(The EHS marking is not needed for EHS of less than 5L or 5kg. There are shippers tendering shipments with the EHS marking. Should we ask them to remove?)

Q.
There are shippers who apply the EHS marking for PI Y964 and Y 956. If the net quantity is 5L or 5kh or less, you need not apply the EHS marking. Shippers claim that the rules do not say that we must not apply the marking. Should we refuse the shipment. (31 Oct 13)

A.
The EHS marking as shown in Figure 7.1.B is required if the net quantity of a single packaging or the net quantity of the inner packaging of a combination package exceeds 5L or 5kg. If within, the rule says “not required”.

Any packages with markings not related to the actual contents must be rejected, but since the regulations does not prohibit the use of EHS marking, I find no reason why we should reject the shipment or demand removal of the EHS marking. It does not jeopardize safety.

I would advise the shipper that they need not put the EHS marking if the quantity is less than the limits. While, for MAG labels, it clearly states in 7.2.3.9.1 that Class 9 label “must be replaced by” the MAG label.


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