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I bought a label printer, and it prints, but it doesn’t print labels.  Oh, I do take what it prints out, peel it off the backing, and stick the adhesive side onto my box, but it’s still not a label.  It’s just a sticker, a sticker with markings on it.

Long ago I learned the transport regulations aren’t written in English.  Oh sure, you can find the words in an English dictionary, but the regulations seem to be written in Bureaucratish or Legalese or Regulatory Speak.  So, when I discovered that printing my ID number and Proper Shipping Name with my label printer wasn’t actually labeling, I wasn’t too surprised.  I just adopted the idea that regulatory labels are the diamond-shaped warnings of the general category(ies) of hazard within the package.  I had my English labels, anything that I peel off and stick on, versus my regulatory labels, with symbols and colors and hazard class numbers.  Stickers aren’t necessarily labels.  Got it.

Then I learned more, and it wasn’t pleasant.  I watched someone prepare a US ground DG (HazMat) shipment of fairly large bottles of a liquid Limited Quantity (LQ, Ltd Qty).  When he had finished, I asked why he hadn’t added orientation arrows to the box?  Proving that my training hadn’t been a total waste of time, he showed me a 49CFR reference that excepted LQ ground shipments from labeling.  When I explained that not all stickers are labels, and that orientation arrows aren’t labels, he said “Oh, yes they are”.  And then he grabbed his A.I.R. Shipper (ICAO, IATA) book and showed me the handling labels!  Sure enough, as I already knew but hadn’t really thought about, orientation arrows are labels.  But, of course, they’re not.  The 49CFR doesn’t define them as labels, but as marks or markings.

Obviously, the packer and I soon cleared up which set of regulations applied to the US ground shipment.  And we agreed that orientation arrows both are and are not labels.

But now I am left to ponder that accuracy of some of my other statements to many training classes, that ‘transportation regulations are almost completely harmonized’ and that workplace safety regulations are ‘still working to catch up to transport regulations as far as harmonization is concerned’.  Which brings up a whole new perspective on labels, as transport regulations don’t really consider workplace safety (CLP, OSHA, etc.) labels to be labels either.  So, again, there’s a situation where an adhesive-backed sticker is a label and is also not a label.

Does it matter?  Does anyone care?  I know we don’t placard airplanes, but the road journey to the airport before the shipment and from the airport after the shipment may be subject to placarding requirements.  In some regulations, placarding requirements are triggered by the quantities of labeled DG on the vehicle, but markings are irrelevant.  In some regulations, separation and segregation requirements only apply to DG packages bearing labels.  So, for placarding and for separation/segregation, knowing what a label is, is important.

The UN Subcommittee will be indirectly taking up this issue soon.  Currently, a lithium battery handling sticker might be considered a mark or a label, depending upon which transport regulations are being used.  Currently, a dead-tree-and-dead-fish sticker is definitely a mark, and a Class 9 hazard label is definitely a label.  But, there is a proposal to incorporate the lithium battery mark onto a Class 9 label, and separately to incorporate the dead-tree-and-dead-fish onto another Class 9 label.  If a mark is added to a label, is it both a mark and a label, or just a different label?  Maybe if this is adopted, there will be a ‘no strong magnets’ mark incorporated onto a Class 9 label for air`, a ‘keep away from heat’ shade symbol added into 4.1 and 5.2 labels, and a ‘cryogenic’ Dewar stenciled into 2.2 labels, too.  Certainly, it would save space on boxes.

So, labels aren’t always labels unless they are labels, or something like that.  It makes my head hurt to try to understand that.  What I do know about “labels” is, I have to be very careful about how the word “label” is used, and what the context is.  Because, much like the packer of the US ground LQ shipment, if I’m not careful about when a label isn’t a label, I could end up non-compliant.

Written 5/2/2014 for HCB Magazine