PHMSA Allows Cylinder Labels with Hazard Text on Two Lines 

The Pipeline and Hazardous Materials Safety Administration (PHMSA) has notified GAWDA that cylinder labels with the text, “Flammable Gas” or “Non-Flammable Gas,” shown on two lines instead of one line are acceptable under the Hazardous Materials Regulations (HMR). 

Although the cylinder label requirements in 49 CFR § 172.405(a) do not require hazard text on the label for Division 2.1 or 2.2 gases, the label examples in § 172.417 (for flammable gases) and § 172.415 (for non-flammable gases) show the text on one line. Some GAWDA members have been cited recently in New York State for having the hazard text on two lines on their labels. The citations were based on an Oct. 20, 2016 interpretation from PHMSA stating that if the text was included on the label, it must be on a single line.
 
In an email from Shane Kelly, director of standards and rulemaking at PHMSA, GAWDA was informed that cylinder labels for flammable and non-flammable gas may have hazard text on two lines because they meet with UN standards. 49 CFR § 172.407(f) contains an exception stating that a label conforming to specifications in the UN Recommendations (which are incorporated by reference into the HMR) may be used in place of a corresponding label that conforms to the HMR requirements. Because the UN recommendations provide that hazard text is optional for Division 2.1 or 2.2 labels, a label that includes hazard text may have it on one or two lines. PHMSA also indicated it would revisit the October 2016 interpretation to the contrary.
 
If you have any questions related to cylinder labels or receive any more citations, please contact GAWDA Consultants Mike Dodd at  mldsafety@hotmail.com , 573-718-2887, or Rick Schweitzer at  rpschweitzer@rpslegal.com , 703-946-2548.