Since the advent of the Safety Data Sheet (SDS) – formerly known as the Material Safety Data Sheet (MSDS) – there has been some confusion regarding the use of and authorization of section 14 of the SDS, entitled: Transportation Information.  The name alone seems to indicate that the shipper of a hazardous material may rely on the information in section 14 when making their HazMat Classification.  It would also seem logical then that the person completing section 14 would require HazMat Employee training per 49 CFR 172, subpart H of the USDOT/PHMSA Hazardous Materials Regulations.  This however, is not the case.  See below for my reply to this FAQ.

• The SDS is a requirement of the Federal regulations of OSHA (Occupational Safety & Health Administration).
• Over the past several years OSHA worked with its counterparts in other countries to create a globally harmonized SDS. Therefore, the SDS represents a compromise between U.S. regulations and those of other countries.  Read: Learn more about the Global Harmonization System and revisions to OSHA’s HazCom standard.
• In some other countries (I don’t know which) all 16 sections of the SDS are authorized (i.e. the information contained in them must be correct and is subject to enforcement if incorrect).
• Neither OSHA, EPA, nor DOT has authorized sections 12 – 15 of the SDS. Therefore, to the best of my understanding (I am not an OSHA expert), the person providing the information for sections 12 – 15 is not subject to enforcement if the information is incorrect.
• DOT requires HazMat Employee training for any person whose job responsibilities directly affects the safe transportation of hazardous materials. This includes – but is not limited to – the classification of a hazardous material for transportation.  For more information view: Who or What is a HazMat Employee? And What Training is Required?
• Since section 14 of the SDS is not authorized by DOT, I don’t believe providing information for section 14 meets the definition of a HazMat Employee. Though, HazMat Employee training is good idea for any such person.
• Further, if a person performs a HazMat classification for their own purposes (shipping a HazMat), that activity meets the definition of a HazMat Employee and requires training.

Summary:

My recommendation is that anyone involved in the transportation of a hazardous material, including completion of section 14 of the SDS, receive HazMat Employee training every three years.