TT Talk - Dangerous Goods Declarations and Material Safety Data Sheets
Mike Compton, the Technical Advisor for ICHCA International, writes: A document that is increasingly being used in relation to the conveyance of packaged dangerous goods is a Material Safety Data Sheet (MSDS) or, as it is becoming more commonly known, the Safety Data Sheet (SDS). Often dangerous goods declarations for conveyance of packaged goods by sea are accompanied by an SDS and, if there is any doubt about the substance or material, the person taking the bookings and/or receiving the declaration may ask for an SDS and they are relied upon for specific information relative to conveyance, stowage and segregation.
Whilst, apart from cargoes shipped in bulk carriers, there is believed to be no legal obligation for SDS to be supplied to organisations in the transport chain, the TT Club encourages the practice of providing them. However, ICHCA International has informed its members that recent discussions have shown that the contents of SDSs can vary and that this could pose a problem for the recipient shipping companies, ports and terminals. In one instance, a well known chemical manufacturer issued separate SDSs over three successive months each with a different UN Number but for the same product. This happened because the individuals preparing each SDS had insufficient training on how correctly to choose UN Numbers and to classify goods in the first place. There are reasons for believing that this kind of situation is not uncommon.
The legal situation is that a shipper signs a dangerous goods note and this implies that the consignment has been classified and identified correctly and legal liability is attached to this statement. Furthermore, from January 2010 all such persons involved with packaged DG on the shoreside must be trained, including those who prepare SDSs (see TT Talk 121 for practical guidance on encouraging compliance with this new requirement). In addition, specialist shipping line and port staff could usefully be trained in how to read and interpret SDSs.
However, from a practical point of view what is the booking clerk or person receiving the declaration to do when faced with an SDS? More specifically, what should they be trained to do? The implications of the above are that we should all be more circumspect when using SDSs. The following are example scenarios:
Example 1 - A shipper submits an SDS which shows that a substance or material that is in the IMDG Code is really not dangerous for transport by sea, eg carbon black of mineral origin. - This should be checked with the shipper and/or an in-house or outside expert who can advise on what should be the response. If the shipper insists that the SDS is correct, it is suggested that a categorical written statement be obtained before accepting it. - The booking clerk's training should enable him/her to consider whether the data presented in these sections support the transport class, subsidiary class, packing group, proper shipping name and packing group and aquatic pollutant classification presented in the transport section including whether confirmation as being not dangerous for transport is supported.
Example 2 - A shipper submits an SDS which shows that a substance is a flammable liquid even though not specifically in the IMDG Code but should be, eg a flammable liquid with a flashpoint at or below 600C. - Generally this would be accepted, unless there is any reason to doubt it.
Example 3 - A shipper submits an SDS which shows that the substance or material is not dangerous but the stowage information includes advice regarding stowage away from heat and/or away from other substances such as organic peroxides. - It is thought that there are a number of substances that this situation can apply to and, at the very least, the relevant stowage information must be noted and implemented during the stowage and segregation provisions on shore and on ship.
Readers who deal with SDSs are alerted to this situation and advised to treat them carefully. There should always be someone in-house or outside who can assist in cases of doubt and those details should be readily to hand.