A recent customer of my Onsite HazMat Employee training followed-up with a question (08.15.17):
Hello Daniel,
Thank you again for your training last week. It was very informative.
We have a question regarding shipping between US and Canada, along with questions of how the customer would ship this material once in Canada. The safety data sheets (SDSs) are different between the US and Canada. This is making the Canadian distributor hold our shipment before receiving. Do we need to mark these shipments in accordance to the Canada SDS or the US SDS? Also, if we mark them according to the US SDS, does the distributor have to change the markings in order to ship within Canada? Thank you in advance for your assistance.
Best Regards,
SEVERAL SAFETY DATA SHEETS (SDS) WERE ATTACHED TO THE EMAIL
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Daniels Training Services, Inc. 815.821.1550 |
I held him off for a little bit:
I will be able to reply later this evening.
And I did reply that night after reviewing the SDS he had provided (08.15.17):
I will try to answer your questions below.
- I cannot answer questions about the SDS with great confidence as it is a requirement of OSHA regulations with which I am not experienced.
- However, under the new OSHA HazCom Standard as revised by OSHA’s adoption of the Global Harmonization System (GHS) an SDS should be the same throughout the world. I have no explanation why section 2 of the SDS for Part A differs between the U.S. version and the Canadian. It must be an error as it should be the same in both.
- Section 14 appears to be incomplete in all four SDS. It does not include a basic description for the HazMat under IATA or IMDG.
- As addressed in my training, the U.S. and Canada have a reciprocal agreement for the transport of HazMat / Dangerous Goods between the two countries by highway or rail. Read: The Transport of HazMat Between the U.S. and Canada.
- Based on the information provided it appears that all of the materials are a Class 3 Flammable Liquid and the best shipping description is: UN1133, Adhesives, 3, Packing Group II (or PG I. It depends on the initial boiling point and that data isn’t available on the SDS.)
- The above shipping description should suffice in both U.S. and Canada.
I hope this helps. Please don’t hesitate to contact me with any questions.
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Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail International and Domestic Daniels Training Services, Inc. 815.821.1550 |
The next day he had another question:
Hello Daniel,
They are also claiming that, due to the flash point, we can’t ship limited 
quantity. In your opinion is this the case?
And I had a quick answer ready for him:
They are incorrect. A Class 3 Flammable Liquid adhesive can be shipped as a limited quantity no matter the flash point. There are limits on the net quantity of the HazMat in the package based on the Packing Group which is determined, in part, on the HazMat’s flash point. The limited quantity exception also has a limit on the gross weight of the package for all HazMat no matter the Packing Group.
Conclusion:
Here is a perfect example of a shipper relying on information provided by someone else to comply with the USDOT/PHMSA Hazardous Materials Regulations (HMR) for the transport in commerce of hazardous materials. As the shipper of HazMat you must do everything you can to ensure the HazMat is transported safely. One way to do this is training: USDOT HazMat Employee, IATA for shippers and packers of dangerous goods by air, and IMO for shore-based personnel shipping dangerous goods by vessel.