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Hidden hazardous materials in the things we ingest, inhale, or put on our skin. Who knew? Proper hazard identification is critical in meeting shipping regulations. Read More
September 03, 2014 | Hazmat Handling
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Hi Gene Great article. I really appreciate these insights into how an SDS factors into the HazMat/DG classification debacle that many face. I am completely on board for vetting shipments against being undeclared HazMat/DG, but let me pose to you the following thought... You say that an SDS should be used to rule something in as HM/DG, but not to rule it out. However, could this approach be slightly problematic? What if one were never able to trust an SDS that has "Not-Regulated" written in Section 14? Where might that lead? Prior to GHS this kind of scrutiny was certainly necessary, but now isn't it one of the SDS's many fuctions to answer that YES/NO/MAYBE question about Haz/Non-Haz for transport? While it's hardly ever safe to assume anything, I do think that when an SDS has every other section completed in the GHS format, and, it is a current one (less than a year old in my personal opinion), then I feel confident that the author was prepared to do the following before he or she listed "Not-Regulated" in Section 14: 1.) Identify if/when the material meets the established defining criteria for any Hazard Class and, a.) Do so based on all modes of transportation and, b.) Do so for as many separate regulations/standards/destinations as feasible and, c.) Do so in a manner that does not assume the materials are already under the minimum quantity threshold for de-regulating 2.) Point out by reference any Special Provisions, Exceptions, or other means of de-regulating )or re-classifying) the product as HM/DG, whether that be based on quantity or other means. What do you think? Does an otherwise compliant SDS truly present a concern when Section 14 tells a shipper what they were hoping to hear? Looking forward to your thoughts.