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36 Spray May 2017 Steven CharleS hunt President, ShipMate, Inc. From here to there: Topics in Transportation Sticking to the Rules The purpose of marking and labeling on packages of hazardous materials is to communicate the contents and risks associated with the dangerous goods within the package. Consequentially, the labels and marks must be durable and capable of withstanding the types of forces and conditions that are reasonably expected to be encountered in transportation. 49 CFR subchapter C The requirements outlined in Title 49, Code of Federal Regulations, subchapter C, Part 172, section 172.407(a) mandate that: Each label, whether printed or affixed to a package, must be durable and weather resistant. A label on a package must be able to withstand, without deterioration or a substantial change in color, a 30-day exposure to conditions incident to transportation that reasonably could be expected to be encountered by the labeled package. International Regulations Similar provisions are found in the International Civil Aviation Organization (ICAO) Technical Instructions and the International Maritime Dangerous Goods (IMDG) Code. The International Air Transport Association (IATA) Dangerous Goods Regulations specify in Section 7.1.3.2(c) that all marks (e.g., proper shipping name, identification number) must be “…able to withstand open weather exposure without a substantial reduction in effectiveness….” and, in Section 7.2.2.1 that “…the material of every label, the printing and any adhesive thereon, must be sufficiently durable to withstand normal transport conditions including open weather exposure without a substantial reduction in effectiveness.” The International IMDG Code requires, in Section 5.2.1.2 of Amendment 38-16, that “…all package marks required…shall be such that this information will still be identifiable on packages surviving at least three months immersion in the sea….” Further, IMDG Code, Amdt. 38-16, Section 5.3.1.1.1.2 states that “…the methods of placarding and marking… on cargo transport units shall be such that this information will still be identifiable on cargo transport units surviving at least three months’ immersion in the sea.” British Standard BS 5609:1986 The obscure, 24-page British Standard, BS 5609:1986, on which the IMDG Code vessel transport requirement is based, is a specification for printed, pressure-sensitive, adhesive-coated International Air Transport Association (IATA) Dangerous Goods Regulations - labels on containers that may be transported all, or in part, by vessel or stored, handled or


Spray May 2017
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