Say HI to Proposed DOT Labels
All indications are that the HI system for identification of hazardous materials in transit will be adopted by the United States Department of Transportation to replace the old ICC labels and rule out any other identification method, such as the 704M system of the National Fire Protection Association.
An explanation of the HI system issued by the DOT for review by emergency response personnel states that the objective of the new marking system “is to provide a comprehensive and effective method of communication that will aid in the protection of the public as well as fire, law enforcement, and other emergency response personnel, when transportation incidents involving hazardous materials occur.” The DOT further states that “the HI system is designed to enable such personnel to quickly determine possible actions and precautions.”
The proposed system uses two-digit numbers on placards and labels. The first digit indicates the basic hazard and the second, except for explosives, will indicate additional hazards. If there is no additional hazard, the second digit will be a zero.
Card book planned
The DOT plans to publish a book that will key the hazard numbers to about 75 hazard information cards, one card for each HI number. The numbers will appear on labels and placards marked explosive, flammable, combustible, compressed gas, oxidizer, radioactive, corrosive or poison, which is all the information that will be immediately available to the viewer. The numbers also will appear on shipping papers.
To determine the exact nature of the hazardous material placarded, it will be necessary to look up the hazardous information card with the same two-digit number sis that on the placard. The material will not be identified, but its basic characteristics will be defined at the top of the card. Immediately below that will be the applicable fire, explosion and health hazards. In some cases, only one of these hazards will be noted because that is the only one applicable to the material, and for other materials, all three hazards will be described.
Under the heading, “Immediate Action Information,” will appear a more extensive description of action to take in the event of fire, spill or leak, or the need for first aid to victims.
Under this system, three additional hazards can be mentioned in combination with the basic hazard. If necessary, the DOT explains, “other hazards will be recognized by specific designation in the commodity list.”
Distribution of books
The HI card books will cover all regulated materials, and the books will be distributed free to organizations that make emergency responses. Others will be able to buy the card books, and the DOT hopes that organizations with members who use emergency response information will assist the DOT in making a wide distribution of the HI card books.
The proposed placards for trucks and railroad cars are in the shape of a diamond, 10½ inches on each side, although the final design of the placards has not yet been chose.
As an example of how the HI numbers would be determined, the HI number 30 would be assigned to gasoline because it is a flammable liquid without any additional hazards. Anhydrous ammonia, a compressed gas that is highly toxic, would get 24 as a HI number. The flammable liquid acrolein, which is also corrosive, highly toxic and thermally unstable, would take the HI number 37.
Reason for adoption
The DOT cites the following reasons for adopting the HI system:
“1. The system addresses itself to single and significant hazards based on specific definition criteria. It provides information on procedures and precautions to observe.
“2. The system may be carried out by preparation of approximately 75 hazard information and recommended action ‘cards.’
“3. The system permits easy communication to emergency personnel.
“4. Considering the complexity and scope of hazardous materials, the system is relatively simple and without great difficulty can be incorporated into the regulations.
“5. The HI markings, essential to the implementation of the system, may be used in conjunction with the new package labels proposed by DOT and new placards presently under development. Also, the 2 digit HI numbers on shipping papers, which will be necessary to tie the system together, will provide another means of verifying the nature of the shipment.”
Legal complexities are cited for DOT rejection of the NFPA 704M system for marking hazardous materials. It has been learned that DOT lawyers believe that it would be impractical to apply enforcement procedures to the 704M system because it is felt that it offers too many difficulties in the assignment of the numbers 0 to 4 for indicating the severity of the three hazards: health, flammability and reactivity. A fourth space in the “firemen’s diamond” could be used to indicate the possible hazard of using water or to denote radioactivity or other information. □ □