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Bulk vs. Non-Bulk Packaging

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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.

Legal Definitions

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:

  • Any packaging (excluding vessels or barges but including Large Packagings, freight containers, and transport vehicles) in which hazardous materials are loaded with “no intermediate form of containment” (e.g., additional inner packaging or containers)
  • For packaging carrying liquids: A maximum capacity exceeding 450 L (118.87 U.S. gallons)
  • For packaging carrying solids: A maximum net mass exceeding 400 kg (881.85 lbs) and a maximum capacity exceeding 450 L (118.87 U.S. gallons)
  • For packaging carrying gases: A maximum water capacity exceeding 454 kg (1,000 lbs)

49 CFR also defines packaging and large packaging as follows:

  • Packaging: “A receptacle and any other components or materials necessary for the receptacle to perform its containment function.”
  • Large Packaging: A packaging consisting of an outer element that contains inner packaging or articles, designed for mechanical handling, exceeds 400 kg of net mass or 450 L of capacity, and with a volume not exceeding 3 cubic meters (106 ft³).

Non-bulk packaging is a packaging that meets the following criteria:

  • For packaging carrying liquids: A maximum capacity of 450 L (118.87 U.S. gallons) or less
  • For packaging carrying solids: A maximum net mass of 400 kg (881.85 lbs) or less and a maximum capacity of 450 L (118.87 U.S. gallons) or less
  • For packaging carrying gases: A maximum water capacity of 454 kg (1,000 lbs) or less

Several IBC tanks stacked on each other

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Container examples

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:

  • As IBCs, they can be used to transport liquid hazardous materials
  • They are single units; they do not contain smaller containers or inner receptacles
  • 275 U.S. gallons equals approximately 1,041 liters, exceeding the maximum capacity of a non-bulk container

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.

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Vehicles and containers as bulk packaging

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:

  • Cars
  • Trucks
  • Semi-trailers
  • Tractors
  • Tank cars and rail car

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.

Labeling and Marking Hazardous Materials

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.”

an array of transport hazard pictograms

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How to Label Hazardous Materials

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:

  • Class 1: Explosives
    • Class 1.1: Mass explosion risk (e.g., TNT, dynamite, nitroglycerine)
    • Class 1.2: Blast and projection risk (e.g., hand grenades, detonating fuzes)
    • Class 1.3: Minor blast risk (e.g., commercial-grade fireworks)
    • Class 1.4: Major fire risk (e.g., small arms ammunition)
    • Class 1.5: Blasting agents
    • Class 1.6: Insensitive explosives
  • Class 2: Gases
    • Class 2.1: Flammable gases (e.g., propane, acetylene)
    • Class 2.2: Non-flammable gases (green placard) or Oxygen (yellow placard)
    • Class 2.3: Inhalation hazard
  • Class 3: Flammable liquids
    • Alternative placards include Combustible, Fuel Oil, or Gasoline.
  • Class 4: Flammable solids
    • Class 4.1: Flammable solids (generic)
    • Class 4.2: Spontaneously combustible solids (e.g., pyrophoric materials)
    • Class 4.3: Dangerous When Wet (e.g., calcium carbide)
  • Class 5: Oxidizers and organic peroxides
    • Class 5.1: Oxidizing agents
    • Class 5.2: Organic peroxide oxidizing agents
  • Class 6: Poisons, toxic, and infectious substances
    • Class 6.1: Poisons (e.g., methyl bromide, tear gas, cyanides)
    • Class 6.2: Biohazards (e.g., bacteria, viruses, fungi, medical waste)
    • Class 6.3: Packing Group III
  • Class 7: Radioactive substances
  • Class 8: Corrosive substances
  • Class 9: Miscellaneous hazardous materials

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How to Mark Hazardous Materials Containers

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.

Non-bulk packaging markings

On non-bulk hazmat packaging, the markings must feature the following information:

  • A proper shipping name and identification number written in English
    • The text used must feature a minimum height of 12 mm (0.47”) and be preceded with a UN, NA, or ID code, as appropriate.
  • A technical name (except in the case of Class 6.2 substances)
  • If applicable, special permit information, including the DOT-SP code and the special permit number.
    • For permits approved before October 1, 2007, the preceding code may be DOT-E instead.
  • If applicable, the consignor’s or consignee’s name and address (unless the package will be transported by a single vehicle on highways only or if part of a car, truck, rail car, or container load)
  • For containers used to transport non-odorized LPG, the container must possess a legible marking that reads either “NON-ODORIZED” or “NOT ODORIZED.” These markings must be written in text with a minimum height of 6.3 mm (0.25”).

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:

  • Any package with a maximum capacity of 30 L (7.93 U.S. gallons) or less
  • Any package with a maximum net mass of 30 kg (66 lbs) or less
  • Any cylinder with a maximum water capacity of 60 L (18.85 U.S. gallons) or less

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 packaging markings

Bulk hazmat packaging must feature markings with the following information and criteria:

  • Clearly legible proper shipping name and identification number on multiple sides, according to the following criteria:
    • If the packaging’s total capacity is 1,000 U.S. gallons (3785.41 L) or more, the identification numbers must be marked on each side and each end.
    • If the packaging’s total capacity is less than 1,000 U.S. gallons, the identification numbers must be marked on two opposing sides.
    • If the packaging is a permanently installed cylinder (e.g., tube trailer), the identification numbers must be marked on each side and end of the host vehicle.
  • Marking sizes must meet specific legal minimums, depending on the container type:
    • Rail cars: Minimum 100 mm (3.9”) tall and 6 mm (0.24”) wide
    • Portable tanks with a capacity of less than 1,000 U.S. gallons: Minimum 12 mm (0.47”) tall and 4 mm (0.16” wide)
    • IBCs: Minimum 25 mm (1”) tall and 4 mm wide (0.16”)
    • All other bulk containers: Minimum 50 mm (2”) tall and 6 mm wide (0.24”)
  • If applicable, special permit information, including the DOT-SP code and the special permit number.
    • For permits approved before October 1, 2007, the preceding code may be DOT-E instead.

All bulk containers must remain marked as initially required, even after emptying, except in the following cases:

  • The container has been sufficiently cleaned and disinfected, and all gases and vapors were eliminated to remove all potential hazards.
  • The container has been refilled with different materials requiring different markings (or none, if applicable) to the point any dangerous residues have been removed or are no longer hazardous.

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.

Air Sea Containers, Your Packaging Partner

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.


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