Transportation vs. SDS: Finding Harmony in Compliance

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or wrong classifications, mismatch between product form and SDS (powder vs aerosol, solids on ethanol), outdated or un-updated Section 14 entries after reformulation, and confusing or mode-specific exception claims (limited quantity, accepted quantity, consumer commodity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.