For anyone that has shipments delayed or rejected because of the border size of their hazmat labels, relief is on the way.
In a Letter of Interpretation issued on May 8th, PHMSA responded to a request for clarification on the 2mm inner border on labels. The final rule issued on January 8, 2015 revised 172.407(c)(1) required:
Each square on point diamond must be at least 100 mm on each side with a solid line inner border 5 mm inside and parallel to the edge;
The 5mm measurement is from the outside edge of the label to the outside of the solid line forming the inner border;
The width of the solid line forming the inner border must be at least 2 mm.
While the amendments were intended to improve consistency, it has had unintended consequences of delays based on different interpretations of the regulation. In July 2017, the United National Sub-Committee of Experts on the Transport of Dangerous Goods determined that specifying a minimum thickness for the line width was not necessary for safety reasons. The International Civil Aviation Organization (ICAO) and the International Maritime Organization (IMO) have rescinded the requirements adopted in 2015 United Nations Model Regulations effective January 1, 2019. PHMSA supports and will most likely align with those amendments in a future rulemaking action.
If you didn’t know these regs, it may be time to update your training. Call me at 1-800-535-5053 for 49 CFR DOT hazmat training, IATA dangerous good training, and/or IMDG training. We have plenty of options to meet you needs!