During transportation, the HMR governs hazcom labeling requirements, and OSHA

Joint Memo Clarifies Hazmat Labeling Requirements

PHMSA and OSHA issued it Sept. 19, it explains that an HSC 2012-compliant OSHA label and a DOT HMR label or marking may both be the same package.

A new memorandum from OSHA and DOT's Pipeline and Hazardous Materials Safety Administration (PHMSA) explains what the two agencies require for labeling hazardous chemicals for bulk shipments. Issued Sept. 19, it explains that an HSC 2012-compliant OSHA label and a DOT HMR label or marking may both be on the same package.

However, the two-page memo also notes that some examples of pictograms and symbols displayed on bulk packages aren't consistent with the Hazard Communication Standard (HCS, 29 CFR 1910.1200) and aren't compliant with hazard communication as spelling out by the U.S. Hazardous Materials Regulations (HMR). "Such labeling is prohibited by the HMR," it states.

During transportation, the HMR governs hazcom labeling requirements, and OSHA's HCS 2012 labeling isn't required on shipping containers in transport; the OSHA-required labeling must be in place on hazmat containers in the workplace, both before and after transport, says the memo, which indicates the agencies issued it in response to "a number of questions from stakeholders" concerning the labeling they require.

And the memo says the OSHA HCS 2012 requirements for shipped material apply independently of whether or not that material is subject to HMR labeling requirements during transport.

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