I may be old, but I’m not old enough to have watched the television show, Daddy Knows Best. However, as a father, I’d sure like it to be true about me. Unfortunately, there’re several children that could testify eloquently about the number and severity of my parenting errors. Hey, it’s not like I didn’t try. I really did.
Good intentions aren’t always enough, though. Sometimes it’s almost impossible to make a good decision that covers all the possibilities and permutations. For example, suppose were to be an international manufacturer and shipper of a slightly flammable (Flash Point ~58oC / ~136oF) flavoring product that I sell in a variety of sizes. When I complete my mSDS, what do I put in Section 14?
In order to reduce expenses and fees, I use a variety of regulatory exceptions. These are aimed at avoiding UN specification packaging, avoiding labels that trigger separation & segregation as well as placarding requirements, and avoiding shipping papers that can cause higher HazMat (dangerous goods, DG) carrier rates and fees.
For my shipments of 30 mL or less, I’ll use Dangerous Goods in Excepted Quantities, which has no UN specification packaging, no labels, and no special DG paperwork, yet offers the convenience of surface and/or air transport interchangeably.
For my 1 L bottles, I’ll use Limited Quantity (LTD QTY, LQ), which is no UN spec., no labels, no shipping papers, but alas, isn’t quite as helpful for air transport.
For my air shipments greater than 30 mL but not over 5 L, I’ll take advantage of the ID8000, Consumer Commodity exception, which avoids Class 3 labeling in favor of a Class 9, and probably matches the classification of some of my other products.
For shipments within the USA, I will even plan to use their Combustible Liquid exception, and ship this product completely non-regulated, non-restricted, although this only applies in non-bulk sizes shipped via rail or highway.
For all the rest of the permutations of size, destination, origin, transit, and mode, I’ll use a fully regulated classification, such as, perhaps, UN1197, Extracts, flavouring, liquid, 3, III.
Sometimes, I’ll provide paperwork and other times I won’t.
Sometimes, I’ll use one identification number and at other times a different one.
Sometimes, there’ll be label(s) and other times not, and the labels won’t always be the same when present.
Sometimes, there’ll be marks and other times not.
Sometimes, I’ll use the more expensive UN specification packaging, and other times a less expensive, strong outer packaging, which may or may not, depending upon exception have been pre-tested for dropping and stacking.
BUT ALWAYS LEGAL, ALWAYS COMPLIANT.
So, again I ask, with the best of intentions, in order to minimize any delays caused by my mSDS not matching my shipments, what do I put in Section 14? I’ve read repeatedly that manufacturers know their product best. But whatever I put in Sec. 14, unless I reproduce most of this column there, it can’t match every one of my shipments.
So, judging from past experience with shipments held for not reflecting the mSDS, it certainly may appear, at least to those that unthinkingly refer to Section 14, that like some daddies, manufacturers and mSDS authors don’t always know best.