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.
The Global Harmonization System (GHS) is a product of the United Nations that embodies an international approach to hazard communication using an agreed upon criteria for classifying hazardous chemicals and a standardized method to communicate the hazards through use of container labels and Safety Data Sheets (SDS).
The Occupational Health and Safety Administration (OSHA) within the U.S. Bureau of Labor has adopted most – not all – of the provisions of the GHS within its hazard communication regulations (aka: HazCom Standard). They are found in Title 29 of the Code of Federal Regulations 1910.1200.
Appendix D to 29 CFR 1910.1200 indicates the required (and suggested) information to include in the SDS and the format. Sections 1-11 and 16 are required, sections 12-15 may be included but are not required.
- Section 1—Identification: Product identifier, manufacturer or distributor name, address, phone number, emergency phone number, recommended use, and restrictions on use.
- Section 2—Hazard(s) identification: All hazards regarding the chemical and required label elements.
- Section 3—Composition/Information on ingredients: Information on chemical ingredients and trade secret claims.
- Section 4—First-aid measures: Required first aid treatment for exposure to a chemical and the symptoms (immediate or delayed) of exposure.
- Section 5—Fire-fighting measures: The techniques and equipment recommended for extinguishing a fire involving the chemical and hazards that may be created during combustion.
- Section 6—Accidental release measures: Steps to take in the event of a spill or release involving the chemical. Includes: emergency procedures, protective equipment and proper methods of containment and cleanup.
- Section 7—Handling and storage: Precautions for safe handling and storage, including incompatibilities.
- Section 8—Exposure controls/Personal protection: OSHA’s permissible exposure limits (PELs), threshold limit values (TLVs), appropriate engineering controls, and personal protective equipment (PPE).
- Section 9—Physical and chemical properties: The chemical’s characteristics.
- Section 10—Stability and reactivity: Chemical stability and possible hazardous reactions.
- Section 11—Toxicological information: Routes of exposure (inhalation, ingestion, or absorption contact), symptoms, acute and chronic effects, and numerical measures of toxicity.
- Section 12—Ecological information: How the chemical might affect the environment and the duration of the effect.
- Section 13—Disposal considerations—describes safe handling of wastes and methods of disposal, including the disposal of any contaminated packaging.
- Section 14—Transportation information—includes packing, marking, and labeling requirements for hazardous chemical shipments.
- Section 15—Regulatory information—indicates regulations that apply to chemical.
- Section 16—Other information—includes date of preparation or last revision.
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Many times when classifying a hazardous material for transportation a shipper may rely upon Section 14 of the Safety Data Sheet (SDS), (formerly the Material Safety Data Sheet or MSDS), for classification information. After all, it’s entitled “Transport Information” and frequently contains classification information pertaining to all transportation regulatory agencies:
- The Pipeline and Hazardous Materials Safety Administration (PHMSA) within the U.S. Department of Transportation (USDOT).
- The International Air Transport Association (IATA).
- The International Maritime Organization (IMO).
But is it correct? Can you rely on the information it contains for your HazMat classification? The answer: maybe. (more…)
Summary: