Section 14 of an SDS gives transport classification information, but the shipper remains responsible for correct classification under the IMDG Code. Section 14 should therefore be consistent with the physical, toxicological and environmental hazard data elsewhere in the SDS. A recently reviewed SDS shows why this matters.
That SDS assigns a solid product to UN 3077, ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S., Class 9, Packing Group III, marine pollutant, and claims relief under Special Provision 375 for packages of not more than 5 kg, which would leave those packages outside the other provisions of the Code. Section 11 of the same SDS reports an oral LD₅₀ of 283 mg/kg for the finished product. The product and manufacturer are not identified.
What Sections 11 and 14 say
| Section 11, Toxicological information | Section 14, Transport information |
|---|---|
| Acute oral toxicity | UN 3077 |
| Oral LD₅₀: 283 mg/kg, finished product | ENVIRONMENTALLY HAZARDOUS SUBSTANCE, SOLID, N.O.S. |
| Value reported for the finished product | Class 9, Packing Group III |
| Marine pollutant: yes | |
| Exemption claimed under SP 375 for packages of not more than 5 kg |
An oral LD₅₀ of 283 mg/kg falls inside the Class 6.1 range. Section 14 does not account for that hazard.
Class 6.1 oral toxicity criteria
LD₅₀ is the statistically estimated dose, in milligrams per kilogram of body weight, expected to kill half of a test population under stated conditions. IMDG Code paragraph 2.6.2.2.4.1 sets these oral toxicity limits for Class 6.1:
| Packing group | Oral LD₅₀ (mg/kg) |
|---|---|
| I | ≤ 5 |
| II | > 5 to ≤ 50 |
| III | > 50 to ≤ 300 |
283 mg/kg is in Packing Group III. If the SDS figure is accurate, the finished product meets the Class 6.1 oral criterion.
Why UN 3077 does not fit
IMDG Code paragraph 2.10.2.3 covers marine pollutants that also meet the classification criteria of Classes 1 to 8. They are transported under the entry that matches those other hazards. UN 3077 is for environmentally hazardous solids that meet no criterion of Classes 1 to 8, unless a more specific entry applies. A product with a Class 6.1 oral toxicity value cannot go under it on the strength of its environmental hazard.
The oral LD₅₀ establishes that the product meets the Class 6.1, Packing Group III toxicity criterion. Its final classification must also account for any other hazards. Under 2.0.1.5, a substance listed by name in the Dangerous Goods List takes its class, subsidiary hazards and packing group from that list. Under 2.0.1.6, dangerous goods that meet the criteria of more than one class or division and are not listed by name are assigned on the basis of the precedence of hazard provisions in 2.0.3.
The appropriate UN number must be determined from the chemical identity, composition and complete hazard profile. A specific named entry or another applicable generic or n.o.s. entry must be considered before selecting a general toxic solid n.o.s. entry such as UN 2811 (organic) or UN 3288 (inorganic). Where the selected n.o.s. entry is assigned SP 274 in column 6 of the Dangerous Goods List, the technical name is required. Marine pollutant status applies where its criteria are met.
Why SP 375 cannot be applied
SP 375 gives relief to UN 3077 and UN 3082 when the quantity and packaging conditions are met. For UN 3077 the limit is not more than 5 kg net mass per single or inner packaging, and the packagings must also meet the general provisions of 4.1.1.1, 4.1.1.2 and 4.1.1.4 to 4.1.1.8. The provision does not override Class 6.1 criteria, and it applies only if UN 3077 or UN 3082 is the correct classification.
Paragraph 2.10.2.7 is a different, narrower relief
Paragraph 2.10.2.7 provides limited relief for marine pollutants assigned to another hazard class when transported in qualifying small packages. The relief is subject to the quantity limits and conditions in 2.10.2.7 and concerns the marine pollutant provisions listed below. It does not remove the requirements applicable to Class 6.1. This differs from SP 375, which applies to UN 3077 and UN 3082.
| Paragraph | Subject |
|---|---|
| 5.2.1.6 | Marine pollutant mark on packages |
| 5.3.2.3 | Marine pollutant mark on cargo transport units |
| 5.4.1.4.3.6 | Marine pollutant information in the dangerous goods transport document |
| 7.1.4.2 | Marine pollutant stowage provisions |
Reading the other sections of the SDS
Other sections of the SDS should also be examined before seeking clarification from the manufacturer.
| SDS section | What to look for | Why it matters here |
|---|---|---|
| Section 2, Hazard identification | GHS acute oral toxicity category and hazard statement | Category 3 (H301) covers the same 50 to 300 mg/kg band as Packing Group III. If H301 is listed, it is further evidence that the Section 14 classification needs review. GHS and IMDG classification are separate systems |
| Section 3, Composition | Ingredients, concentrations and any acute toxicity estimate | Shows whether the product-level LD₅₀ is consistent with the ingredients and may help identify a technical name, though it may not be enough on its own to select the transport entry |
| Section 9, Physical and chemical properties | Physical state, flash point and other physical hazard data | A liquid assigned UN 3082 with a flash point at or below 60 °C (closed cup) meets the Class 3 criterion, so UN 3082 and SP 375 would not apply. Physical hazard data can defeat the assignment in the same way as toxicity data |
| Section 11, Toxicological information | Whether 283 mg/kg is a test result or a calculated value, and for which species and test | Establishes the basis of the figure the classification rests on |
| Section 12, Ecological information | Aquatic hazard data | Shows whether the marine pollutant criteria are met |
| Section 14, Transport information | UN number, class, packing group, special provisions | Check whether the stated transport classification is supported by the hazard data |
The shipper’s responsibility
Under IMDG Code paragraph 2.0.0.1, classification is the responsibility of the shipper or consignor, or of the competent authority where the Code says so. An SDS does not pass that responsibility to its author. Where the hazard information in an SDS conflicts with Section 14, the classification must be resolved before the consignment is offered for transport.
Ingredient-level toxicity figures cannot be carried straight over to a mixture. That point does not apply here, because the SDS states the LD₅₀ for the finished product. Until the manufacturer confirms the basis of that value and explains the choice of UN 3077, the SP 375 claim should not be relied on.
Checks before accepting an SP 375 claim from an SDS
The sequence applies to any SDS that claims SP 375 relief for UN 3077 or UN 3082. The toxicity steps reflect the SDS reviewed here; other hazard data, such as the flash point of a liquid, is read the same way.
| Step | Action |
|---|---|
| 1 | Read Section 11 for acute oral, dermal and inhalation values and compare them with 2.6.2.2.4.1 |
| 2 | Read Section 2 for H301, H311, H331 and the GHS category |
| 3 | Read Section 9 for physical state and flash point. For a liquid assigned UN 3082, a flash point at or below 60 °C (closed cup) points to Class 3 |
| 4 | Read Section 3 for composition; it may help identify a technical name but may not be enough to select the transport entry |
| 5 | Write to the manufacturer if Section 14 and the hazard data disagree, asking for the basis of the figure and a corrected transport classification |
| 6 | Do not offer the consignment as non-regulated under SP 375 until the classification is resolved. Where the marine pollutant criteria are met, apply the relevant provisions of Chapter 2.10, including any applicable relief under 2.10.2.7 |
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