DOT markings retention requirements

Under 1926.61, follow the same retention rules that apply in general industry as set out in 1910.1201. The text of 1926.61 explicitly states that the requirements applicable to construction work are identical to those in 1910.1201. For any practical question about how long to keep markings or how to handle damaged labels, consult 1910.1201 because it contains the operative retention and handling provisions.

Under 1926.61, the retention requirement covers DOT markings, placards, and labels on containers, vehicles, or equipment that indicate hazardous materials—i.e., the same items covered under 1910.1201. In practice, that means keep the hazardous-material labels, placards, and markings that communicate the presence and identity of hazardous chemicals until the conditions described in 1910.1201 allow removal or replacement.

Under 1926.61, the employer is responsible for ensuring DOT markings, placards, and labels are retained and remain legible in accordance with the identical requirements in 1910.1201. Employers must implement the practices and procedures called for in 1910.1201 to make sure markings are not obscured, damaged, or removed prematurely and that employees can see and use hazard information.

Under 1926.61, DOT labels or placards may only be removed when the conditions and timing for removal set forth in 1910.1201 are met. That means you must follow the removal, decontamination, or re‑labeling rules in 1910.1201 and any applicable DOT regulations before taking markings off a container or vehicle.

Under 1926.61, if a DOT placard or label becomes torn, faded, or illegible, you must replace or restore it so that the hazard information remains visible and understandable, following the same requirements in 1910.1201. Employers should have procedures to inspect markings periodically and promptly replace damaged or unreadable labels and placards as required by 1910.1201.

Under 1926.61, temporary coverings or wraps must not defeat the purpose of DOT markings; the same limitation applies as in 1910.1201. If a temporary covering obscures required hazard information, employers must ensure employees who need the information still have access to it (for example by using alternative labels or ensuring coverings are removed when the container is handled), consistent with the requirements in 1910.1201.

Under 1926.61, employers must meet whatever recordkeeping or documentation requirements are specified in the identical 1910.1201. If 1910.1201 or related OSHA/DOT provisions require documentation of inspections, replacements, or retention periods, those records must be maintained as described in 1910.1201.

Under 1926.61, the treatment of empty containers—including when markings may be removed—follows the rules in 1910.1201. If 1910.1201 or applicable DOT rules require a container to remain labeled until it is cleaned or decontaminated, employers must retain the markings until those conditions are satisfied.

Under 1926.61, when hazardous material is transferred to a new container, you must label and retain DOT markings on the new container as required by 1910.1201. The same responsibilities apply: the new container must bear the required markings or labels, and the employer must follow the retention and application rules in 1910.1201 so that hazard communication remains continuous.

Under 1926.61, each employer—including subcontractors—must meet the retention and labeling requirements applicable to the materials they control, consistent with 1910.1201. If a subcontractor brings hazardous materials or takes custody of containers, they are responsible for ensuring the DOT markings and labels remain in place and legible while they control those items, and for coordinating with the prime contractor as necessary under 1910.1201.

Under 1926.61, there is no separate set of retention rules for drums, cylinders, tanks, or transport vehicles in construction—they are governed by the same retention requirements found in 1910.1201. Employers should apply the labeling and retention practices in 1910.1201 consistently across container types so hazard information remains available whenever materials are present on the site.

Under 1926.61, deliberately removing DOT markings before the conditions for removal in 1910.1201 are met would violate the retention requirements; the employer must restore the required markings and correct the condition in accordance with 1910.1201. Employers should have procedures to prevent unauthorized removal and to promptly remedy any deficiency to ensure compliance with 1910.1201.

Under 1926.61, employers must meet the training and information obligations that accompany the retention and hazard communication provisions in 1910.1201. That means employers should train employees who handle or work near hazardous materials so they understand the meaning of DOT markings, how retention works, and what to do if markings are missing or damaged, consistent with 1910.1201.

Under 1926.61, the frequency and methods for inspecting DOT markings and placards should follow the practices required or recommended in 1910.1201. Employers should establish inspection intervals adequate to ensure markings remain legible and intact during use—routine inspections and checks after handling or weather exposure are common approaches consistent with the expectations of 1910.1201.

Under 1926.61, any alternative labeling or marking must meet the same retention and hazard‑communication objectives set out in 1910.1201. If an employer proposes an alternative marking system, it must provide equivalent information and be maintained in the same way required by 1910.1201; otherwise, the standard's requirements for DOT markings, placards, and labels apply.

Under 1926.61, OSHA's retention requirement for DOT markings refers you to the same rules in 1910.1201, but employers must also comply with applicable DOT regulations when materials are being transported. In other words, follow 1910.1201 for OSHA retention obligations on site and ensure those practices are consistent with DOT requirements while the material is in transit.

Under 1926.61, start by reviewing the retention and labeling provisions in 1910.1201 because the construction rule is identical to that standard. For complex or site‑specific questions, consider consulting OSHA regional offices or submitting a written request for an interpretation; in all cases, follow the requirements and practices described in 1910.1201 while you seek clarification.