The Drum Labeled Only CORROSIVE
You are loading at a pool-chemical supplier in South Florida for a run to Fort Myers. The load includes:
6 steel drums (non-bulk), each described as UN2922, Corrosive liquid, toxic, n.o.s. (sodium hypochlorite, sodium hydroxide solution), 8, PG II, with a Class 6.1 subsidiary risk shown on the shipping paper. Each drum has a single CORROSIVE label centered on the top head, and the shipping-paper pouch has been taped diagonally across the lower corner of that label.
10 fiberboard boxes of UN1263, Paint, 3, PG II, shipped as limited quantity. They carry no hazard labels, only a diamond limited-quantity mark - on one box, that mark is a photocopy on plain paper, taped to the side.
The shipper's lead says, "the toxic part is minor, the drum is already labeled, and the little boxes don't need anything." The van trailer will be loaded three drums high with boxes on top.
1. What labels must the six drums carry, and what is wrong with how they are applied?
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The shipping description itself answers the label question. UN2922 is Class 8 with a Class 6.1 subsidiary risk listed in Column 6 of the Hazardous Materials Table. A package must display a label for the primary hazard and a label for each subsidiary hazard. The drum therefore needs both a CORROSIVE (Class 8) label and a POISON (Class 6.1) label. The shipper's opinion that the toxic hazard is "minor" is irrelevant - subsidiary risks are assigned by the Table, not by the shipper's comfort level.
Application is also defective. Labels must be at least 100 mm (about 4 in) on each side, on point, durable, legible, and free of anything that obscures them. A drum loaded three high will have its top head covered, so a top-head label will not be visible to a responder or inspector. The pouch taped across the label corner obscures the hazard communication outright. The fix is to place both labels on the side of each drum, near the shipping name and UN number marking, and to move the document pouch clear of them.
2. Are the ten limited-quantity boxes correctly labeled and marked? Address the limited-quantity exception and the photocopied mark.
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The labeling is correct in principle. Class 3 PG II limited quantities are excepted from the hazard label requirement, so the absence of a FLAMMABLE LIQUID label is not a defect - the shipper is right about that part. The exception is conditional: the material must be within the limited-quantity limits for the class and packing group (for Class 3 PG II, generally 1 L per inner packaging and 30 kg gross per package), and the package must be marked with the limited-quantity mark.
The mark is where it breaks down. It must be durable, legible, and applied to the package so it survives handling, weather, and abrasion. A photocopy on plain paper taped to a fiberboard box will tear, fade, or peel before the truck reaches Fort Myers, and a mark that is not durable is not a mark. The shipper needs to apply a proper printed or weather-resistant limited-quantity mark directly to each box.
Also verify the boxes carry a UN certification mark rated for PG II - a "Y" or "X" - since the limited-quantity exception reduces labeling, not packaging strength.
3. The shipper refuses to change anything and asks you to sign the bill of lading so the truck can leave. What is your position, and what makes this a judgment call rather than a paperwork dispute?
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The refusal is justified, and signing does not fix it. The shipper's duties are to classify, describe, package, mark, and label correctly, and to certify that on the shipping paper. As the driver, you are not certifying the packaging or the labels, and you cannot cure a mislabeled drum by accepting it.
The judgment element is that the load is not uniformly bad. The limited-quantity boxes are correctly unlabeled; only the mark is defective. The drums are wrong on two counts - missing a subsidiary label and an obscured primary label - and those are the ones that matter at an incident: a responder who sees only CORROSIVE and not POISON will handle a spill differently than the hazard requires, and a label hidden under a pouch communicates nothing at all.
The practical path is to separate the lots. Offer to load the boxes once the marks are properly applied, refuse the six drums until both labels are on the side and unobstructed, and document what you refused and why. A carrier that loads it anyway owns the consequences.