Hazardous materials marking retention

You must keep the DOT markings, labels, or placards on the package until the packaging is cleaned and purged so that no potential hazards remain. See 1910.1201(a).

• Keep markings in place until residue is removed and vapors have been purged to eliminate hazards.
• Use chemical Safety Data Sheets (SDS) and DOT/HMR guidance to determine when cleaning and purging are complete.

Markings and placards must remain on the freight container, rail freight car, motor vehicle, or transport vehicle until the hazardous materials that required the marking or placarding are sufficiently removed to prevent any potential hazards. See 1910.1201(b).

• Do not remove placards merely because cargo is moved or relocated; ensure hazardous contents or residues no longer pose a danger before removing.
• Follow DOT/HMR procedures and consider testing/monitoring to confirm removal of hazards.

Markings, placards, and labels must be kept in a condition and location so they are clearly visible whenever they are required. See 1910.1201(c).

• Keep markings free of dirt, paint, tape, or other materials that obscure wording or symbols.
• Place or re-position labels/placards so they are not blocked by packaging, shrink-wrap, or cargo handling fixtures.
• Replace or reapply faded, torn, or illegible markings promptly to preserve visibility and meaning.

Yes — for non-bulk packages that will not be reshipped, you meet 1910.1201 if you affix a label or other acceptable marking in accordance with the Hazard Communication Standard. See 1910.1201(d) and the Hazard Communication Standard at 1910.1200.

• Use the required HazCom elements (product identifier, signal word, pictograms, hazard statements, precautionary statements, and supplier information) when labeling non-bulk packages that will remain on-site and not be reshipped.
• Keep SDS information available for employees handling those packages as required by 1910.1200.

The term "hazardous material" in 1910.1201 has the same definition as in the Hazardous Materials Regulations (49 CFR Parts 171 through 180). See 1910.1201(e).

• When you need the specific regulatory definition for classification, consult the DOT Hazardous Materials Regulations (49 CFR Parts 171–180).
• For workplace labeling and hazard communication you should also reference OSHA's Hazard Communication Standard at 1910.1200 for complementary duties.

No — you must retain the DOT markings until the package is sufficiently cleaned of residue and purged of vapors so that no potential hazards remain. A persistent odor indicates vapors or residues may still pose a hazard, so markings must remain. See 1910.1201(a).

• Use appropriate testing or monitoring to confirm vapors are below hazardous levels before removing markings.
• Keep records of cleaning and testing where feasible to demonstrate compliance.

No — placards must remain on the vehicle until the hazardous materials that required the placarding have been sufficiently removed to prevent any potential hazards. See 1910.1201(b).

• If any residue, vapors, or other hazardous conditions remain during or after unloading, keep the placards in place.
• Only remove placards after confirming removal of hazards by inspection, cleaning, or monitoring.

No — you may not cover a required marking or placard if doing so prevents it from being readily visible; markings must be maintained so they are visible. See 1910.1201(c).

• If you must protect a marking from damage, use a method that preserves full visibility and legibility (for example, applying a clear protective coating or relocating the package so the marking remains visible).
• If a marking becomes damaged, replace it promptly to restore visibility.

You must restore or replace the marking so it is readily visible and legible; maintaining clear markings is required by the standard. See 1910.1201(c).

• For non-bulk packages that will not be reshipped, you may instead affix a compliant Hazard Communication label per 1910.1201(d) and 1910.1200.
• Keep replacement labels consistent with DOT/HMR requirements when reshipment or transport is intended.

An overpack that contains packages required to be marked or placarded must be handled so that required markings remain valid and readily visible until the hazardous contents are sufficiently removed or the overpack is cleaned/purged. See 1910.1201(a)–(c).

• If the original markings on inner packages are no longer visible, ensure the overpack itself bears equivalent markings/labels that convey the required hazard information and remain legible.
• If the overpack will not be reshipped and is non-bulk, you may use a HazCom label per 1910.1201(d).

The standard requires that markings remain until residue is removed and vapors purged so no potential hazards remain; you should document cleaning, use appropriate testing, and follow manufacturer/DOT/HMR guidance to verify safety. See 1910.1201(a).

• Follow SDS and DOT/HMR cleaning/decontamination guidance for the specific chemical.
• Use air monitoring or wipe testing to show vapors/residues are below hazardous levels.
• Record cleaning procedures, personnel involved, dates, and test results to demonstrate that hazards were removed.

If a non-bulk package will not be reshipped, the employer can meet 1910.1201 by affixing a label or other acceptable marking in accordance with the Hazard Communication Standard to the decanted container. See 1910.1201(d) and 1910.1200.

• Ensure the HazCom label includes required elements (product identifier, hazard statement, pictograms, precautionary statements, and supplier information) per 1910.1200.
• Maintain SDS access and provide employee training on hazards and safe handling.

The employer who receives the package or transport vehicle is responsible for retaining the markings and placards until the hazardous materials are sufficiently removed or the package is cleaned/purged. See 1910.1201(a)–(b).

• Receiving employers must ensure markings stay in place and remain legible until hazards are eliminated.
• Coordinate with carriers and shippers when cleaning, offloading, or disposing of hazardous-material packages to confirm when placards/labels may be removed.

No — if a package will be reshipped, you must retain the DOT markings required by the Hazardous Materials Regulations until you have cleaned and purged the package so it no longer presents hazards; the non-bulk/No-Reshipment exception in 1910.1201(d) only applies when the package will not be reshipped. See 1910.1201(a).

• For packages intended to move in commerce, follow DOT/HMR marking rules until the package is confirmed hazard-free.

The 1910.1201 requirement focuses on maintaining markings, placards, and labels so they are readily visible; practical compliance normally means preserving DOT-identifiable symbols and wording so emergency responders and handlers can recognize the hazard. See 1910.1201(c).

• If a DOT-style marking is required by the Hazardous Materials Regulations, replacing it with an equivalent DOT-compliant marking is appropriate when the original is damaged.
• For non-bulk packages not reshipped, a compliant HazCom label per 1910.1200 is acceptable under 1910.1201(d).

Treat the package as hazardous and retain required markings and placards until you can confirm cleaning/purging has eliminated potential hazards. See 1910.1201(a)–(c).

• Conduct testing, consult SDSs, or engage qualified cleanup contractors to identify residues and confirm decontamination.
• Keep markings in place while residues are present or until professional clearance is documented.

Yes — 1910.1201 references packages and transport units that are required to be marked, labeled or placarded under the U.S. Department of Transportation's Hazardous Materials Regulations, so employers must follow those DOT/HMR marking requirements as applicable while also meeting OSHA's retention and visibility rules. See 1910.1201(a)–(b).

• Use DOT/HMR rules to determine what markings are required initially and comply with OSHA for how long and in what condition they must be maintained.

While 1910.1201 does not explicitly prescribe a separate training requirement, employers should train employees on marking retention as part of their overall hazardous-materials handling program; Hazard Communication training under 1910.1200 is an appropriate place to cover label meanings and retention practices. See 1910.1201(d) and 1910.1200.

• Train receiving, storage, and shipping staff to recognize DOT placards and HazCom labels, how long to keep them, and what steps confirm a package or vehicle is safe to delabel.

No — placards must remain until the hazardous materials that required the placarding are sufficiently removed to prevent any potential hazards, and contaminated piping or residue can continue to present hazards. See 1910.1201(b).

• Ensure inspections, cleaning, and appropriate testing are completed before removing placards.
• Coordinate with carriers and qualified cleaners to document when hazards have been eliminated.

Yes for non-bulk packages that will not be reshipped — you may use a labeling system that complies with the Hazard Communication Standard in lieu of the DOT marking requirement. See 1910.1201(d) and 1910.1200.

• For bulk packages, transport units, or items intended for reshipment, you must retain DOT-prescribed markings/placards until hazards are removed per 1910.1201(a)–(b).
• Any facility-specific system should still communicate hazard information clearly to employees and emergency responders.