Recently, I received an interesting question about the labeling of hazardous materials during transport.
Specifically, the question was why, in some cases, an additional label for environmentally hazardous substances is used alongside the standard ADR label (danger placards).
My colleague Simona Miklavčič, our ADR safety advisor, helped me with the answer. It might be interesting to you as well.
Packages (packaging together with contents ready for shipment) containing environmentally hazardous substances must be permanently marked with an environmental hazard label. Therefore, this is an additional label that is independent of the UN number and corresponding ADR label.
It looks like this:
How do we know which substances are hazardous to the environment?
If you are familiar with the regulations on the classification, labeling, and packaging of hazardous chemicals, then you know the answer to this question. Environmentally hazardous substances are those that have at least one H4XX label listed in section 2 of the safety data sheet or on the label:
- H400 Very toxic to aquatic life.
- H410 Very toxic to aquatic life with long-lasting effects.
- H411 Toxic to aquatic life with long-lasting effects.
- H412 Harmful to aquatic life with long-lasting effects.
- H413 May cause long-lasting harmful effects to aquatic life.
In terms of hazardous materials transport regulations, chemicals classified as toxic are considered environmentally hazardous. This means they are assigned labels H400, H410, or H411. According to ADR hazardous materials transport regulations, these chemicals must be marked with an additional environmental hazard label.
Let's look at an example.
The chemical is classified under the regulations as H225 (Highly flammable liquid and vapor) and H411 (Toxic to aquatic life with long-lasting effects).
In accordance with hazardous materials transport regulations, this chemical is assigned UN number 1268, and the transported goods must be marked with a class 3 hazard placard. It looks like this:
However, due to the H411 label, an additional label indicating environmental hazard is required. This means that in our example, the transport will be marked as follows:
There are exceptions. In the case of environmentally hazardous substances, these are packages containing less than 5 liters of liquid or 5 kilograms of solid substances. These packages do not require an additional environmental hazard label.
This pertains to the transport of smaller packaging units, about which you can read more here.
Labeling environmentally hazardous substances is a good example of the connection between chemical regulations and hazardous materials transport regulations.
If you also have an interesting question about labeling hazardous materials, feel free to write to me at nina.pajovic@bens-consulting.eu.
nina.pajovic@bens-consulting.eu
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