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or wrong classifications, mismatch between product form and SDS (powder vs aerosol, solids on ethanol), outdated or un-updated Section 14 entries after reformulation, and confusing or mode-specific exception claims (limited quantity, accepted quantity, consumer commodity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.
00:00 Show Intro and Resources
00:37 Meet Ken Sumner
02:09 Why SDS Transport Data Fails
05:05 How Ken Verifies Classifications
07:57 Hand Sanitizer Case Studies
11:11 When Testing Data Is Missing
16:01 More Real World SDS Disconnects
22:33 Exceptions Limited Quantity Confusion
26:04 GHS Pictograms vs DOT EPA
29:03 Environmental Hazard Nuances
30:00 SDS Catch All Pitfalls
31:19 AI Needs Human Judgment
31:59 Warehouse Mercury Lesson
33:37 Packaging From Section 14
36:12 Accepted Quantity Testing
38:45 Drop Stack Test Demo
42:27 Documenting Your System
44:05 Keeping SDS Current
47:29 Trade Secrets Controlled Drugs
52:43 Where to Include SDS
57:48 Trust But Verify Wrap Up
