Hazardous material marking retention

Under 1918.99(a), you must keep the DOT-required markings, labels, and placards on the package until the packaging is sufficiently cleaned of residues and purged of vapors to remove any potential hazards.

• Keep the original DOT markings in place while any hazardous residues or vapors that could create a hazard remain.
• Do not remove or cover the markings until cleaning and purging are complete and the package no longer presents a hazard.
• See 1918.99(a) for the exact requirement.

Under 1918.99(b), markings and placards must remain on a 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.

• This means markings stay on until the cargo and any residues or vapors that could cause harm are removed.
• The requirement covers the whole transport unit (container, car, vehicle) — not just individual packages inside.
• See 1918.99(b) for details.

Under 1918.99(c), markings, placards, and labels must be maintained so that they are readily visible.

• "Readily visible" means labels and placards are legible, not faded, not obstructed by dirt or equipment, and placed where workers can see them during normal handling.
• Inspect markings regularly and repair or replace them if they become illegible or obscured.
• See 1918.99(c) for the requirement.

Yes. Under 1918.99(d), non-bulk packages that will not be reshipped meet this section’s requirements if a label or other acceptable marking is affixed in accordance with OSHA's Hazard Communication Standard, 29 CFR 1910.1200.

• Use a [1910.1200]-compliant label that identifies the hazardous chemical, hazard warnings, and the responsible party where appropriate.
• This option applies only to non-bulk packages that will not be sent out again; it does not change the retention rule for bulk packages or transport vehicles.
• See 1918.99(d) and 29 CFR 1910.1200 for details.

Under 1918.99(e), the term "hazardous material" has the same definition as in the Hazardous Materials Regulations (49 CFR parts 171 through 180).

• That means the DOT definitions and classifications in 49 CFR parts 171–180 determine whether a material is a "hazardous material" under 1918.99.
• Employers should consult the DOT Hazardous Materials Regulations for classification and marking details and then comply with the retention rules in 1918.99(e).

No. You cannot remove DOT-required placards simply by securing the area; placards must remain until the hazardous materials are sufficiently removed or the packaging is cleaned and purged so there is no potential hazard, per 1918.99(a) and (b).

• Securing the area or controlling access does not eliminate the underlying requirement to retain markings while hazards persist.
• Only after residues, vapors, or hazardous contents are removed or the package is cleaned/purged may you remove the markings/placards in accordance with 1918.99(a)–(b).

You must keep the DOT marking visible and legible while the hazard remains; if the original marking is illegible or damaged, you must replace or restore an equivalent DOT-compliant marking so the hazard remains clearly identified, consistent with 1918.99(a)–(c).

• Where practical, restore the original DOT marking or affix a clear replacement that conveys the same hazard information.
• For non-bulk packages that will not be reshipped, you may instead affix a label meeting 29 CFR 1910.1200 as allowed by 1918.99(d).
• Keep records of corrective actions (inspection, repair, replacement) as part of your safety practices.

Yes. If a package is subject to DOT marking/labeling and will be reshipped, you must retain the DOT-required markings until the package is cleaned and purged of residues and vapors to remove any potential hazards, per 1918.99(a).

• Do not substitute only an OSHA HazCom label when the package will be reshipped; the DOT marking required for transport must stay in place until hazards are removed.
• For non-bulk packages that will not be reshipped, see the alternative in 1918.99(d).

To meet 1918.99(c), keep markings, placards, and labels clean, unobstructed, legible, and located where workers normally view or handle the package or transport unit.

• Inspect markings regularly for dirt, fading, or physical damage and promptly clean, repair, or replace them.
• Position placards and labels on surfaces that are not blocked by cargo, tarps, or equipment during storage or handling.
• Use lighting or reflective materials as needed so markings remain visible in the workplace environment.
• See 1918.99(c) for the visibility requirement.

A [1910.1200]-compliant label is acceptable in place of DOT markings only for non-bulk packages that will not be reshipped, according to 1918.99(d).

• Confirm the package is non-bulk and will remain on-site or be used/disposed rather than sent through transportation that requires DOT markings.
• Affix a label that meets 29 CFR 1910.1200 requirements (product identifier, signal word, hazard statement, pictograms, precautionary measures, and manufacturer information where applicable).
• For bulk packages, transport units, or items that will be reshipped, retain the DOT markings until hazards are fully removed, per 1918.99(a)–(b).

Yes. Because this requirement is in Part 1918, it applies to maritime employers and shore-side operations covered by Part 1918; employers who receive hazardous material at marine terminals must comply with 1918.99.

• Marine terminal employers should ensure DOT markings and placards remain on packages and transport units until residues and vapors are removed or the hazardous materials are sufficiently removed, per 1918.99(a)–(b).
• Maintain visibility and legibility of markings as required by 1918.99(c).

No. Photographs or electronic records are useful supplements but do not replace the requirement to retain the physical DOT-required markings, labels, or placards on the package or transport unit while the hazards remain, under 1918.99(a)–(b).

• Physical markings must remain in place until the package is cleaned/purged or hazardous materials are sufficiently removed to prevent hazards.
• Photos may be kept for documentation (e.g., showing condition or replacement), but they do not satisfy the retention requirement for the physical marking itself.
• See 1918.99(a)–(b) for the retention obligations.

You must wait until the container has been sufficiently cleaned of residues and purged of vapors to remove any potential hazards before removing the placard or marking, per 1918.99(a)–(b).

• Even if the solid product is removed, residual residue or vapors can create hazards; the placard must remain until those risks are addressed.
• Use appropriate cleaning and purging procedures and verify through inspection or monitoring that hazards have been eliminated before removing markings.
• See 1918.99(a) and 1918.99(b).

The employer who receives the package or transport unit is responsible for retaining the DOT-required markings on the hazardous items or on the unit that requires placarding until the hazards are removed, under 1918.99(a)–(b).

• If the shipment includes a placarded transport unit (container, vehicle, rail car) the placards must remain on that unit until the hazardous materials are sufficiently removed, per 1918.99(b).
• For individual non-bulk packages that will not be reshipped, you may use a [1910.1200]-compliant label instead, as allowed by 1918.99(d).
• See 1918.99(a)–(d) for responsibilities.