Material Safety Data Sheet (MSDS)

A material safety data sheet (MSDS) is the document a chemical product's manufacturer or importer writes to describe its hazards, how to handle and store it safely, and what to do in a fire, spill or exposure. Its current name is safety data sheet (SDS): the UN's Globally Harmonized System of Classification and Labelling of Chemicals (GHS) set a standard 16-section layout, and OSHA adopted it in its Hazard Communication Standard (29 CFR 1910.1200) in 2012. Shippers, forwarders and carriers still say MSDS and mean the same document.

What an SDS contains

The 16 sections, in this order (29 CFR 1910.1200(g)(2)): 1 identification, 2 hazard identification, 3 composition, 4 first aid, 5 fire-fighting, 6 accidental release, 7 handling and storage, 8 exposure controls and personal protection, 9 physical and chemical properties, 10 stability and reactivity, 11 toxicology, 12 ecology, 13 disposal, 14 transport information, 15 regulatory information and 16 other information, including the date it was prepared or last revised. OSHA does not enforce sections 12 to 15, which fall under other agencies, but a GHS-format SDS still carries their headings.

Section 14 and your shipment

• Is it dangerous goods? Section 14 gives the UN number, proper shipping name, transport hazard class and packing group, and says whether the product is a marine pollutant. Your forwarder and the carrier read it to decide whether the cargo must be booked as dangerous goods under the IMDG Code by sea or the IATA rules by air
• Proving it is not: carriers often ask for the SDS on chemicals, paints, adhesives, cosmetics and cleaning products, even when the goods are not hazardous. A section 14 that reads "not regulated" for transport is what lets them accept the cargo as general cargo
• LCL and air: on a consolidation the SDS decides whether the cargo can share a container at all, and airlines check it against the IATA Dangerous Goods Regulations before they accept the booking

The SDS is not a transport document. When the cargo is dangerous goods, the shipper still completes the dangerous goods declaration (UN number, proper shipping name, class and packing group) and packs, marks and labels it for its class; the SDS is where that information usually starts.

Importing chemicals into the United States

• The importer's duty: under 29 CFR 1910.1200(g), chemical manufacturers and importers must obtain or develop an SDS, in English, for each hazardous chemical they produce or import, and give it to their distributors and customers with the first shipment and with the first shipment after it is updated. For an imported product that duty is the importer's, so get the SDS from your supplier before the goods ship
• TSCA certification: separately, CBP requires the importer or its agent to certify, before release, that a chemical substance in bulk or in a mixture complies with the Toxic Substances Control Act, or is not subject to it (19 CFR 12.121). Your customs broker files the certification with the entry

Common mistakes

• An old free-form MSDS, or one for a different formulation or supplier, that does not match the product on the commercial invoice
• A blank or vague section 14, which leaves the carrier to treat the cargo as hazardous or refuse it
• Sending the SDS after booking: the class decides which carriers, vessels and containers can take the cargo, so a late SDS can mean a new booking

Send the SDS with your inquiry so the right carrier and equipment are booked the first time. See hazardous cargo on FCL ocean freight, LCL ocean freight and air freight.