Hazardous material markings retention

You must keep the Department of Transportation (DOT) markings, labels, and placards on the package until the package has been cleaned of residue and purged of vapors so that any potential hazards are removed. See 1915.92(a).

• The retention period ends only when the packaging is "sufficiently cleaned of residue and purged of vapors to remove any potential hazards."
• If residue or vapors remain, the markings and placards must stay in place to communicate the hazard.

You must retain DOT-required markings and placards on those transport units until the hazardous materials have been sufficiently removed to prevent any potential hazards. See 1915.92(b).

• Removing cargo (unloading) alone does not automatically allow removal of placards if residue or vapors remain.
• The placards may only be removed after the vehicle or container is cleaned or otherwise made free of potential hazards.

You must keep markings, placards, and labels in a condition and location where they can be easily seen and read by workers and emergency responders. See 1915.92(c).

• Readily visible means not obscured by dirt, paint, packaging, or other materials and positioned where normal movement or inspection will reveal them.
• If a marking becomes faded, damaged, or covered, the employer should restore or replace it so the hazard information remains apparent.
• Maintain visibility during storage, handling, and any on-site movement of the package or transport vehicle.

Yes—if a non-bulk package will not be reshipped, the requirement is met by affixing a label or other acceptable marking in accordance with the Hazard Communication Standard at [1910.1200]. See 1915.92(d) and 1910.1200.

• This means you can use the employer-applied HazCom label and workplace labeling system required by 1910.1200 instead of DOT markings when the package is not being reshipped.
• For bulk packages, transport vehicles, and any package required by DOT to remain marked, the DOT markings still must be retained until cleaned/purged.

The employer who receives the package, freight container, rail car, motor vehicle, or transport vehicle is responsible for retaining those DOT-required markings, labels, and placards as specified in [1915.92(a) and (b)]. See 1915.92(a) and 1915.92(b).

• The duty attaches to the receiving employer, not solely to the carrier or shipper, once the package or vehicle is received at the workplace.
• The receiving employer must ensure markings remain until the packaging or vehicle is rendered safe by cleaning/purging.

No—markings, placards, and labels must be maintained so they are readily visible and should not be obscured during handling or storage. See 1915.92(c).

• If handling requires temporary coverings for protection, the employer must ensure that hazard information remains accessible (for example, by using transparent covers or relocating the marking to a visible spot).
• If a marking becomes obscured, the employer should restore visibility immediately or replace the marking consistent with the standard.

No—DOT placards and markings must remain until the packaging is sufficiently cleaned and purged of vapors (for packages) or until hazardous materials are sufficiently removed (for containers, rail cars, and vehicles) to prevent any potential hazards. See 1915.92(a) and 1915.92(b).

• Simply unloading bulk or non-bulk cargo does not end the retention obligation if residue or vapors remain that could create a hazard.

For non-bulk packages that will not be reshipped, an employer can use a label or other acceptable marking that complies with the Hazard Communication Standard, [1910.1200]. See 1915.92(d) and 1910.1200.

• Acceptable markings include workplace labels, pictograms, signal words, hazard statements, and manufacturer-provided information as required by 1910.1200.
• This alternative applies only to non-bulk packages that will not be reshipped; it does not change the retention rules for bulk packages or transport vehicles.

No—an employer cannot remove DOT markings based solely on a cursory wipe-down; markings may be removed only after the packaging is sufficiently cleaned of residue and purged of vapors to remove any potential hazards. See 1915.92(a).

• "Sufficiently cleaned" means there should be no remaining residue or vapors that could pose a hazard; employers should evaluate contamination, odor, and vapors before deciding to remove markings.
• When in doubt, retain the markings until you can verify the package presents no potential hazard.

Yes—the requirement applies to any employer who receives a package or transport unit that is required to be marked under the DOT Hazardous Materials Regulations, regardless of whether the shipment is domestic or imported. See 1915.92(a) and 1915.92(b).

• The standard refers to DOT-required marking obligations, and that duty follows the marked package to the receiving employer at the workplace.

Yes—markings must remain on the package until it has been sufficiently cleaned and purged of vapors so that potential hazards are removed. See 1915.92(a).

• An "empty" container can still present hazards from residue or trapped vapors, so the package retains the marking obligation until it is rendered safe.

No—this section specifically requires retention of markings, labels, and placards; it does not impose a separate requirement to retain shipping papers or manifests. See 1915.92.

• Shipping papers and manifests are generally governed by the DOT Hazardous Materials Regulations, not by this particular OSHA text, so employers should consult the DOT rules for those recordkeeping duties.

You must restore or replace the marking so that it is readily visible and legible; maintaining visibility is required by [1915.92(c)]. See 1915.92(c).

• If damage makes the label unreadable, apply a replacement that conveys the same DOT-required hazard information.
• For non-bulk packages that will not be reshipped, consider using a 1910.1200-compliant workplace label per 1915.92(d).

No—the standard does not provide a numeric or procedural definition of "sufficiently cleaned of residue and purged of vapors"; employers must ensure cleaning and purging remove any potential hazards before removing markings. See 1915.92(a).

• Employers should adopt procedures based on the nature of the material (including flammability, toxicity, and vapor hazard), manufacturer and DOT guidance, and workplace practices to verify that residues and vapors no longer present hazards.
• Where appropriate, document cleaning and purging steps and any tests (e.g., air monitoring) used to confirm safety.

No—DOT markings on a bulk package required under DOT rules must remain until the package is sufficiently cleaned and purged of vapors to remove any potential hazards; reuse for nonhazardous material does not allow removal before cleaning. See 1915.92(a).

• Before reusing a bulk package for a different commodity, ensure all residues and vapors are removed to the extent they pose no potential hazard and then remove or replace markings as appropriate.

You must retain the DOT-required markings and ensure they are readily visible on the packages that were required to be marked, while applying workplace controls to separate or identify those marked items as needed. See 1915.92(a) and 1915.92(c).

• Maintain visibility of markings on hazardous packages, and use segregation, secondary containment, or clear area labeling to reduce risk to workers handling the mixed load.
• For non-bulk hazardous packages not to be reshipped, you may use a 1910.1200-compliant workplace label per 1915.92(d).

Yes—if a freight container, rail car, motor vehicle, or transport vehicle is required to be marked or placarded under DOT rules, you must retain those markings until the hazardous materials are sufficiently removed to prevent potential hazards, even if the unit will be transported off-site for disposal. See 1915.92(b).

• If disposal involves transporting the unit while hazardous residue or vapors remain, retain placards and markings during transport as required by DOT and OSHA.

No—this section applies to packages and transport units that are required to be marked, labeled, or placarded in accordance with the U.S. Department of Transportation Hazardous Materials Regulations; it does not impose marking-retention duties for items that were not required to be marked. See 1915.92(a).

• If DOT did not require a marking, the retention obligation in 1915.92 is not triggered, although other OSHA standards (such as 1910.1200) may require workplace labeling or hazard communication.

No—using a HazCom-compliant label on a non-bulk package that will not be reshipped satisfies the marking requirement in [1915.92(d)], but the employer must still meet all other applicable Hazard Communication duties under [1910.1200], such as providing safety data sheets and employee training. See 1915.92(d) and 1910.1200.

• Labeling alone does not substitute for required training, access to safety data sheets, or other employer responsibilities under 1910.1200.