Numerous laws and regulations govern what you can and can’t do when packaging and shipping hazardous materials (hazmat). While there is no shortage of packaging options, the law only recognizes two types of hazmat packaging: Bulk and non-bulk.
If you’re looking to ship hazardous materials, it is essential to know the legal distinctions between bulk and non-bulk and what packaging options these definitions include.
The Pipeline and Hazardous Materials Safety Administration (PHMSA), an agency of the U.S. Department of Transportation (USDOT), outlines the definition of bulk packaging and non-bulk packaging in the context of hazardous materials in the Hazardous Materials Regulation (HMR) document. These definitions are part of U.S. law, under the Code of Federal Regulations article 49 CFR 171.8 .
Under the legal definition, bulk packaging has the following characteristics:
49 CFR also defines packaging and large packaging as follows:
Non-bulk packaging is a packaging that meets the following criteria:
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For example, 275 gallon totes for sale are a type of Intermediate Bulk Container (IBC) intended to transport liquids; they meet the definition of bulk packaging due to the following criteria:
In contrast, standard hazmat boxes , such as 4GV boxes , do not meet the definition of bulk packaging because their maximum capacities are far below the legal limit for non-bulk packaging, regardless of their dimensions. For instance, one of the largest available sizes, the 4GV/X40 box (dimensions: 16”x16”x16”), only has a maximum carrying capacity of 40 kg.
Other examples of bulk packaging include cargo tank trailers, specific types of trailer steel tanks, and non-standard IBCs (as long as their capacity meets the bulk packaging definition).
Non-bulk packaging examples include standard 55-gallon drums, cans, cylinders, corrugated boxes, and most custom shipping boxes .
The USDOT regulates and enforces the Hazardous Materials Regulations, which means that specific vehicle types may be designated as bulk containers for transporting hazardous materials.
The law outlines transport vehicles and freight containers as bulk containers if they meet the maximum capacity definitions and if the hazardous materials are not transported into smaller, dedicated containers. In other words, the vehicle or container may be considered a single bulk packaging container if the only layer of protection between the hazardous material and the environment is the vehicle or container’s body.
A transport vehicle may be any of the following:
The HMR explicitly excludes barges and vessels because they are watercraft. The rules surrounding the transportation of hazardous materials on watercraft are enforced by the U.S. Coast Guard’s Hazardous Materials Division (CG-ENG-5) instead of the USDOT.
The law defines freight containers as reusable containers with an interior volume of 64 ft³ or more, designed primarily for transporting and containing packages and keeping them intact during lifting or transportation.
For example, an ISO standard 40-ft intermodal container (40’ long, 8’ wide, 8’6” tall), such as those used on cargo ships and transported by semi-trailer trucks, features an internal volume of 2,385 ft³ and supports a maximum net load of 26,680 kg. So, it falls within the legal definitions of bulk packaging and freight containers.
Although the USDOT guidelines outlining how to label and mark hazmat bulk containers properly may seem similar at first glance, they are not identical. Labels are not the same as Markings, and the labeling and marking rules are different between bulk and non-bulk containers.
The term Labels and Labeling refer to the use and application of standard USDOT Hazmat labels. The diamond-shaped, colored placards indicate what type of hazard the materials inside the container may pose. They may be printed or painted directly on the packaging or be external placards (stickers, metal signs, etc.) intended to be permanently affixed to the packaging.
In contrast, the term Marking is specifically defined in 49 CFR. A Marking is a specific set of information describing the materials inside the packaging, typically printed, painted, or permanently inscribed on the sides of the container. The law describes a marking as a “descriptive name, identification number, instructions, cautions, weight, specifications, or UN marks, or combinations thereof.”
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Hazardous material labels are divided into nine classes, most of which possess their own sets of subdivisions. Regardless of the materials transported, all containers must include a label on at least one side, either on the overpack or visible through it. The label must be clearly visible and not require opening or manipulating the packaging to read.
Which labels you apply depends on the type of hazardous materials carried in each container. Although it is not expressly forbidden to transport multiple types of hazardous materials in the same container (and apply multiple corresponding labels on each packaging), you must follow the hazmat segregation table and avoid transporting incompatible materials together.
The hazmat label classes are as follows:
Bulk and non-bulk hazmat packaging marking requirements differ slightly from each other. 49 CFR dedicates a section for each type: 172.301 for non-bulk packaging and 172.302 for bulk packaging.
Regardless of the packaging type, all markings must be written in English and inscribed in a durable manner (printed or affixed to the package and protected from the elements).
To maximize readability, they must also be displayed away from other markings (e.g., advertising, branding) on a sharply contrasting background, and labels must not obscure them or render them unreadable.
On non-bulk hazmat packaging, the markings must feature the following information:
Your package’s proper shipping name and ID number may employ 6 mm (0.24”) text instead of 12 mm if the packaging meets the following criteria:
Small packages (maximum capacity 5 L/1.32 gallons or maximum net mass 5 kg/11 lbs) can use any text size as long as it is legible and appropriate for the package’s size.
It is legal to reuse containers with previous markings, provided the contents are the same and the markings remain legible.
Bulk hazmat packaging must feature markings with the following information and criteria:
All bulk containers must remain marked as initially required, even after emptying, except in the following cases:
Specific types of bulk containers (including portable, cargo, tank cars, and multi-unit tanks for tank cars) may be subjected to additional rules and requirements. Refer to the regulations outlined in 49 CFR 172.326, 172.328, 172.330, and 172.331 for more information.
Packaging and shipping hazardous materials require a keen knowledge and familiarity with all relevant laws and regulations. Knowing the difference between bulk and non-bulk hazmat packaging is critical, as the rules vary significantly between both types, and finding the right containers can be rather challenging.
At Air Sea Containers, we aim to make hazardous materials logistics as easy as possible. We offer a complete suite of UN-approved, hazmat-rated containers compliant with all relevant laws and regulations. Our selection includes 4GV boxes, jerricans, pails, infectious substance containers, shipping barrels, IBCs, and more.
