Fact or Fiction: SDS are required for all HazMat/DG Including Vehicles, Air Bags, Batteries, Lithium Batteries and “manufactured articles.”.
Under OSHA regulations, SDS are not required for “manufactured articles.” There are interpretation letters https://lnkd.in/gcMV32rr you can point to for that as well as the text of the OSHA regs https://lnkd.in/gV9hW2eH (b) (6)(v). The ECFR doesn’t link very well for this but here’s a definition (c) “Article means a manufactured item other than a fluid or particle.”
So today I ran into a support issue where a client was getting a lithium battery shipment rejected going to Hong Kong because the SDS said “65th Edition of IATA” instead of “66th Edition.” This comes back to what Paul Horner and Geoff Leach and others have been talking about—rejections that may or may not impact safety.
In this case, there does not even seem to be any requirement on which to base this rejection in the first place. So tell me if I’m wrong:
(1) ICAO/IATA doesn’t require an SDS for manufactured articles in the first place. (they can of course request independent validation of anything they want, but as a matter of course…. SDS aren’t specifically required)
(2) Carriers can file a variation to demand one, but I see no such variation for HKG or the carriers.
(3) While emergency response information (i.e. US DOT requirement for written Emergency Info) CAN be fulfilled by an SDS, it doesn’t mandate one.
The UN “Purple Book” GHS book is less clear about articles, but I don’t see anything in there that would require an SDS for an airbag, truck, or motorcycle, car battery or anything like a consumer type of manufacturered article. Am I mistaken on that?
My advice to the client was to get it in writing from the carrier — where does it say an SDS is required by IATA for lithium batteries? I noticed that some carrier variations said an SDS was needed for “all DG” and a couple mentioned lithium batteries but that’s the exception.
Do you agree? Thanks!
Jim
Offer the carrier a lithium battery test summary report if they insist on a written document vouching for the batteries. WE ALL KNOW the lithium battery test summary report is not a transport document. And it’s not really part of IATA per se, it’s part of the UN Manual of Test and Criteria.