Well it finally happened………

A shipping line actually asked for a Safety Data Sheet for a CAR!

We see, on a continuous basis, operators requesting Safety Data Sheets (SDS) to check section 14 for transport purposes, each time we are asked, we ask why, to which we are told its needed to check the UN number, or its needed to check other items.

Due to this new process being seen by many lines, the movement of dangerous goods is becoming more problematic, here are a few actual examples:

UN3077, Environmentally Hazardous Substance, Solid, N.O.S.; being shipped in 4 x 3kg inner packages in a combination package – the airline refused them as non-hazardous for transport, because the SDS stated UN3077 in section 14. Special provision A197 was explained to them, however the operator maintained that they had to be shipped as full scope dangerous goods or they would not ship them.

UN3480, LITHIUM ION BATTERIES; the battery was placed in a phone, the shipper declared this correctly as UN3481, LITHIUM ION BATTERIES CONTAINED IN EQUIPMENT; the airline requested the SDS and stated it could not fly as the UN number on the SDS was not the same as the UN number on the shippers declaration, they asked the shipper to change the SDS. When the operator was quizzed on why they wanted an SDS, they confirmed that they needed to either identify the amount of lithium content in grams or the watt hour capacity, it must be noted that neither of these items are required on an SDS.

And the final example:

UN3269, POLYESTER RESIN KIT, which contain a flammable resin and a very small amount of organic peroxide used as the hardener; the shipping line asked for the SDS for both components, on receipt of this they entered the two UN numbers into their system, and then refused to ship them as they required segregation.

These issues are solely from asking for an SDS, or more importantly not understanding what is contained in an SDS or what it is for.

There are more than 30 classifications in GHS, which have not been adopted by all countries and regions, for the movement of dangerous goods there are in general 9 classes, many of the GHS classifications are not then classified for transport purposes.

I know the CAA have asked for SDS information to be provided in DG training schemes, and many operators have stated that it says in the IATA Dangerous Goods Regulations to request an SDS.

No, it does not, Appendix B4, gives an overview of GHS and the pictograms that are used in its application, GHS itself is implemented differently in different countries and regions around the world. The GHS transport elements are implemented using the UN Model Regulations, which then flows down into the various dangerous goods regulations which are implemented internationally.

Again, in ADR, 49 CFR, IMDG or any other International dangerous goods regulations, it does not state that an SDS is needed.

So, what is an SDS and when is it needed:

The UK HSE describes them as:
Safety data sheets provide information on chemical products that help users of those chemicals to make a risk assessment. They describe the hazards the chemical presents, and give information on handling, storage and emergency measures in case of accident.

OSHA describe them as:
The Hazard Communication Standard (29 CFR), requires that the chemical manufacturer, distributor, or importer provide Safety Data Sheets for each hazardous chemical to downstream users to communicate information on their hazards.

The key word in these descriptions is the word USER.
An SDS is required to be provided to the user prior to the first time they receive it, its not required with every delivery and is to be provided free of charge by the person placing it on the market for its use.

The SDS is then consulted by the user to understand the hazards and complete a sufficient assessment of the risks during its use.

SDS are also required for third part operators who are to store the products long term, this does not include temporary storage or transhipment of dangerous goods seen in normal transport operations.

Section 14 of the SDS provides basic transport information only, it does not take into account the quantity being shipped, or how it is being shipped, it does not take into account any of the exemptions or special provisions relating to its transportation.

It must be noted that under the 29 CFR Section 14 is not mandatory, because the information is for the person using the product and not for when it is being transported, I would agree they have this right, the SDS is nothing to do with transport.

The safe transportation, including how goods are classified for transport, packaged, marked and labelled and consigned, including any exemptions or special provisions and emergency measures to be taken during transport are dealt with by the appropriate dangerous goods codes and regulations that have been successfully used for many years, before the phenomenon of requesting SDS.

A plea for industry

Can we please stop complicating the movement of dangerous goods by asking for a document that is nothing to do with the transportation of those goods?

Shippers and consignors have the obligation to classify, identify and consign their products in accordance with the dangerous goods regulations for the relevant mode of transport being used.

Please, please, please, other than for Ethiopia (their reason is still unclear), stop asking for SDS for transport purposes and save our sanity.

SDS Request for Transport Purposes

Llewellyn Europe