Host Atanu Das interviews Ken Sumner of KWS Training, a dangerous goods transportation trainer with 30+ years’ experience, about where OSHA HazCom and DOT transport requirements intersect and frequently conflict. Sumner describes common SDS problems—missing or wrong classifications, mismatch between product form and SDS (powder vs aerosol, solids on ethanol), outdated or un-updated Section 14 entries after reformulation, and confusing or mode-specific exception claims (limited quantity, accepted quantity, consumer commodity ID 8000). He explains his approach: gather exact product/packaging details, compare SDS data (flash point/boiling point/ingredients) to IATA and 49 CFR definitions, and use worst-case assumptions when testing data is absent or trade secrets limit disclosure. They discuss benefits of targeted testing to reduce regulation burdens and shipping costs, packaging system testing for accepted quantities, the limits of “harmonization” across agencies, and the need to “trust but verify” SDSs.

Ken Sumner

President

Ken Sumner of KWS Training, Inc. is a professional Dangerous Goods transportation trainer with over 30 years of experience in 49CFR, the IATA DGR and IMDG regulations. He has trained thousands of students from a wide variety of industries and research organizations in the requirements to ship an enormous variety of hazardous materials. Infectious specimens, novel research compounds, battery powered equipment, medicines, aerosols, radioactive materials, flammable flavorings, dangerous street drugs, and live viruses are just a small sample of the many products he has trained clients to classify, package and ship. Ken attended the original Department of Transportation Train-the-Trainer program in Oklahoma City in the 1990’s and regularly attends training provided by a wide variety of organizations to maintain a high degree of current knowledge.