In this article, Phil Todd takes a look at the various issues surrounding the safety data sheet (SDS) with reference to section 14 on Transport Information.
SDSs are used to communicate a wide variety of important health, safety and environmental information about a chemical to the people who handle it. Not least of these are the transport community via section 14 — Transport Information.
Historically, the content of section 14 of SDSs has varied considerably. There are many examples of SDSs which contain useful information but there are also plenty of examples of SDSs where the only content in section 14 was “contact your nearest sales office” — which is not exactly useful.
Historically, EU directives were very sparse when providing guidance for the content of section 14. For example, the SDS Directive 93/115 simply suggested it includes “any special precautions that the user needs to comply with in connection with transport”.
The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) now contains more detailed guidance, suggesting that the UN number, Proper Shipping Name, hazard classes, packing group and environmental hazards should be included. In Europe, further details are required as REACH Annex II specifies that this information should be included for the various modes of transport.
This introduces the first problem that compilers of section 14 of the SDS need to cope with: how to arrange all this information. The European Chemicals Agency (ECHA) guidance on compilation of SDSs does not provide any enlightenment. Its example of the section is no more than a repetition of the required subsections. There has been a lot of discussion about the lack of detail in this guidance with a body of opinion that there should have been a suggested layout for this section in the guidance. Practically, two main approaches are evolving. The first approach groups the information according to the mode of transport. The second approach groups the information according to the sub-heading.
Both approaches appear to satisfy the requirements and, to a reader, there appears to be little to choose between them.
For materials that are not classified as hazardous for transport, the same requirements apply. REACH Annex II states that where information is not relevant, this needs to be stated. This means that for materials that are not classified as hazardous for transport, the sub-headings for UN number, packing group, etc, still need to appear. This has the effect of increasing the size of the section, the benefits of which are questionable.
SDS compilers are now required to include two additional requirements when writing section 14. The first is that all SDSs are required to address the bulk transport requirements of Annex II of MARPOL 73/78 and the International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (IBC Code), even if the material is never carried in bulk by sea. Both the GHS Annex 4 and REACH Annex II state that this subsection only applies when cargos are intended to be carried in bulk by sea. However, REACH then makes the sub-heading mandatory by including it in the list of mandatory sub-headings: surely a contradiction that should be resolved when Annex II is next updated. In the meantime, compilers will need to include this subheading even if, due to the nature of their products, the only information that will ever be included is “not applicable”. Fortunately, modern SDS software is capable of creating default text, hence avoiding a small amount of unnecessary work.
The second piece of additional information is “Special precautions to the user”. The use of the word “user” in a section dedicated to transport is a little confusing. Fortunately, the explanatory text clarifies that it refers to the transport environment.
The ECHA guidance suggests that this section can be used for additional information such as special provisions or tunnel codes. Additionally, this section provides a home for other transport-related information that does not fit anywhere else in the SDS. For example, where products involve small amounts of non-hazardous gases (such as carbon dioxide), packs are often equipped with vents to avoid pressurising the container. This has no impact on surface modes of transport, however, vented packages are forbidden for air transport. As the vents are often incorporated into the caps and are not immediately visible, a warning on the SDS would help to prevent shipment by air of these packages. Similarly, if a material is not classified as dangerous due to the size/type of packages that are used, then additional information would be useful if a recipient was thinking of repacking the material. An example could be where the bonfire test is used to avoid classification as an explosive or for self-heating products carried in packages of less than 450 litres.
Finally, SDS compilers need to decide on their philosophy when writing this section. One school of thought is that this section provides basic information to allow a competent person to apply the transport regulations, when used with other information about the actual product to be shipped. Under this approach, the SDS contains only the information specified in GHS/REACH. The main advantage of this method is that this section only needs updating when the classification of the product changes, eg a UN number or Proper Shipping Name changes. The downside of this approach is that customers or shipping lines sometimes ask for extra information from the transport regulations to be included and it can look less than customer-friendly to ignore.
Conversely, the other school of thought is to include extra information; such as tunnel codes, packing instructions, etc. The major disadvantage of this approach is that SDSs may need updating when the transport regulations change. You need only to consider the amount of effort that would have been triggered by the systematic renumbering of the International Civil Aviation Organization (ICAO) packing instructions to see the problem.
While the content of section 14 of the SDS is still evolving, the introduction of the REACH/GHS format SDS does define minimum content. It is hoped that the usefulness of this section to transport professionals will increase and the days of “contact your nearest sales office” will soon be nothing but an unpleasant memory.
Last reviewed 1 February 2012