OSHA & GHS Labeling 101: Tank Cars/Trucks

 DOT Tanker Truck and Railroad Tank Car Labeling

In instances where a tank truck, rail car, or similar vehicle that is comprised of containers with hazardous chemicals, labeling information is to be place either on the outside of the car or attached with shipping papers.

Labels are required to be shipped with the vehicle, no separate labels are allowed. The goal is to provide an immediate hazard warning.

When labels are shipped directly to employees who are transporting the hazardous chemicals this defeats the purpose. (There are exemptions such as solid metals, plastics, shipments of whole grain, and even whole wood.)

Any tanker truck labeled in accordance with the DOT labeling requirements and is unloaded into a storage tank, the DOT labeling will be sufficient for the storage tanker truck and or railroad tank car before offloading. The HCS labeling requirements apply.

In instances where a tanker truck or railroad car becomes a part of the processing or piping system, it must be labelled according to paragraph (f) (7) of the OSHA safety manual. This means it is a stationary process container.

Labels and Other Warnings, Paragraph (f). 1. General Labeling Requirements. A. Manufacturers and importers are required to comply with the June 1, 2015 provisions. Those in the distribution industry have until December 1, 2015 to comply with these standards. Manufacturers and importers who take on a shipment are responsible for labeling and must be in compliance as well. During the classification process, importers or manufacturers are to determine the proper classification and category. Hazard statements such as “Danger” or “warning” must be put on the label if needed. In Appendix C you will see the standard for shipments who qualify for signal words. All labels are to be in English, but supplemental languages can be used as well.

Any hazard that is not classified as a (HNOC) is not required to be noted on labeling. However, it must be included as supplementary hazard information on the label. Importers, distributors and manufacturers can also list environmental effects on the label should that be applicable. OSHA neither approves nor endorses any labels. Any wording that states “OSHA certified/approved/compliant” on any HCS label is completely prohibited.

Confused by all the requirements? Not sure if you’re in complaince? TCA can help to provide seamless support for your operation!! Contact us today or call toll free 855-637-9566 to learn more!