Hazardous material markings retention

You must keep DOT-required markings, labels, or placards on the package until the package has been cleaned of residue and purged of vapors so that any potential hazards are removed. See 1917.29(a).

• Practical actions employers take to meet this requirement include: documenting the cleaning/purging procedures, testing for residual vapors before removing marks, and retaining evidence (e.g., cleaning logs or gas test results).
• If you need more information on the hazardous chemical itself (health hazards, safe handling), also consult the Hazard Communication Standard, 1910.1200 for labeling and safety data sheet requirements.

Placards may be removed only after the hazardous materials that required the placarding have been sufficiently removed so that they no longer present a potential hazard. See 1917.29(b).

• ‘‘Sufficiently removed’’ typically means unloading, cleaning, purging, or other actions (and verification testing when appropriate) to eliminate hazardous residues and vapors.
• Maintain records of removal, cleaning, and any verification testing to show why placards were removed.

Readily visible means the markings, placards, and labels must be kept legible and unobstructed so workers can see them during normal handling and inspection activities. See 1917.29(c).

• Practical steps: replace faded or torn labels, move obstructions that block viewing, mount placards where they can be seen from usual approach paths, and use weather-resistant or laminated labels when exposure to weather or solvents is expected.
• If a label becomes unreadable during operations, replace it immediately and document the replacement.

Non-bulk packages that will not be reshipped meet 1917.29 if they are labeled or otherwise marked in accordance with the Hazard Communication Standard, 29 CFR [1910.1200]. See 1917.29(d) and 1910.1200.

• This means affixing a compliant HazCom label that includes product identifier, signal word, pictogram(s), hazard statement(s), precautionary statement(s), and the supplier identification or other acceptable marking per 1910.1200.
• Keep and make available any corresponding Safety Data Sheets (SDS) required by 1910.1200 so workers know the hazards and controls.

Under 1917.29(e), the term "hazardous material" and any terms not defined in the section have the same meanings as in the Department of Transportation's Hazardous Materials Regulations (49 CFR parts 171–180). See 1917.29(e).

• In practice, that means you should consult the DOT Hazardous Materials Regulations for classification, marking, labeling, and placarding definitions and requirements referenced by 1917.29.
• When in doubt about a term, use the DOT definitions as the authoritative source cited by OSHA.

Under 1917.29, the employer who receives the package or transport unit is required to retain the markings and placards until the hazards are removed as specified by the regulation. See 1917.29(a) and 1917.29(b).

• That means when your facility receives hazardous-material packages, containers, railcars, or vehicles, your employer must keep the required markings/placards until cleaning, purging, or removal has eliminated the potential hazard.
• If you are both a carrier and receiver in a chain of custody, coordinate responsibilities and document when markings may be removed.

No — markings must remain until the package is sufficiently cleaned of residue and purged of vapors to eliminate potential hazards. See 1917.29(a).

• Employers should perform and document appropriate cleaning and vapor testing before removing markings.
• If residue or vapors remain, continue to treat the package as hazardous and retain DOT markings until verification shows it is safe.

Yes — employers must maintain markings so they are readily visible, which includes repairing or replacing damaged or missing labels and placards with equivalent, compliant markings. See 1917.29(c).

• Replacement marks should conform to DOT requirements when DOT markings are required and to [1910.1200] labeling for non-bulk packages that will not be reshipped per 1917.29(d).
• Use weather-resistant materials and keep a log of replacements so you can show ongoing compliance.

If a non-bulk package will be reshipped and is required by DOT to be marked or labeled, you must retain the DOT-required markings/labels until the package is cleaned and purged; the non‑bulk HazCom alternative in 1917.29(d) applies only when the package will not be reshipped. See 1917.29(a).

• For reshipped packages, follow the DOT Hazardous Materials Regulations (49 CFR parts 171–180) for required markings/labels.
• If you will convert the package to a non‑hazardous form before reshipment, document cleaning/purging to justify removal of DOT markings.

1917.29 does not prescribe a specific test method, but employers must ensure the package is purged of vapors so that potential hazards are removed before markings are taken off. See 1917.29(a).

• Practical verification methods include using calibrated gas detectors, performing air monitoring for the specific contaminant, and documenting results showing vapor concentrations below recognized safe thresholds.
• Keep records of monitoring, who performed it, instruments used and calibration, and the results to demonstrate compliance if questioned.

Employers must maintain markings so they are readily visible, which means correcting any situations where labels or placards are obscured by cargo, shrink-wrap, or palletization. See 1917.29(c).

• Actions to take: relocate the package so the marking is visible, apply an additional compliant label on an exposed face, or un-wrap/adjust palletization to expose required markings.
• If applying an additional label, ensure it meets DOT or HazCom standards as applicable.

When DOT markings, labels, or placards are required by the Hazardous Materials Regulations, employers must retain those DOT-compliant markings; they cannot substitute a different format. See 1917.29(a) and 1917.29(b).

• For non-bulk packages that will not be reshipped, employers may meet the requirement by affixing a marking that complies with 1910.1200 per 1917.29(d).
• Always follow the precise DOT specifications (49 CFR parts 171–180) for content, size, placement, and durability when DOT marks are applicable.

Yes — 1917.29 is part of OSHA’s maritime standards and applies to employers who receive hazardous-material packages, freight containers, railcars, motor vehicles, or transport vehicles in maritime operations. See 1917.29.

• Maritime employers must retain required DOT markings/placards per 1917.29(a)–(b).
• Coordinate with vessel operators, carriers, and longshore personnel to ensure appropriate retention, replacement, and removal procedures are followed and documented.

Hazard Communication training required by 1910.1200 helps workers understand labels and SDSs, but training alone does not replace the physical retention and visibility obligations under 1917.29. See 1917.29 and 1910.1200.

• Employers should both keep required markings visible per 1917.29 and provide HazCom training so employees understand the hazards shown on those markings and labels.
• Training should cover how to recognize DOT placards and HazCom labels, and procedures for reporting damaged or missing markings.

The receiving employer must retain the markings until the hazardous material has been sufficiently removed, cleaned, or purged to eliminate potential hazards — even if actual decontamination will occur off-site — unless and until the receiving employer documents that the condition no longer presents a hazard. See 1917.29(a) and 1917.29(b).

• If removal or decontamination is to occur off-site, retain the markings until a qualified person verifies the package or vehicle has been decontaminated and records that verification.
• Maintain chain-of-custody and decontamination documentation to show why markings were removed after off-site cleaning.

While 1917.29 does not explicitly prescribe a recordkeeping format, employers should document cleaning, purging, tests, or other actions that justify removing markings to demonstrate compliance. See 1917.29(a)–(b).

• Practical records include cleaning logs, vapor test results, date/time of removal, responsible person, and photographs before/after removal.
• Good documentation helps show that the package, container, or vehicle no longer posed a hazard when markings were removed.

When using a Hazard Communication label to meet 1917.29(d) for non-bulk packages not to be reshipped, the label must comply with the labeling elements required by [1910.1200], such as product identifier, signal word, pictogram(s), hazard statement(s), precautionary statement(s), and supplier identification (or other acceptable marking consistent with 1910.1200). See 1917.29(d) and 1910.1200.

• Also keep the corresponding Safety Data Sheet (SDS) available per [1910.1200].
• If unsure which hazard class applies, consult the SDS or the DOT Hazardous Materials Regulations referenced by 1917.29(e).

Yes — placards required by DOT must remain on the transport unit until the hazardous materials that necessitated the placarding have been sufficiently removed to prevent potential hazards, including during intermediate handling and maintenance moves. See 1917.29(b).

• For maintenance that requires emptying and cleaning the vehicle or container, verify cleaning/purging and document before removing placards.
• Ensure workers performing maintenance are trained and protected per applicable standards, including HazCom 1910.1200 for chemical hazards.

You must follow any more stringent state or local requirements in addition to 1917.29; OSHA sets a federal minimum for maritime workplaces, but state or local laws that are more protective must be followed. See 1917.29.

• Check with your state OSHA plan (if applicable) or local authorities to determine additional obligations.
• When in doubt, comply with the most protective applicable requirement and document the basis for your actions.