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General Requirements Retention of DOT Markings, Placards, and Labels
The classification of each chemical produced or imported must be consistent with the provisions of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 3. Information concerning the classification of hazards for each chemical must be transmitted to employers and employees by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, safety data sheets and employee training (see 29 CFR 1915.1200). Maritime requirements also affected by the Hazard Communication standard include Asbestos (29 CFR 1915.1001) and Chromium (VI) (29 CFR 1915.1026).

Retention of DOT Markings, Placards, and Labels
Potential Hazards:

The retention of markings, placards, and labels on hazardous materials the shipyard receives and handles is imperative in ensuring the safety and health of works. The premature removal of markings, placards, and labels before the sufficient cleaning of residue and the purging of hazardous vapors can lead to the improper handling and disposal of packaging contents, resulting in worker injury and/or possible death.

Requirements and Example Solutions:
  • Any package, freight container, rail freight car, motor vehicle, or transport vehicle received that is required to be marked, labeled, or placarded in accord with the U.S. Department of Transportation Hazardous Materials Regulations (49 CFR parts 171 through 180) must retain those markings, labels, and placards until the hazardous materials are sufficiently cleaned of residue and purged of vapors to remove any potential hazards (29 CFR 1915.92(a) and (b)).
  • Markings, placards, and labels must be readily visible (29 CFR 1915.92(c)).
  • Non-bulk packages that will not be reshipped, affixing a label or other acceptable marking in accord with 29 CFR 1910.1200, Hazard Communication is acceptable (29 CFR 1915.92(d)).

Note: For more detailed information on hazard communication, see OSHA webpage Hazard Communication.

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