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Placards And Labels On A Storage Container Are Intended To

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Placards And Labels On A Storage Container Are Intended To

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Placards And Labels On A Storage Container Are Intended To

Paragraph (a) of the proposed standard required that markings, placards and labels remain on the package, freight container, etc. of hazardous material until the hazardous materials are removed therefrom so that they no longer pose a health or safety risk. A number of comments (see, e.g. Exs. 5-10, 5-13, 5-17, 5-23, 5-25, 5-27, 5-29, 5-34, 5-36, L5-40, L5-41 and L5-42) suggested that the language in this provision was ambiguous and employers would be uncertain as to when DOT labels, placards and markings could be removed without being in violation of the rule. Various suggestions were offered regarding how to clarify this issue, ranging from deleting paragraph (a) (Exs. 5-25, 5-29, L5-40) to allowing removal of the markings and placards as long as no more than a de minimis amount of the hazardous material remains in a container (Ex 5-10).
placards and labels on a storage container are intended to 1

Placards And Labels On A Storage Container Are Intended To

There was some confusion regarding paragraph (a) of the proposed rule which required that markings, placards and labels be maintained in a manner that ensures the legend is visible. In effect, all that was intended by this provision was to assure that the label, placard, or marking be kept sufficiently clean (unobscured by dust, dirt, mud, etc.) that it would be easily seen in the event of an emergency or as necessary to prevent a hazardous situation. The provision was never intended to place restrictions on how or where DOT-labeled materials should be stored. However, since one commenter (Ex. L5-42) objected to the use of the term “legend,” the provision has been revised as paragraph (c) in the final rule to read: “Such markings, placards and labels shall be maintained in a manner that assures they are readily visible.” This does not mean that non-bulk packages with DOT labels that are stored in a warehouse (e.g. cartons containing 4-gallon cans of a hazardous material) have to be arranged in a manner which allows every label to be in view at all times. Rather it requires that where DOT hazard warnings are required to be retained, that such warnings are maintained in a manner that ensures that the message which the hazard warning is intended to convey is not compromised. In other words, at least some labeling should be visible for each type of hazardous material.
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Placards And Labels On A Storage Container Are Intended To

Hazard markings, labels and placards are a common approach to warning the public of hazards that may be encountered. The DOT uses labels, defined as 4″ x 4″ colored diamond with warning words and graphics, affixed to the outside of the shipping container or box. Labels are required on the outside of the package regardless of the quantity shipped. The DOT requires placards, a much larger version of the labels, to be displayed on tank cars, cargo tanks, portable tanks and bulk packaging. Requirements for placarding are dependent upon the identity and quantity shipped. “Markings” are required to convey specific information about the enclosed hazard and the person responsible.
placards and labels on a storage container are intended to 3

Placards And Labels On A Storage Container Are Intended To

SUMMARY: OSHA is hereby issuing a final rule that requires employers who receive a package, transport vehicle, freight container, motor vehicle or rail freight car which contains a hazardous material and which is required to be marked, placarded, or labeled in accordance with the U.S. Department of Transportation’s (DOT) Hazardous Materials Regulations, to retain the markings, placards, and labels on the package, transport vehicle, freight container, motor vehicle or rail freight car. Such markings, placards and labels generally must be retained on packages until the packaging is sufficiently cleaned of residue and purged of vapors to remove any potential hazards and retained on transport vehicles, freight containers, motor vehicles or rail freight cars until hazardous material which requires the marking or placarding is removed therefrom. This rule is issued pursuant to section 6(b) of the Occupational Safety and Health Act of 1970 (the Act) and in accordance with section 29 of Public Law 101-615, the Hazardous Materials Transportation Uniform Safety Act of 1990 (HMTUSA).
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Placards And Labels On A Storage Container Are Intended To

Finally, Amoco (Ex. 5-21) raised the issue of whether the rule would apply to an employer’s current inventory of DOT-labeled materials and whether changes to the existing markings and labels would be required. In response to this comment, the Agency is allowing 90 days following publication of the final rule in the Federal Register for employers to come into compliance. The rule requires no changes in the content of the label. However, OSHA is providing what it believes is sufficient time for employers to replace labels, markings or placards that may have been removed, or to empty containers of hazardous materials. Once the effective date of the rule has passed, employers will be subject to OSHA citations if packages, transport vehicles, freight containers, etc. of hazardous materials covered by DOT’s HMR are present in the workplace, do not have the appropriate DOT hazard warning and violate the standard. It is not possible for OSHA compliance officers to readily know the date transport vehicles or packages were received and DOT warnings were removed. The 90-day period is a realistic time in which to replace removed placards, markings or labels or to empty containers.
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Placards are used to represent the hazard classes of materials contained within freight containers, motor vehicles or train car. Labels communicate the same hazards for smaller containers and packages offered for transport. Examples of the placards and labels used for the various hazard classes follow. This placard or label is used to designate explosive materials, specifically Class 1.1, 1.2 and 1.3 explosives. Explosives that belong to classes 1.4, 1.5 and 1.6 will have that specified, with the class designation replacing the exploding ball. This placard is required when transporting ANY quantity of a Class 1.1, 1.2 or 1.3 explosive, or over 1001 lbs of a Class 1.4 or 1.5 explosive.
placards and labels on a storage container are intended to 6

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In November 1988, six Kansas City firemen were killed when the arson-caused fire they were fighting caused the violent explosion of an unmarked truck-trailer parked at a highway construction site. Because the trailer’s hazardous materials placards had been removed, the firemen were unaware of the danger it posed. The Secretaries of Labor, Transportation and the Treasury should cooperate in order to ensure that placards and labels required on hazardous materials and explosives, both in transportation and at stationary facilities, be retained until such materials have been removed to the extent that they no longer pose a safety risk.
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In the final standard OSHA has amended the language in paragraphs (a) and (b) so that it is now clear. Employers need only retain the DOT label, marking or placard until such time as the packaging which contained the hazardous material is sufficiently cleaned of residue and purged of vapor to remove any potential hazard. Paragraph (b), which requires the retention of markings and placards on transport vehicles, etc., states that markings and placards may be removed from transport vehicles if the transport vehicle no longer contains hazardous material subject to the marking or placarding requirements of the DOT’s HMR. In the alternative, employers will be in compliance if they choose to retain the appropriate DOT hazard warning on packaging containing only the residue of the hazardous chemical in the same manner as when it contained a greater quantity of the hazardous material.
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Not later than 18 months after the date of enactment of this Act, the Secretary of Labor, in consultation with the Secretary of Transportation and the Secretary of the Treasury, shall issue under section 6(b) of the Occupational Safety and Health Act of 1970 (29 U.S.C. 655(b)) standards requiring any employer who receives a package, container, motor vehicle, rail freight car, aircraft, or vessel which contains a hazardous material and which is required to be marked, placarded, or labeled in accordance with regulations issued under the Hazardous Materials Transportation Act to retain the markings, placards, and labels, and any other information as may be required by such regulations on the package, container, motor vehicle, rail freight car, aircraft, or vessel, until the hazardous materials have been removed therefrom.
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The HM224B/DOT31FP can be used over and over again. It’s designed to be light weight to save on shipping costs. These aluminum cylinder shipping cases have passed the ATA 280 cycle drop test, which closely simulates common material handling abuse. The all-aluminum exterior is reinforced with more than 1,000 industrial-grade rivets. Ball corners, latches, hinges and handles are made of the highest quality material. All container labels, DG labels and Airline Markings are incorporated on each container. The cylinder valve assembly is protected inside the larger of the Super Boxes by a removable cradle that is securely tethered to the container and can only be used in the correct position, allowing unobstructed access to the bottle in the Side-load Design container.
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Amoco supports OSHA’s proposal requiring employers who receive bulk packages of materials defined as hazardous * * * to maintain the markings, labels, or placards in accordance with the requirements set forth in 49 CFR Part 171 to 180. However, we feel that retention and maintenance of the markings and labels for non-bulk packages would be significantly burdensome to both large and small businesses alike.
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OSHA did not modify its previous exemption under the Hazard Communication Standard with regard to labeling of portable containers. Where hazardous substances are transferred from a labeled container into a portable container, used within a work shift, and under the control of the employee who performs the transfer, no labels are required on the portable container. However, if the chemical transferred to a portable container is not used within a work shift and under the control of the employee who performs the transfer, then labeling is required.

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