A difficult shipper ! If the labels and Mar ings are on one single side, it will certainly help his package to reach the desired destination without any mishap or delay. Guess he doesn?ft understand that his own stubbornness will work against himself. Indeed, there are many types of shippers. Indeed the rules do not forbid to Mar the packages on the top surface. However, to transport packages, the very natural consequence will be that the packages will have to be stacked to be palletized or placed into containers. It is common sense that you would not put the labels and Mar ings on the top side of the package as they will be obstructed from sight. This shipper is taking the risk of his packages to go astray.
DGR 220.127.116.11.1 and 18.104.22.168.5 stipulate the position where you are to place the labels. In DGR 22.214.171.124, it says the CAO label must be placed on the same surface where the Hazard labels are shown. The ideal package will be the illustration shown as Figure 7.2.A on Page 601 of the DGR where all labels and Mar ings are applied on one single side of the package. Your shipper needs to attend one of our initial DG courses. You May wish to advise the shipper that all packages are bound to be stacked and it is better and safer to have all the Mar ings and labels shown on one single side so the packages would not go astray.
Yes, the regulation does not forbid placing the Mar ings and labels on the top. However, it is common sense not to do that because packages are bound to be stacked.