printreg, October, 2003
Exceptions to DOT Labeling Requirements

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From:Debra Jacobson (
Date: Thu, 16 Oct 2003 08:57:51

The following is a summary of exceptions to DOT labeling requirements. All other materials and packages not listed here are subject to DOT labeling and placarding requirements.
Debra Jacobson


Hazardous Material Labeling Exceptions According to the Department of Transportation (DOT) at 49 CFR 172.400a, the following hazardous materials are excepted from the labeling requirements:

* Cylinders containing Division 2.1 or 2.2 compresses gases that are not poisonous, carried by private or contract motor carrier, not overpacked and are packaged and labeled in accordance with the standards of the Compressed Gas Association (CGA)
* Packages or units of military explosives shipped by or on behalf of the Department of Defense when in:
* Freight containerload, carload, truckload shipments, if loaded or unloaded by the shipper or DOD,
* Unitized or palletized break-bulk shipments by cargo vessel under charter to DOD if at least one required label is displayed on each unitized or palletized load
* Package containing a hazardous material other than ammunition that is:
* Loaded and unloaded under the supervision of DOD personnel
* Escorted by DOD personnel in a separate vehicle * Compressed gas cylinders permanently mounted to/in a transport vehicle
* Freight containers, aircraft unit load device or portable tank which are placarded in accordance with 49 CFR 172 Subpart F
* Overpacks on which labels representative of each hazardous material in the overpack or unit load device are visible
* Packages containing low specific activity radioactive materials and surface contaminated objects
* Limited quantity, small quantity, and consumer commodity shipments

These exceptions do not apply to hazardous materials shipped by air.

Source: "reg of the day" listserv operated by Tammy Silverthorne @ the Environmental Resource Center

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