TT Talk - Classification and safety data sheets
Using the appropriate modal regulations or convention, the shipper/consignor is responsible for correctly classifying any item that is to be transported. In many instances, reliance has to be placed on the manufacturer to provide reliable data so that the carrier is adequately alerted and may respond appropriately in an emergency.
One of the primary requirements of the documentation for all goods, and particularly those classified as dangerous, is to convey fundamental information regarding the hazards of the goods being carried to all stakeholders in the supply chain, including emergency responders if need be.
The road to harmonisation
Seeking consistency between different regulatory systems (use or transport), the United Nations developed a system for the harmonisation of hazard classification criteria and communication of this information. This is called the Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The GHS addresses classification of chemicals by type of hazard and enables consistent communication, including labels and safety data sheets.
However, recognising that the information requirements differ amongst the stakeholders – beyond the various modes of transport – rather than producing multiple hazard documents, a single ‘all encompassing’ document was devised. Originally these were referred to as Material Safety Data Sheets or MSDS, but now this has been shortened to SDS.
“It should be checked that the description of the product in the SDS agrees with the transport information given”
Because these SDS documents are primarily required between supplier and recipient, they may include information relevant to certain stakeholders and not to others. By standardising the format of the document, it makes assessment easier — SDS now have a standard 16-section format in most jurisdictions. It is also important to note that SDS are intended to apply to the product being used within a supply chain. Thus, the shoreside industry product description may differ from the Proper Shipping Name used in transport. Nevertheless, it should be checked that the description of the product in Section 1 of the SDS agrees with the transport information given in Section 14. For example, where shipping ‘ground cinnamon’ (not dangerous goods) the SDS should not be for ‘cinnamon bark essential oil’ (UN2810 TOXIC LIQUID, ORGANIC, N.O.S.).
The freight supply chain
Containerised goods are often driven on roads, moved on rail and inland waterways, then transferred to ships, so the SDS is expected to contain information on the transport controls for all modes.
Those involved in the maritime mode of carriage will be familiar with the International Maritime Dangerous Goods (IMDG) Code. However, given the likely journey of a container from stuffing to delivery, there is also a need to be aware of the other modal regulations. The International Carriage of Dangerous Goods by Road (ADR) was originally set up by the UN Economic Commission for Europe but is now applied around the world to road transport. Rail transport is controlled by International Carriage of Dangerous Goods by Rail (RID) regulations, and air transport by the International Air Transport Association (IATA) as the airline’s trade association, in conjunction with local governments and the International Civil Aviation Organization (ICAO), as a UN specialised agency.
The regulatory controls forbid transport of dangerous goods, which, when presented, may “explode, dangerously react, produce a flame or dangerous evolution of heat or dangerous emission of toxic, corrosive or flammable gases or vapours under normal conditions of transport...” and yet such products are transported all over the world. The key words are ‘under normal conditions of transport’ – it is possible to move such products by ‘altering’ the normal conditions. Such alterations may include: refrigeration, heating, pressure tanks, shipping in small quantities, or adding dilutants or stabilisers to the product in question.
It would be cumbersome to produce a single regulatory document to cover all modes of transport; each set of modal regulations is based on the UN Model Recommendations on the Transport of Dangerous Goods, which harmonise with GHS in relation to transport criteria. For example, both the ADR and RID have additional restrictions on certain chemicals with respect to things like bridges and tunnels (something which the maritime sector does not often have to think about). Similarly, IATA restricts certain magnetic materials, as these can affect the navigation systems on aircraft, but are unlikely to affect rail transport.
One area of ‘dangerous goods’ which applies equally to all modes is that defined as Environmentally Hazardous Substances (EHS) – these are also referred to as ‘marine pollutants’ in the IMDG Code, but may be just as unpleasant if they reach rivers and streams, hence ‘EHS’ is the description used in GHS with the ‘dead fish/tree’ symbol. Some products can be both EHS and have other primary hazards, so may be listed under their primary UN number. If they only have EHS hazards, they will be UN3077 (solids) or UN3082 (liquids).
“Some products can be both EHS and have other primary hazards”
Many countries have made the provision of an SDS mandatory, but certain sections (and EHS is one of them) permit ‘no data available’ as the description and the manufacturer may not be required to generate the necessary data. Based on experience, here are some common issues found on SDS:
• It is an error if the SDS displays the ‘dead fish/tree’ symbol but contains no UN number;
• Similarly, an ‘H400’ statement (the EU hazard statement for EHS products) should be accompanied by the ‘dead fish/tree’ symbol;
• The SDS may provide a UN number and indicate the product is EHS but not list any ecotoxicological data (so how do they know it is hazardous?). Conversely, the SDS may include ecotoxicological data evidencing that the product is EHS but fail to declare an appropriate UN number;
• All hazardous ingredients are listed in Section 3 of the SDS, but the sum of the concentration may not be 100% - it is not unusual to find that some ingredients (and their hazards) are not reported.
We gratefully acknowledge the assistance in the preparation of this article of Penelope Cooke, Consulting Scientist, Brookes Bell (a member of the Thomas Miller Group)
We hope that you have found the above interesting. If you would like further information, or have any comments, please email us, or take this opportunity to forward to any colleagues who you may feel would be interested.
We look forward to hearing from you.
Risk Management Director, TT Club