CVSA inspection bulletin addresses GHS markings during transport

Enforcement given guidance on what is permissible

Posted October 12, 2017

The Commercial Vehicle Safety Alliance (CVSA) recently posted Inspection Bulletin “2017-03 – Display of GHS Labels on Bulk Packages” on its website.

Specifically, the document offers guidance to roadside inspection personnel when dealing with Globally Harmonized System of Classification and Labeling of Chemicals (GHS) pictograms or labels on bulk packages during transport. It covers Section 172.401, relating to prohibited labeling, and Section 172.502, relating to prohibited and permissive placarding.

Previously, the Pipeline and Hazardous Materials Safety Administration (PHMSA) and the U.S. Department of Labor Occupational Safety and Health Administration (OSHA) issued a joint guidance memorandum titled, “Labeling of Hazardous Chemicals for Bulk Shipments.” Both the joint letter and the Inspection Bulletin state that you may use GHS labels with hazmat warning labels and placards that are required by the Hazardous Materials Regulations, provided they are displayed as a complete GHS label. Showing just part of a GHS label, such as pictograms, is not authorized.


Hazardous Materials Compliance PocketbookJ. J. Keller's Hazardous Materials Compliance Pocketbook gives your drivers fast access to the current info they need to check placards, labels, markings and shipping papers for compliance with hazardous materials regulations.

 

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