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Policy & Compliance


Classification and safety data sheets


TT Talk recently explained the harmonisation process that safety data sheets have undergone, as well as their use in the freight supply chain, and highlights some of the problems that can arise. The article is reproduced here


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. 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


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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 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’ that 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


October 2018


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