SDS (MSDS) for Shipping: the 16 Sections, Section 14 Transport Information and Non-Dangerous Goods

What an SDS is and its 16 sections

The safety data sheet is the GHS document that a manufacturer, importer or distributor of a hazardous chemical product gives to its customers. Its 16 sections, in this order, are: 1 Identification; 2 Hazard(s) identification; 3 Composition and information on ingredients; 4 First-aid measures; 5 Fire-fighting measures; 6 Accidental release measures; 7 Handling and storage; 8 Exposure controls and personal protection; 9 Physical and chemical properties; 10 Stability and reactivity; 11 Toxicological information; 12 Ecological information; 13 Disposal considerations; 14 Transport information; 15 Regulatory information; 16 Other information.

The older name MSDS (material safety data sheet) is still common in trade, but the current documents are SDSs in the GHS format. In the United States, OSHA's Hazard Communication Standard requires the 16-section format; Sections 12 to 15 must be included for consistency with the GHS, but OSHA does not enforce their content because other agencies regulate those matters. In the EU, the format is set by Annex II to REACH, as amended by Regulation (EU) 2020/878, and the SDS must be supplied in an official language of the Member State where the product is placed on the market.

Section 14: transport information

Under REACH Annex II, Section 14 gives basic classification information for transporting the product by road, rail, sea, inland waterways or air:

• 14.1 UN number.
• 14.2 UN proper shipping name.
• 14.3 Transport hazard class(es).
• 14.4 Packing group.
• 14.5 Environmental hazards, such as whether the product is a marine pollutant.
• 14.6 Special precautions for the user.
• 14.7 Maritime transport in bulk according to IMO instruments.
• If the product is not dangerous for transport, Section 14 should say so for each mode, for example "not regulated" under ADR/RID, the IMDG Code and the ICAO Technical Instructions or IATA DGR.

Why carriers and forwarders ask for an SDS

Airlines and shipping lines must not carry dangerous goods that are not declared, so they and forwarders ask for the SDS to check the classification of chemical products, cosmetics, cleaning products, batteries and similar goods. For air transport, the IATA Dangerous Goods Regulations, based on the ICAO Technical Instructions, are used to classify, mark, pack, label and document dangerous goods, and airlines such as JAL state that it is the shipper's responsibility to determine the class and to comply with them. An SDS supports that classification; it does not replace the Shipper's Declaration for Dangerous Goods when the goods are dangerous.

Cosmetics and other everyday products

• Perfumes and other products with flammable alcohol are often classified as UN1266, Perfumery products, class 3; see Triplicate's note on shipping perfume and aerosols.
• Aerosol sprays are UN1950, class 2.
• Lithium batteries, including those packed with or in equipment, are UN3480, UN3481, UN3090 or UN3091.
• Creams, lotions and shampoos are usually not dangerous goods, but carriers still ask for an SDS showing "not regulated" in Section 14 to accept them by air.
• Small quantities may qualify for limited or excepted quantity provisions with simpler rules, but they are still dangerous goods and must be declared as the rules require.

How to prepare SDSs for export

• Get the SDS for each product from the manufacturer, in the current GHS format and with a recent revision date.
• Check that the product name and code match the commercial invoice and packing list.
• Check Section 14 for every transport mode you use, and that it agrees with Section 2 and Section 9, such as the flash point of liquids.
• For the EU, use the Annex II format and the language of the destination Member State; other countries may require their own language and format.
• Send the SDS to the forwarder when you book, so that dangerous goods are identified before the cargo reaches the terminal.