Markings On UN Packagings Must Be Ligible To Be Compliant

When shipping non-bulk drums that contain hazardous materials, it is the shippers responsibility, and liability, to confirm that the packaging is compliant with 49CFR 178.500 and 178.600. With respect to the markings on the package, 178.503(a) states, “The markings must be durable, legible and placed in a location and of such a size as to be readily visible.” In addition, the CFR does not specify a required marking system and therefore, it is the responsibility of the manufacturer to choose a compliant format. At Skolnik, we emboss our permanent marks and use a laser printed pressure sensitive label for the durable side mark. Recently, we have seen drums in which the bottom embossment is illegible and we have seen other marking systems, (that print directly onto the drum surface) which often result in unreadable letters. If a shipper accepts new packagings (drums) that have an embossment or a durable mark that is not legible, they should return it to the manufacturer. If the drum is shipped, it is likely that the DOT will consider the illegible marks to be in violation of the CFR and the shipper will be fined.