SDS (Safety Data Sheet) — Section 14 and Transport Information for Dangerous Goods
Interlink編集部What Is an SDS?
An SDS, or Safety Data Sheet, is a safety document that details the hazardous properties, chemical composition, handling, storage, first-aid measures, spill response, disposal, and transport information of chemical products.
It was formerly known as an MSDS, but the term SDS is now the standard terminology.
In freight forwarder operations, the SDS serves as the initial reference for dangerous goods transport. It is used to confirm whether cargo qualifies as dangerous goods, whether a UN number is assigned, the hazard class, packaging group, and how the cargo should be handled for maritime or air transportation.
However, receiving an SDS alone is not sufficient to decide transport eligibility. It is necessary to cross-check the transport information section of the SDS alongside GHS labeling, actual cargo markings, dangerous goods declarations, invoices, packing lists, and acceptance requirements from shipping lines, airlines, CFS, and warehouses.
Scope Covered in This Article
| Item | Content Covered in This Article | Content Covered in Other Articles |
|---|---|---|
| Basics of SDS | Organizes the Safety Data Sheet as a document to confirm chemical hazards, composition, handling, storage, and transport information. | Detailed legal explanations of the SDS system itself are covered in the Chemical Management System article. |
| Interpretation in Freight Forwarder Operations | Covers how to use SDS to link with dangerous goods transport, CFS in-gate, warehouse receipt, and confirmations with airlines and shipping lines. | Preparation and classification work for SDS from the chemical manufacturer’s side are covered in specialized materials and articles for manufacturers. |
| Differences Between MSDS and SDS | Explains why confirming the latest SDS is necessary when receiving an older MSDS. | Details on the system transition from MSDS to SDS are handled in the Chemical Labeling System article. |
| Relationship with GHS Labeling | Discusses the link between GHS labeling and SDS, and the differences between GHS hazard classification and transport dangerous goods classification. | Details on GHS pictograms and labels are covered in the GHS Labeling article. |
| How to Read Section 14 of SDS | Focuses on confirming the UN number, proper shipping name, hazard class, packaging group, marine pollutant status, and sea/air transport conditions. | Detailed application and interpretation of the IMDG Code and IATA Dangerous Goods Regulations are covered in their respective articles. |
| When Transport Information Fields Are Blank or Not Applicable | Addresses how to respond when fields are blank, under review, not applicable, sea-only, air-only, or contradictory to actual markings. | Formats and preparation of non-dangerous goods certificates are covered in the Non-Dangerous Goods Certificate article. |
| Cross-Checking with Other Documents | Covers matching SDS with dangerous goods declarations, invoices, packing lists, physical labels, and non-dangerous goods certificates. | Details on filling out and formatting dangerous goods declarations are covered in the Dangerous Goods Declaration article. |
| Handling Practical Troubles | Addresses issues such as outdated SDS, product name mismatches, insufficient transport information, contradictions with actual markings, and reconfirmation when concentration, quantity, or packaging change. | Judgments on cost allocation, compensation, and delay liability are covered in the Cargo Incidents and Cost Allocation article. |
Overview of SDS
An SDS is a document used to communicate essential information for the safe handling of chemicals between business operators.
It is used by manufacturers, importers, sellers, users, storers, and transporters of chemicals to understand the hazards and handling conditions of the chemical substances involved.
In Japan, laws such as the Chemical Substances Control Law, the Industrial Safety and Health Act, and the Poisonous and Deleterious Substances Control Act may require provision of an SDS and labeling for certain chemical substances or products containing them.
For freight forwarders, it is important not only to treat the SDS as part of customs clearance documentation but also to use it as a reference to confirm dangerous goods transport, warehouse in-gate acceptance, CFS receipt, and acceptance by airlines and shipping lines.
Differences Between MSDS and SDS
MSDS stands for Material Safety Data Sheet and is the older term previously used. Currently, within the flow of information transmission aligned with GHS, the term SDS is commonly used.
When a shipper submits an old MSDS, the freight forwarder needs to verify whether it can still be used as is.
| Category | Practical Interpretation | Points of Caution | Freight Forwarder Practical Response |
|---|---|---|---|
| MSDS | Safety data sheet created under the old naming system. | If the creation date is old, the GHS classification, transport information, and regulatory information may not align with current standards. | Confirm with the shipper or manufacturer whether a latest version SDS is available. |
| SDS | Currently the commonly used safety data sheet. | Need to confirm it is the latest version, corresponds to the relevant product, and includes a transport information section. | Focus on verifying Section 14 transport information. |
| GHS-Compliant SDS | SDS that includes GHS classification, pictograms, signal words, and hazard statements. | GHS labeling does not necessarily match the dangerous goods classification for transport purposes. | Cross-check Section 14 transport information against physical labels on the actual cargo. |
| When Receiving an Old MSDS | While it can be useful as reference material, it should not be solely relied upon for transport decisions. | Important not to determine non-dangerous goods status only based on outdated documentation. | Obtain the latest SDS, manufacturer confirmation letters, and dangerous goods classification documentation. |
Relationship Between SDS and GHS Labeling
GHS labeling conveys the hazardous and harmful properties of chemicals using pictograms, signal words, and hazard statements. The SDS provides more detailed information about these hazards and handling precautions.
When GHS pictograms are present on the product or its packaging, freight forwarders should review the SDS and separately assess the hazards communicated by GHS and the dangerous goods classification for transport purposes.
| Item to Confirm | Details to Check | Practical Meaning for Freight Forwarders | Notes |
|---|---|---|---|
| GHS Labeling | Check pictograms, signal words, hazard information, and precautionary statements. | Serves as the initial screening to determine whether cargo requires dangerous goods confirmation. | Do not base dangerous goods classification solely on GHS labeling. |
| SDS | Review hazards, ingredients, physical properties, handling instructions, transport information, and regulatory data. | Used to verify dangerous goods classification, shipping conditions, and safe storage and handling. | Confirm that the SDS version matches the specific product and is the latest available. |
| Section 14 of SDS | Check UN number, proper shipping name, hazard class, packing group, marine pollutant status, etc. | Directly links to verification under the IMDG Code and IATA Dangerous Goods Regulations. | Confirm conditions for each mode of transport. |
| Dangerous Goods Declaration | Examine details declared for transport as dangerous goods. | Must be cross-checked with the SDS for consistency. | Verify UN number, proper shipping name, quantity, packaging form, and packing. |
| Physical Labels | Check GHS labels, dangerous goods labels, UN number, and product name on the actual item. | Serves as evidence that the physical goods match the SDS and declaration. | If discrepancies exist between physical labeling and SDS, reconfirm information. |
The 16 Sections of an SDS and How They Are Used in Transport Operations
An SDS is generally structured into 16 sections. For freight forwarder operations, Section 14 on transport information is the most directly relevant, but the other sections also provide important supplementary information.
| SDS Section | Main Content | Use in Transport Operations | Points to Confirm |
|---|---|---|---|
| 1. Chemical and Company Identification | Product name, supplier, emergency contact details, etc. | Verify consistency with invoice product name, manufacturer, and the intended product. | Ensure the SDS is not for a different product. |
| 2. Hazards Identification | GHS classification, pictograms, signal words, hazard statements. | Check that GHS labeling matches the physical labels on the cargo. | This may not always directly correspond to transport dangerous goods classification. |
| 3. Composition/Information on Ingredients | Ingredient names, concentrations, and mixture information. | Confirm if changes in concentration or ingredients affect dangerous goods classification. | Reconfirm if formulation changes occur even under the same product name. |
| 4. First-Aid Measures | Instructions for inhalation, skin contact, eye contact, ingestion. | Review as safety information for warehouse or CFS accident response. | May be requested by the receiving facility. |
| 5. Fire-Fighting Measures | Suitable extinguishing agents, hazards during fire, protective equipment. | Confirm for flammable cargo or shipments where fire response is critical. | Relevant to carrier and warehouse safety checks. |
| 6. Accidental Release Measures | Precautions for human health and environment, containment methods. | Provides handling instructions requested by CFS, warehouse, and carriers in case of leakage. | Important for liquid cargo and marine pollutants. |
| 7. Handling and Storage | Safe handling practices, storage conditions, conditions to avoid. | Relates to confirming CFS in-gate, dangerous goods warehouse, temperature control, and compatibility. | Compare with warehouse and CFS acceptance conditions. |
| 8. Exposure Controls/Personal Protection | Exposure limits, protective equipment, ventilation requirements. | Check if special safety measures are necessary during cargo handling and warehouse operations. | Relevant to the safety of onsite personnel. |
| 9. Physical and Chemical Properties | Appearance, odor, pH, flash point, boiling point, vapor pressure, etc. | Flash point and physicochemical data may justify dangerous goods classification or transport conditions. | Especially important for flammable liquids and volatile cargo. |
| 10. Stability and Reactivity | Reactivity, chemical stability, conditions to avoid, incompatible substances. | Important for confirming stacking, segregation, compatibility, and storage conditions. | Affects decisions on mixed shipments with other cargo. |
| 11. Toxicological Information | Acute toxicity, skin corrosion, carcinogenicity, etc. | Relevant for verifying GHS labeling and handling precautions. | May not directly match transport dangerous goods classification. |
| 12. Ecological Information | Hazards to aquatic environment, persistence, biodegradability, etc. | Acts as an entry point for determining marine pollutant status. | Check against marine pollutant classification. |
| 13. Disposal Considerations | Disposal methods, residues, handling of contaminated containers. | May relate to handling incidents, leaks, and cargo returns. | Confirm when return or disposal is expected. |
| 14. Transport Information | UN number, proper shipping name, class, packaging group, marine pollutant status, etc. | The most directly relevant section for confirming dangerous goods classification in maritime and air transport. | Verify that transport mode-specific details are included. |
| 15. Regulatory Information | Applicable laws such as Chemical Substances Control Law, Industrial Safety and Health Law, Poisonous and Deleterious Substances Control Law, Fire Service Law. | Relevant to confirming domestic storage, handling, customs clearance, and warehouse acceptance. | Separate confirmation of domestic legal status from international transport dangerous goods classification. |
| 16. Other Information | Date of creation, revision date, reference sources, disclaimers, etc. | Verify the SDS is the latest version and check revision history. | Confirm that an outdated SDS is not being used. |
While Section 14 is central to transport operations, Sections 3 (composition), 7 (storage conditions), 9 (flash point and physical properties), 10 (reactivity), and 12 (environmental impact) may also influence transport-related decisions.
How to Read Section 14 “Transport Information”
The transport information field in Section 14 of the SDS is the key area freight forwarders should carefully check.
| Check Item | What to Confirm | Practical Significance | Response if Issues Are Found |
|---|---|---|---|
| UN Number | Confirm which UN number applies as the dangerous goods identifier for transport. | This is the basis for the IMDG Code, IATA Dangerous Goods Regulations, and dangerous goods declarations. | If blank, request confirmation from the manufacturer or ask for dangerous goods classification documentation. |
| Proper Shipping Name | Confirm that the Proper Shipping Name is provided. | Declare the shipping name used in transport regulations, not the commercial product name. | If it differs from the invoice name, verify the specific product. |
| Hazard Class | Check for primary and subsidiary hazard classes. | Relates to labeling, stowage, segregation, and acceptance confirmation. | Cross-check with the dangerous goods declaration and external labels. |
| Packing Group | If applicable, confirm whether the packing group is specified. | Helps verify packaging standards and quantity limits. | Confirm packaging conditions with the shipper and packer. |
| Marine Pollutant | Confirm if the cargo qualifies as a Marine Pollutant. | Relevant to marking, declaration, and shipping line confirmation for sea transport. | Cross-check SDS Section 12, dangerous goods declaration, and external markings. |
| Maritime Transport Conditions | Confirm whether handling instructions under the IMDG Code are indicated. | Supports acceptance confirmation by shipping lines, CFS, and warehouses. | Confirm acceptance with the shipping line and CFS. |
| Air Transport Conditions | Confirm whether handling instructions under the IATA Dangerous Goods Regulations are indicated. | Supports acceptance confirmation by airlines, couriers, and airport warehouses. | For air shipment, verify airline acceptance conditions. |
Even if transport information is listed in the SDS, shipping lines or airlines do not always accept the cargo. The SDS serves as an initial reference point; final acceptance depends on transport mode, packaging, quantity, cargo form, and carrier conditions.
Handling Cases Where the Transport Information Section Is Blank or Not Applicable
Even if the SDS transport information section is marked as "Not Applicable," this alone does not necessarily mean the cargo can be treated as ordinary freight.
| SDS Status | Possible Reasons | Freight Forwarder Actions | Notes |
|---|---|---|---|
| Transport Information Section Is Blank | The manufacturer may not have filled it in, the transport information may not have been confirmed, or the SDS may use an older format. | Request the latest SDS, manufacturer confirmation letter, or dangerous goods classification documents from the shipper. | Do not interpret a blank section as meaning the cargo is non-dangerous goods by default. |
| Transport Information Section Says "Under Review" | The dangerous goods classification may still be undetermined. | Do not finalize quotations or bookings; wait for classification results. | Do not proceed with collection or in-gate confirmation while the status is unresolved. |
| Transport Information Section Says "Not Applicable" | It may genuinely be non-dangerous goods, but the applicable transport mode might be unclear. | Confirm the "Not Applicable" status for both maritime and air transport. | Verify the scope of "Not Applicable." |
| Only Maritime Transport Addressed | Air transport conditions may not have been verified. | If shipping by air, additionally confirm handling according to the IATA Dangerous Goods Regulations. | Do not apply maritime transport determinations to air transport situations. |
| Only Air Transport Addressed | Maritime transport conditions or marine pollutant classification may be missing. | If shipping by sea, additionally confirm handling according to the IMDG Code. | Also check for marine pollutant classification. |
| Physical Item Has GHS Labeling or Dangerous Goods Labels | There may be discrepancies between the SDS "Not Applicable" status and the actual labeling on the cargo. | Cross-check photos of the physical item, labels, SDS, and manufacturer confirmations. | Do not disregard actual labeling on the cargo. |
| SDS Is Outdated | Classification, components, regulations, or transport information may have been updated. | Obtain the latest version and verify the revision date and transport information. | Do not make judgments based solely on outdated documents. |
When the transport information section is blank, marked "Not Applicable," or "Under Review," it is important not to proceed as if it were ordinary cargo but to verify why it is recorded that way.
Relation to Maritime and Air Transport
In maritime transport, the treatment under the IMDG Code is confirmed based on the information in the SDS. In air transport, acceptance conditions, packaging standards, labeling, and the necessity of a dangerous goods declaration are confirmed according to the IATA Dangerous Goods Regulations.
| Transport Mode | Regulations and Conditions to Confirm | Key SDS Points to Check | Practical Considerations |
|---|---|---|---|
| Maritime Transport | Confirm IMDG Code, shipping line, NVOCC, CFS, and dangerous goods warehouse conditions. | Check the UN number, proper shipping name, class, packaging group, marine pollutant status, and stowage and segregation requirements. | The shipping line may accept cargo, but the CFS or warehouse may refuse it. |
| Air Transport | Confirm IATA Dangerous Goods Regulations, airline, courier company, and airport warehouse conditions. | Check the UN number, class, packing standards, quantity limits, passenger aircraft carriage eligibility, and the necessity of a dangerous goods declaration. | Cargo accepted for sea may be prohibited or restricted for air transport. |
| Domestic Delivery and Warehousing | Confirm Fire Service Act, Poisonous and Deleterious Substances Control Act, and acceptance conditions of warehouses and delivery companies. | Check flash point, storage conditions, handling precautions, leak response, and regulated information. | Warehouses may request an SDS even if the cargo is not classified as dangerous goods for transport. |
| CFS In-Gate | Confirm acceptance conditions of CFS, consolidation operators, dangerous goods warehouses, and shipping lines for inbound cargo. | Check the UN number, class, packaging, outer packaging markings, marine pollutant status, and consolidation eligibility. | For LCL consolidation, confirm CFS acceptance and consolidation eligibility separately. |
Cargo accepted by sea transport may be rejected or restricted under air transport. Especially lithium batteries, spray cans, paints, adhesives, fragrances, alcohol-containing products, reagents, and cleaning agents frequently have differing transport mode conditions.
Cases Requiring Reconfirmation Even for the Same Product
Even when the cargo has the same product name, changes in concentration, volume, packaging type, packing form, or mode of transport may alter how it must be handled during transportation.
| Changing Factor | Possible Effects | What to Confirm | Recommended Action |
|---|---|---|---|
| Change in concentration | Classification of hazards such as toxicity, flammability, corrosivity, and harmfulness may change. | Review the updated SDS, ingredient information, and hazardous goods classification data. | Do not rely on SDS used for past shipments; reconfirm based on the latest formulation. |
| Change in volume | Quantity classifications such as limited quantity or small quantity and packaging requirements may change. | Confirm container volume, number of outer packages, and total quantity. | Recheck dangerous goods declarations and packaging conditions. |
| Change in packaging type | Transport conditions may vary depending on whether the packaging is bottle, can, drum, aerosol, cartridge, etc. | Check the container, inner packaging, outer packaging, and requirement for UN-certified packaging. | Review SDS and packaging specifications after the packaging change. |
| Switching to aerosol form | Even with the same contents, it may be classified differently due to being a spray can. | Confirm SDS, UN number, air transport eligibility, and label requirements. | Avoid handling it the same way as regular liquid cargo. |
| Incorporation of batteries | It may require separate confirmation as lithium battery cargo. | Check battery type, watt-hour rating, quantity, and whether the batteries are installed in or packed with equipment. | Obtain product specifications and battery documentation. |
| Switching from sea to air transport | Acceptable for sea transport but possibly prohibited or conditionally accepted by air carriers. | Verify handling under IATA Dangerous Goods Regulations and airline-specific conditions. | Do not directly apply sea transport assessments to air transport cases. |
Even if there is a record of successfully transporting the same product before, reconfirmation is necessary if concentration, volume, packaging, or transport mode changes.
Cross-Checking SDS with Other Documents
The SDS should not be reviewed in isolation but cross-checked against the Dangerous Goods Declaration, invoice, packing list, physical labels, and non-dangerous goods certificates.
| Document | Items to Verify | Actions if Discrepancies Are Found | Contacts for Confirmation |
|---|---|---|---|
| Invoice | Verify product name, model number, commercial name, and manufacturer. | Confirm consistency with the product name on the SDS. | Shipper, manufacturer |
| Packing List | Check quantity, packaging type, containers, outer packaging, and weight. | Ensure these match the quantity and packaging conditions stated in the SDS and Dangerous Goods Declaration. | Shipper, warehouse, packer |
| Dangerous Goods Declaration | Verify UN number, proper shipping name, class, container category, quantity, and packaging. | Confirm alignment with Section 14 of the SDS. | Shipper, dangerous goods declarant, shipping line, airline |
| Physical Labels | Check GHS labeling, dangerous goods labels, UN number, and product name. | Verify there are no contradictions with the SDS or declaration. | Shipper, warehouse, delivery company |
| Non-Dangerous Goods Certificate | Confirm the basis for classifying the cargo as non-dangerous. | Ensure no contradictions with hazard information or transport data in the SDS. | Shipper, manufacturer |
| Photos of Outer Packaging | Inspect labels, marks, UN numbers, case marks, and container condition. | Make necessary corrections to markings or documentation before in-gate. | Shipper, warehouse, delivery company |
If inconsistencies are found among documents, confirm with the shipper or manufacturer to finalize classification and transport conditions before proceeding with arrangements.
When Only an English Version of the SDS Is Available
In export-import operations, it is sometimes the case that only an English version of the SDS created by the overseas manufacturer is obtainable.
Even in such cases, freight forwarders need to check the transport information section of the SDS and extract the UN number, hazard class, packaging group, marine pollutant status, and air transport conditions.
| Situation | Practical Response | Points to Note | Parties to Confirm With |
|---|---|---|---|
| Only English SDS available | Check the transport information section, and if necessary, request a Japanese version or translated documents from the shipper. | Ensure that internal staff, warehouses, customs brokers, and inland delivery can understand the content. | Shipper, importer, manufacturer |
| Transactions or management situations requiring a Japanese version | Confirm with the shipper or importer whether a Japanese SDS is available. | Legal compliance or domestic storage and handling explanations may be required. | Importer, shipper, manufacturer |
| Checking content based only on translation | Verify that the translation matches the transport information in the original SDS. | Pay close attention to the UN number, hazard class, packaging group, and possible mistranslations of negations. | Shipper, translator, dangerous goods specialist |
| Differences between overseas and Japanese versions | Compare revision dates, applicable products, ingredients, and transport information. | Confirm which is more recent and which corresponds to the actual cargo. | Shipper, importer, manufacturer |
Even when only the English SDS is available, confirming dangerous goods transport requirements should not be omitted. Verification with the shipper, manufacturer, importer, or dangerous goods specialists should be done as needed.
Comparison Table of Freight Forwarder Involvement
| Category | What Can Be Supported | What Should Not Be Concluded | Practical Responses |
|---|---|---|---|
| When Receiving an SDS | Confirm whether it is the latest version, matches the relevant product, and includes transport information in Section 14. | Concluding transport is possible based solely on the presence of an SDS. | Cross-check the transport information section, physical labels, and other documents. |
| When an MSDS Is Submitted | Confirm the creation date, revision date, relevant product, and whether a latest SDS is available. | Judging that the cargo is non-dangerous goods based only on an outdated MSDS. | Request the latest SDS from the shipper or manufacturer. |
| When the Transport Information Section Is Blank or Marked Not Applicable | Confirm the scope of non-applicability, transport modes, and availability of manufacturer confirmation documents. | Immediately judge the goods as regular cargo simply because the section is blank or not applicable. | Obtain dangerous goods classification materials, certificates of non-dangerous goods status, or manufacturer confirmations. |
| When GHS Labeling Is Present | Cross-check SDS Sections 2 and 14 with physical labels. | Concluding transport dangerous goods status solely based on GHS labeling. | Confirm dangerous goods applicability based on Section 14 and relevant transport regulations. |
| When Receiving a Dangerous Goods Declaration | Check consistency with the SDS, invoice, packing list, and physical markings. | Assuming that once a declaration is submitted, content verification is unnecessary. | Verify UN number, proper shipping name, quantity, and packaging format. |
| When Arranging Maritime Transport | Confirm the IMDG Code, shipping line, CFS, and dangerous goods warehouse conditions. | Assuming that shipment is possible solely because the SDS includes a UN number. | Check acceptance capability with the shipping line, CFS, and warehouse. |
| When Arranging Air Transport | Confirm IATA Dangerous Goods Regulations, airline, and courier company conditions. | Assuming that cargo accepted for sea transport will automatically be accepted by air. | Verify packaging standards, quantity limits, and carriage permission for air transport. |
| When There Are Inconsistencies in Documents or Physical Cargo | Identify inconsistencies and confirm with the shipper or manufacturer. | Submitting documents with unresolved contradictions to the shipping line or airline. | Finalize classification and transport conditions before proceeding with arrangements. |
Common Practical Issues
| Case | Issue | Documents / Parties to Check | Recommended Action |
|---|---|---|---|
| SDS is outdated and does not match current classification | The classification, regulations, or transport information may have been updated. | Latest SDS, revision date, confirmation with manufacturer | Obtain the latest SDS and confirm the revision date and transport information. |
| Transport information section is blank or marked "under review" | It is impossible to determine whether the cargo is classified as dangerous goods. | Shipper, manufacturer, dangerous goods classification references | Request dangerous goods classification documents or confirmation letters from the manufacturer. |
| Product name on invoice does not match the product name on the SDS | There is a possibility that the arrangement is based on an SDS for a different product. | Invoice, model number, manufacturer name, actual product label | Identify the actual product and obtain the correct SDS. |
| UN number on dangerous goods declaration differs from that on the SDS | The transport classification cannot be finalized, preventing shipping line or airline acceptance. | SDS, dangerous goods declaration, manufacturer confirmation | Confirm with the shipper or manufacturer and amend the SDS or declaration as necessary. |
| Cargo not allowed for air transport is booked on an air shipment | It may be acceptable by sea but could be prohibited for air carriage. | SDS, IATA Dangerous Goods Regulations, airline confirmation | Check the airline's acceptance conditions and consider sea transport or alternate routes. |
| Actual cargo has dangerous goods labels but the SDS shows non-applicability | The SDS may be outdated, for a different product, or there is inconsistency between the actual markings and documentation. | Photos of the actual cargo, labels, SDS, manufacturer confirmation letter | Cross-check actual cargo markings against the SDS and reassess classification if needed. |
| Previous SDS becomes invalid due to changes in mixture concentration | Changes in concentration can alter hazard properties and transport classification. | New formulation SDS, component information, dangerous goods classification documents | Obtain an SDS corresponding to the new formulation and reconfirm the dangerous goods classification. |
| Misreading of the English SDS leads to confusion about the UN number or negative statements | This could result in incorrect transport classification or declaration. | English SDS, Japanese translation, manufacturer confirmation | Cross-check the original and translated texts and confirm critical points with the shipper or manufacturer. |
Four-Column Checklist
| Verification Situation | Party to Confirm With | Check Items | Actions if Issues Are Found |
|---|---|---|---|
| Upon Receiving the SDS | Shipper / Manufacturer | Confirm whether it is the latest version, matches the target product, and check creation and revision dates. | If outdated or mismatched, request the latest SDS version to be resubmitted. |
| When Checking Section 14 | Shipper / Manufacturer / Dangerous Goods Specialist | Verify UN number, proper shipping name, hazard class, packaging group, and marine pollutant status. | If fields are blank or unclear, request dangerous goods classification documents or manufacturer confirmation. |
| If GHS Labeling Is Present | Shipper / Manufacturer | Check SDS Section 2, actual product labels, and Section 14 transport information. | Do not conclude transport dangerous goods status based on GHS labeling alone; verify the transport information section. |
| If Transport Information Section Indicates Non-Applicability | Shipper / Manufacturer | Confirm which transport modes (sea, air) the non-applicability applies to. | If the applicable mode is unclear, request manufacturer confirmation or a non-dangerous goods certificate. |
| When Cross-Checking with Dangerous Goods Declarations | Shipper / Dangerous Goods Declarant | Verify UN number, proper shipping name, class, quantity, packaging, and packing form. | If inconsistencies occur, amend either the declaration or SDS before submission. |
| When Arranging Maritime Transport | Shipping Line / NVOCC / CFS / Warehouse | Confirm handling per IMDG Code, whether CFS acceptance is possible, marine pollutant status, and compatibility for mixed loading. | If acceptance is refused, consider alternate CFS, dangerous goods warehouse, FCL selection, or next vessel options. |
| When Arranging Air Transport | Airline / Courier / Air Agent | Check handling according to IATA Dangerous Goods Regulations, packaging standards, quantity limits, and passenger aircraft acceptance. | If acceptance is denied, consider sea transport, alternate flights, cargo aircraft, or other airlines. |
| If Actual Labels and SDS Do Not Match | Shipper / Manufacturer / Warehouse | Verify actual product labels, GHS labeling, UN number, product name, and external markings. | Hold in-gate, loading, and shipment until documentation is corrected or re-evaluation is completed. |
Example 1: Case of Receiving an SDS with a Blank Transport Information Section
This case involves an SDS submitted by the shipper where Section 14 "Transport Information" is left blank, and the invoice description uses a chemical name.
In this situation, the absence of transport information should not be taken as a reason to classify the cargo as non-dangerous. The manufacturer may have omitted the transport details, the SDS could be an outdated version, or the transport conditions may not have been confirmed.
The freight forwarder should request the shipper to provide the latest SDS, manufacturer’s confirmation letter, dangerous goods classification documentation, or a non-dangerous goods certificate.
For maritime transport, the treatment under the IMDG Code should be confirmed; for air transport, confirmation under the IATA Dangerous Goods Regulations is necessary. It is important to retain clear evidence supporting the decision to handle the cargo as regular freight.
Example 2: Case Where the UN Number on the SDS Does Not Match the Dangerous Goods Declaration
In this case, the UN number listed in section 14 of the SDS differs from the UN number on the dangerous goods declaration.
Submitting such inconsistent documents to the shipping line or airline is likely to result in delays during document review. Possible causes include an SDS for a different product, an outdated SDS version, errors in declaration preparation, or classification changes.
The freight forwarder should verify with the shipper or manufacturer to confirm the correct product, the latest version of the SDS, the accurate UN number, the proper shipping name, hazard class, and packaging group.
After making corrections, the freight forwarder should cross-check the SDS, dangerous goods declaration, invoice, packing list, actual goods labels, and external markings, then reconfirm acceptance with the shipping line, airline, CFS, and warehouse.
Example 3: Product Previously Transported by Sea but with Changed Concentration
This involves a case where the shipper requested to handle cargo under the same conditions as before, based on a record of previous sea transport of the identical product name.
However, upon verification, the ingredient concentration had changed, and the formulation differed from the old SDS. Even with the same product name, changes in concentration, volume, or packaging form can affect flammability, corrosiveness, toxicity, environmental hazards, and whether it qualifies as dangerous goods for transport.
The freight forwarder should not rely solely on past records but must obtain the latest SDS reflecting the updated formulation, dangerous goods classification documents, and, if necessary, a confirmation letter from the manufacturer.
Based on that, the UN number, hazard class, packaging category, marine pollutant status, and acceptance by the shipping line, CFS, and warehouse should be reconfirmed.
Example 4: Case Where Only an English SDS Was Available and Transport Information Was Misinterpreted
In this case, only the English version of the SDS was submitted by the overseas manufacturer, and upon internal review of the transport information section, the UN number and hazard class were overlooked.
Even when only an English SDS is available, it does not justify skipping checks for dangerous goods transport. Expressions such as the UN number, Proper Shipping Name, Packing Group, Marine Pollutant status, and Not Regulated are directly relevant to transport decisions.
The freight forwarder should review the original transport information section and confirm with the shipper, importer, manufacturer, or dangerous goods specialists as necessary.
If it is necessary to share the information internally or with the warehouse, CFS, customs broker, or delivery parties, a Japanese version of the SDS or a verified translation should be requested to ensure consistency with the original document.
Points to Confirm with the Shipper
If the SDS is incomplete, the freight forwarder should request the shipper to provide a revised version, manufacturer confirmation, certificate of non-applicability as dangerous goods, test data, or other relevant documents.
- Is it the latest version of the SDS?
- Does the product name in the SDS match the actual product?
- Is there a Japanese version or a version that can be practically verified?
- Is the transport information section filled out?
- Are the UN number, proper shipping name, hazard class, and packaging group clearly stated?
- Does the product qualify as a marine pollutant?
- Are there differences in conditions between air and sea transport?
- If classified as non-dangerous goods, is there supporting documentation?
- Do the actual product labels and packaging markings match the SDS?
- Have concentration, quantity, packaging form, or transport mode changed since previous shipments?
It is especially important to clarify whether cargo is dangerous or not at the quotation and booking preparation stage, rather than after booking confirmation.
Common Misconceptions
| Misconception | Practical Consideration | What Should Be Checked |
|---|---|---|
| Receiving the SDS alone is enough to determine transport eligibility | The SDS is an initial reference; transport eligibility is determined by reviewing the transport information section, packaging, quantity, and acceptance conditions. | Confirm SDS Section 14, dangerous goods declaration, and shipping line or airline conditions. |
| If the transport information section is blank, the cargo is non-dangerous goods | A blank field does not necessarily mean the cargo is non-dangerous goods. | Check manufacturer confirmation, dangerous goods classification documents, and the latest SDS. |
| If it says "Not Applicable," the cargo is ordinary goods for all types of transport | Conditions may vary between maritime, air, domestic transport, and warehouse storage. | Confirm the applicable transport mode, IMDG Code, IATA Dangerous Goods Regulations, and warehouse conditions. |
| If there is GHS labeling, it is always dangerous goods for transport | GHS labeling indicates hazardous properties but does not necessarily match the designation of dangerous goods for transport. | Check Section 14 transport information, UN number, and hazard class. |
| An MSDS used in the past is acceptable | Old MSDS documents may not align with current classifications, laws, or transport details. | Confirm the latest SDS, revision date, and consistency with the product in question. |
| If a dangerous goods declaration is provided, cross-checking with the SDS is unnecessary | If the dangerous goods declaration and SDS do not match, carriers and airlines may halt acceptance. | Verify UN number, official shipping name, quantity, packaging, and form of cargo. |
| If the same product was previously shipped, the same handling can be applied this time | Changes in concentration, volume, packaging, or transport mode may affect handling. | Check the latest SDS, formulation, quantity, packaging, and transport mode. |
| Translating the English version of the SDS is sufficient | It is necessary to verify that the translation matches the original SDS regarding UN number, class, negative statements, and transport mode details. | Cross-check the original SDS, the translation, and manufacturer confirmations. |
Points Freight Forwarders Should Note
Freight forwarders should not assume everything is in order just because they have received the SDS. The crucial step is to verify that the SDS content matches the actual cargo, packaging, mode of transport, and terms of acceptance.
- Obtain the latest version of the SDS.
- Always check the transport information section in Section 14.
- Confirm the basis even if it is classified as non-dangerous goods.
- Separately verify conditions for maritime and air transport.
- Use Sections 3, 7, 9, 10, and 12 as supplementary reference.
- Cross-check information with the shipper, manufacturer, shipping line, airline, CFS, and warehouse.
- If there are uncertainties, consult with dangerous goods specialists or the shipping line/airline in advance.
- If only an English SDS is available, request a Japanese version or verification documents as needed.
Summary
An SDS (Safety Data Sheet) provides detailed information on the hazardous and harmful properties of chemicals, their composition, handling, storage, first aid measures, spill response, disposal, and transport information.
For practical freight forwarding operations, the SDS serves as an initial reference for dangerous goods transport. However, simply receiving an SDS does not automatically confirm whether transport is possible.
In transport operations, particular attention is given to Section 14—Transport Information—including the UN number, proper shipping name, hazard class, packaging group, marine pollutant status, and conditions for maritime and air transport. Additionally, supplementary checks are performed on Section 3—Composition, Section 7—Handling and Storage Conditions, Section 9—Physical and Chemical Properties, Section 10—Stability and Reactivity, and Section 12—Ecological Information.
The SDS becomes practically useful only when cross-checked with GHS labeling, dangerous goods declarations, invoices, packing lists, actual cargo labels, the IMDG Code, IATA Dangerous Goods Regulations, and acceptance criteria of shipping lines, airlines, CFS, and warehouses.
The key point of this article is to treat the SDS not merely as a chemical information sheet, but as an essential operational checkpoint connecting dangerous goods transport, non-dangerous goods determination, sea and air transport, CFS in-gate, and warehouse receipt processes.
