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hi I am dan stare of Daniels training services and I provide training and consulting services for the management of waste and also for the transportation of hazardous materials and that's what I'm here to talk about today this is a packaging or a package that was used for a product and I got this at my local hardware store they were done with it and so I asked like an abbot and here it is and so this is a packaging that's used for the transportation in commerce of a hazardous material okay a specific kind of hazardous material actually so what I'm going to do in this video is explain some of the labels and markings that appear on this package and one particular market that I thought was a violation but actually the regulations allow for that particular type of marking and I'm gonna explain all of that in this video here so first off what do we got this is a cardboard box or what's known by its specification code as a Ford g4g fiberboard box this was used as a combination packaging it contained four one gallon containers inside of it so that's what there was a combination packaging and it was shipped as a fully regulated hazardous material so they didn't take advantage of the limited quantity exception or anything like that there's a couple indicators of how I know it was shipped as a fully regulated hazardous material one is that they used specification packaging now you won't be able to see it in the video and it's not the point of this video anyways but this UN symbol is the marking for a UN specification packaging and that's only required for fully regulated hazardous materials also it's got the orientation arrows on two opposing sides that's required for hazmat where there's inner liquid packagings we got that also it has the hazmat label so that's what this is here the class 8 corrosive material hazmat label and all of that is subject to the regulations and it all appears to be just fine even the fact that this label is printed on the box it's not fixed as a label that's okay and even though it's not the usual bright white colors versus black that's okay as well as long as it meets the requirements for contrasting color what's also just on the margin of this label and I'll try to insert a photo into this video so you can see it better is the proper shipping name and the identification number okay that's required marking on hazmat packaging and so the proper shipping name is hydrochloric acid solution now there isn't a proper shipping name for a hydrochloric acid solution there's a proper shipping name for hydrochloric acid so what that tells me is they use the allowance at 172 point 101 c10 that's entitled 49 they use that allowance to identify this as hydrochloric acid solution so that tells me that this isn't they classified this as not a pure hydrochloric acid but rather a solution okay so that's how its identified there that's still not the point of this video what I want to draw your attention to is this UN 1789 that is the identification number for this particular hazardous material UN three United Nations means you can ship it anywhere around the world with that identification and then 1789 is its specific identifier for hydrochloric acid okay everything seemed fine it does but as of January 1st of 2017 so just earlier this year it became mandatory that that identification number marking be a certain size okay so for most packagings it needs to be 12 millimeters about half an inch for packaging's of this size it needs to be at least six millimeters hot so a quarter-inch I don't think I never ruler I mean I don't think it even meets that requirement and that's where I thought aha there's a violation here and forgive me but a few things make me happier than actually finding a violation that somebody's making the hazmat regs but that's not the case so no sunny side here they're doing just fine because even though there is that requirement for the height of the identification number marking on a hazmat package there is also this in 49 CFR 172 0.301 stick with me a1 double I okay so you got a dig for it but in the regulations it says there is an exception for permanently marked packaging's and that's what this is this is in a label someone stuffed on here imagine they've got a million of these boxes in a warehouse someplace all inked up and printed with it sighs okay so this exception for permanently marked packaging says and I'm summarizing here but it reads that a packaging manufactured prior to January 1 2017 and permanently marked with the identification number at the smaller size can continue to be in use on continuous service until the end of its useful life regardless of whether the identification number markings meets the mineral size requirements so what does that mean that means that this company can continue using this packaging until they've used them all up as long as it was manufactured before January 1 of 2017 they can continue using it until they use them all up now this particular packaging it's time to dump spend used um there are some allowances for reuse or not getting into that here but this packaging then will simply go to recycling and it will be done and all of its other compete reott that it has back in the warehouse will all be used up and even though that identification number doesn't meet the current height requirement it's still okay alright so that's just a little thing about the hazmat regulations if you ship hazardous materials if you're responsible for them you need to know about that minimum height requirement for the identification number I wrote an article for my blog on the subject and I'll put a link to that article at the end of this video in the comments and so you can take a look at that if you need more information if you have any questions about shipping hazardous materials in commerce please don't hesitate to contact me thank you very much