The 2MM Inner Border was Repealed, but What About Other Requirements?

Brooklyn Summerville, August , 2018

“2 mm inner border,” is the minimum width requirement that caused a whirlwind of interpretation, setting into motion rejected compliant packages for many.

The Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) outlined the requirements for DOT label specifications. The requirements included:

  1. Each diamond (square-on-point) label prescribed in the HMR must be at least 100 mm (3.9 inches) on each side with each side having a solid line inner border 5 mm inside and parallel to the edge.
  2. The 5 mm measurement is from the outside edge of the label to the outside of the solid line forming the inner border
  3. The width of the solid line forming the inner border must be at least 2 mm.

The deadline to meet these requirements, after an extension was set, was December 31st, 2018. The third requirement of a “2 mm inner border” was then lifted after the Pipeline and Hazardous Materials Safety Administration (PHMSA), posted a letter of interpretation. The letter of interpretation was posted after several shipments had been declined, and industry associates argued this border width did not affect the safety of a shipment.

The International Civil Aviation Organization (ICAO) removed the requirement from the ICAO Technical Instructions 2019-2020 edition and PHMSA followed suit letting hazardous shippers un-regulate the border width. However, PHMSA will meet in late 2018 to discuss this regulation and adoption of new and updated regulations.

Reliance knows ensuring your labels comply to the latest industry regulations is vital to a hazardous shipper’s business. If you have questions about whether your current stock is in compliance or want to learn more about how to comply, contact Reliance at 800-656-9476 or email us at