⚠️Common Labeling Mistake: UN Number Size on Haz Waste Containers⚠️
- abbyholovach
- 4 days ago
- 2 min read
One of the most overlooked details on hazardous waste containers is the size of the UN identification number. Under DOT regulations (49 CFR 172.301(a)(1)), the “UN” or “NA” number must be at least 12 mm (½ inch) high on non-bulk packages (and many IBC totes! Check out the blurb down below about a great option for labeling totes).
Here’s where many generators go wrong: the preprinted hazardous waste label often includes a small UN number space, but oftentimes, that size doesn’t meet DOT’s visibility requirement.
So even though your “Hazardous Waste” label might look compliant, if the UN number isn’t large enough, it’s technically a DOT labeling violation. A quick fix is to apply separate bold, 0.5-inch-high UN numbers next to the waste label, if a space is not already provided - it keeps shipments compliant and inspectors happy!
In regard to labeling IBC totes, here is a great excerpt from Daniels Training Services:
"A shipper of hazardous materials in an IBC may display a HazMat label on one side of an IBC with a capacity of <1.8 m3 (64 ft3). Remember: the capacity of a typical IBC is 275 – 330 gallons (330 gallons = 1.25 m3 = 44 ft3). If taking advantage of this option the shipper may also display the proper shipping name and identification number marking near the HazMat label on one side of the IBC in the same manner as if it was a non-bulk packaging.
For a bulk packaging with a capacity of <18 m3 (640 ft3), either display HazMat labels or placards according to subpart F per §172.400(a)(2).
Display HazMat labels on the IBC as directed by subpart E per §172.514(c).
According to §172.406(a)(2) and §172.406(e), display of more than one HazMat label on a package is generally not required.
Display HazMat labels on one side of an IBC with a capacity of <1.8 m3 (64 ft3) per §172.406(e)(6).
Display the proper shipping name and identification number marking in the same manner as a non-bulk packaging as is described at §172.301(a)(1) per §172.514(c)(4)."
