Can a Safety Data Sheet Be Wrong?

Posted on 2/2/2023 by Robert Clarke, CDGP and Roseanne Bottone

It’s a call no shipping professional wants to receive. Your carrier is on the line to tell you that your hazardous material leaked from its package during transport. Your material damaged their truck and, even worse, an airplane cargo hold.

Later that same day, you get another call. A 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 not able to process.

You're shocked. You followed the environmental, disposal, and shipping information in boxes 12, 13, and 14 of the material’s Safety Data Sheet to the letter. So what happened?

Safety Data Sheets: Transportation and Disposal

OSHA’s Hazard Communication Standard (HCS) requires chemical manufacturers, importers, and distributors to provide a Safety Data Sheet (SDS) for any hazardous chemical to employers and other downstream users (29 CFR 1910.1200(g)).

The SDS is a 16-section* document that provides information about the chemical’s classification and hazards. The goal is to ensure that workers who handle the chemical are informed about potential dangers and can take the right precautions.    

A Safety Data Sheet (SDS) can be an invaluable tool for identifying hazardous materials and wastes and obtaining the info needed to manage, ship, and transport them safely.

But not every SDS provides completely accurate information. 

Can a Safety Data Sheet Be Wrong?

What's Required on an SDS?

OSHA requires most boxes of an SDS be filled out completely. Other boxes are optional.

Boxes 12 (Ecological information), 13 (Disposal considerations), 14 (Transport information), and 15 (Regulations information) are all optional. That means that these boxes may be empty on the SDS for your material, with zero information to use. Even if the information is there, it may not be accurate.

When you ship hazardous materials, it is your responsibility to ensure your material is properly classified and described for transportation. When you generate hazardous waste, it is your responsibility to make an accurate hazardous waste determination.

Sometimes, relying on the information on the SDS is not enough. You may have to consult chemical publications or industry data, assess process inputs, or take samples for analysis.

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 inaccurate if the test method was not followed correctly, or if an unapproved test method was used. The sample tested may have been contaminated by a previous material sample, or the proper temperature may not have been maintained throughout the test.

Also, the SDS you received may not match up with your exact shipping needs: The creator of the SDS may ship that hazardous substance in small quantities that do not require any indication of a Reportable Quantity (RQ). If you ship greater quantities per package, you may need that RQ to properly mark your package and complete hazmat 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. Even an SDS that your organization created, or that you created yourself, might become outdated over time, requiring an update or revision to remain accurate.

Seemingly minor mistakes that can lead to an inaccurate SDS include: 

  • Units of measure are wrong (e.g., Fahrenheit vs. Celsius or pounds vs. kilograms)
  • The SDS was translated from another language, and details got lost in translation
  • Minor typos. They can make a big difference (e.g., Packing Group I vs. Packing Group II)

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 shippers are responsible for properly classifying any hazardous material they offer for transportation and that generators are responsible for properly identifying any hazardous waste they produce.

Seeking out and using the most accurate, up to date information 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 it is complete and accurate. At the end of the day, that responsibility is yours and yours alone.

The 16 sections of an SDS are:

1.) Identification.
2.) Hazard identification.
3.) Composition/information on ingredients.
4.) First-aid measures.
5.) Fire-fighting measures.
6.) Accidental release measures.
7.) Handling and storage.
8.) Exposure controls/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 (including date of preparation or last revision).

[See 29 CFR 1910.1200(g)(2)].

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Lion's upcoming hazmat shipper and hazardous waste management training in Dallas and Houston is a chance to refresh your expertise, find out what's new, and get training required  by US EPA (RCRA) and US DOT (49 CFR) for "hazardous waste personnel" and "hazmat employees."

After our Texas trip, we're bringing expert-led in-person training to Chicago, Cincinnati, and St. Louis. Check out the workshop schedules at the links below. We'll see you in the classroom! 

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Dallas March 3–4  / Houston March 20–21

Hazmat Air Shipper Certification (IATA) (1 day) 
Houston March 22

Hazmat Vessel Shipper Certification (IMDG) (1 day) 
Houston March 23

Tags: hazardous waste management, hazmat shipping, OSHA compliance, Safety Data Sheets, SDS

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