PHMSA Revises 2016 Interpretation on Cylinder Labeling
The Pipeline and Hazardous Materials Safety Administration has revised an interpretation letter (see below) dated October 20, 2016 to clarify that the words “flammable gas” or “non-flammable gas” may be placed on two lines instead of one line when set out in the transportation diamond as illustrated in CGA C-7, Appendix A.
The new interpretation states that the Hazardous Materials Regulations provide several options for labeling of compressed gas cylinders. Although the letter states that neither CGA C-7, Appendix A nor the HMR specifically illustrate the hazard class text displayed on two lines, 49 CFR 172.407(f) of the HMR specifically permits the use of labels that conform to the UN Model Regulations in place of a corresponding label that conforms to the HMR. Section 184.108.40.206.1.5 of the UN Model Regulations states that for labels other than Class 7 labels, the insertion of any text in the space below the symbol is authorized provided it relates to the nature of the hazard and the precautions to be taken in handling.
Thus, PHMSA concluded that a label displaying the words “flammable gas” or “non-flammable gas,” whether on one or two lines, that otherwise conforms to the UN Model Regulations, is permitted by 49 CFR 172.407(f).