a packaging.

Here’s the good news;

They’re actually pretty straightforward and simple to deal with. In fact, the exceptions for labeling rules are some of the more straightforward and common sense that you’ll see in the rules.

Here’s a short list:

Bulk packages that are 640 cubic feet or less when they are placarded
Portable tanks that are less than 1,000 gallons unless they’re placarded
DOT specification 106 or 110 multi unit tank car tank when placarded
Packages of military explosives when shipped by the Department of Defense.
Compressed gas cylinders that are permanently mounted on vehicles
Overpacks, unit load devices where each of the labels are visible.

Note: There are more exceptions than I’ve listed here. You’ll want to take some time and read the full rule in 172.400a

DOT drum labeling requirements

Labeling a barrel or drum of hazardous materials works the same just like any other packaging.

The barrel should be labeled in accordance with all of the appropriate labeling rules discussed here including not only primary hazards, but subsidiary hazards as well.

Shipping a drum or barrel with have marking requirements in additions to the required labeling that shippers will need to pay attention to.

DOT vs GHS Labels

In addition to dealing with DOT labels shippers are going to need to aware of applying the appropriate label for the Globally Harmonized System (or GHS).

So what does this mean?

It means that you’re going to be shipping a package that has two different labels that conform to two different sets of standards.

It sounds like a pain (and it is) but here is a basic way to understand the difference between the two labels.

The DOT label is designed to provide a warning while the material is in transportation.
The GHS label is the more international standard and designed for handlers of the package.

Summing it up…

Although there are several exceptions to deal with when dealing with DOT labeling requirements, labeling hazmat packages is really pretty straightforward.

Ensuring that you’re in full compliance with the hazardous materials regulations (or HMR’s) means that you need make sure that the package that your shipping or transporting has the right label on it every time.