Do you need a SDS with your dangerous goods shipment?
Q: Does each shipment of dangerous goods require its own SDS?
A: The SDS (MSDS) is NOT a shipping document. It is not required by any government agency or IATA as a shipping document. The primary purpose is that it MAY BE used in the shipping process to provide written emergency response information (required by the US DOT in case of fires, spills/leaks, first aid, etc.). However, there are other documents that can fulfill this requirement (i.e., Emergency Response Guide, etc.).
Q: Do we have to include an SDS in the shipment package?
A: The SDS does NOT have to be included in the package or with the shipment at all – unless used for the purpose of providing written emergency response information (see next question).
Q: What is the primary use of the SDS in shipping dangerous goods?
A: IF it is used as written emergency response information to satisfy shipments to, from or through the US, then it should be attached to the shipping paper (DGD, shipper’s declaration, transport document, etc.) presented to the carrier. Note, the carrier may decline accepting the SDS attached to the shipping document if they feel such information is already easily available during transport – such as found in the North American Emergency Response Guidebook – which many carriers keep at every facility and with every delivery vehicle.
Q: We have the old MSDS but do not have the GHS standard SDS – is this still valid?
A: For DG shippers, the primary use of the SDS/MSDS is to determine whether or not the chemical is regulated for transport or not. Generally, in the old MSDS and in the new SDS, this information can be found in Section 14, entitled, “Transportation.” As long as the information is accurate, either format should fulfill this purpose.
Q: What does our company have to do to comply with the GHS program?
A: Although OSHA has adopted many of the GHS initiatives for workplace safety, etc., it is still NON-COMPULSORY for individual governments to adopt. However, the US has adopted many portions of this program which are enforced through OSHA mandates. Companies that work with hazardous chemicals must be properly trained under OSHA standards. Transportation Development Group (TDG) does not offer training in this area as we specialize in DOT required training for SHIPPING hazardous materials (dangerous goods).
In summary, the purpose of the SDS is to provide a harmonized document around the world in a standard format to identify dangerous chemicals. Section 14 is entitled “Transportation,” and it is this section that MAY be used by shippers in order to identify and classify dangerous goods shipments. This section typically provides the UN Number, Proper Shipping Name, Hazard Class or Division and Packing Group (PG), if applicable. Many chemicals are not hazardous for transportation purposes and Section 14 commonly reflects, “Not regulated for transport,” to confirm this.