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How Much to Trust a Safety Data Sheet

Posted on 12/7/2020 by Robert Clarke, CDGP

It’s the call that no shipping professional wants to receive. Your carrier is on the line to tell you that the packages you shipped with them leaked during transport. Your material damaged their truck and, even worse, an airplane cargo hold.

Later that same day, you get another call. A hazardous waste Treatment, Storage, and Disposal Facility (TSDF) to which you shipped a hazardous waste says they can’t treat it. They sampled the waste and found it contains toxic constituents that they are unable to process.

You’re shocked. You followed the environmental and shipping information in boxes 12, 13, and 14 of the material’s Safety Data Sheet to a T. So what happened?

Using an SDS for Transportation and Waste Disposal

A Safety Data Sheet (SDS) is an invaluable tool for waste identification and waste and product shipping. That said, not every SDS provides the most accurate information.

OSHA requires that most boxes of an SDS be filled out completely. Other boxes—12, 13, 14, and 15 to be specific—are optional. That means that the SDS for your material may not include any information in these boxes. Even if the information is there, it may not be completely accurate.

When you ship hazardous materials, it is your responsibility to ensure your material is properly classified and described for transportation (49 CFR 173.22(a)(1)). When you generate hazardous waste, it is your responsibility to make an accurate hazardous waste determination (40 CFR 262.11). 

Sometimes, relying on the information provided on the SDS is just not enough.

Why a Safety Data Sheet Can Be Wrong

An SDS may include inaccurate environmental and/or transportation information for many reasons. Data points like a material’s flash point or LD50 may be incorrect, leading to an inaccurate hazard class, proper shipping name, and waste disposal restrictions.

The test results used to create the SDS may be faulty if the test method was not followed exactly right. The sample used may have been contaminated by a previous material sample, or the proper temperature may not have been maintained throughout the test.

The SDS you received may not conform to your exact shipping needs. For example, the creator of the SDS may ship a particular hazardous substance in small quantities that do not require a Reportable Quantity (RQ) marking. If you ship in larger quantities, the RQ may be required on the package and your shipping papers.

The SDS for a chemical used in your process may not indicate every contaminant or constituent present in your hazardous waste.

Waste can change over time due to changes in the chemicals used on site or changes in your manufacturing process. So even if you’re using an SDS created by your own organization—it may be outdated or no longer accurate.

Keep in mind that the format of the SDS—formerly called a Material Safety Data Sheets (MSDS)—changed dramatically when OSHA adopted the Globally Harmonized System for Classifying and Labeling Chemicals (GHS) in 2012.

Even seemingly minor mistakes cause inaccurate SDS information, like:  
  • Units of measure are wrong (e.g., Fahrenheit vs. Celsius)
  • The SDS was translated from another language and details were lost-in-translation
  • Minor typos can make a big difference (e.g., Packing Group I vs. Packing Group II)
The fact is that the accuracy of any Safety Data Sheet is highly dependent on the skill and attention-to-detail of the person(s) who created it.

Your Shipment, Your Responsibility 

Nobody is perfect. We all make mistakes because we are human! The bottom line is that the regulations require that shippers properly classify their hazardous materials and that hazardous waste generators properly identify their waste. Creating and using the most accurate data sources possible is vital to ensure compliance,  safeguard the environment, and protect personnel. 

Before you trust the information on any SDS, you should be confident that it is complete and accurate. At the end of the day, that responsibility is yours and yours alone.   

Sign Hazmat Shipping Papers with Confidence

Start 2021 with live, expert-led hazmat training at Lion.com. Keep your shipping certifications up to date and help satisfy training mandates for hazmat employees at 49 CFR 172.704, IATA DGR 1.5, and IMDG Code 1.3.1.

Develop a step-by-step process to ship hazardous materials in full compliance with US DOT and international regulations. 
 
Recurrent Hazmat Ground Shipper Certification (DOT)  Jan. 6
Hazmat Air Shipper Certification (IATA)  Jan. 7
Hazmat Vessel Shipper Certification (IMDG)  Jan. 8
Initial Hazmat Ground Shipper Certification (DOT)  Jan. 19–20

US DOT requires training once every 3 years for all hazmat employees (49 CFR 172.704).
For air shippers, the IATA DGR requires training once every 2 years (IATA DGR 1.5)

Lion offers a full suite of EH&S consulting services—including SDS authoring--to help you maintain compliance with the latest environmental, hazardous materials, and safety regulations.

Tags: hazardous materials, hazardous waste, OSHA compliance, Safety Data Sheets

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