A safety data sheet (Turkish abbreviation GBF, English SDS) is a document that describes the hazards of a dangerous substance or mixture, its safe handling and emergency measures under 16 standard headings. In transport, section 14 is used most: the UN number, proper shipping name, class and packing group are given here and form the basis for ADR classification.
Which headings does an SDS consist of?
In Türkiye, the content of the SDS is set by the Regulation on Safety Data Sheets for Hazardous Substances and Mixtures (Zararlı Maddeler ve Karışımlara İlişkin Güvenlik Bilgi Formları Hakkında Yönetmelik, Official Gazette 13.12.2014, No. 29204) and the Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (KKDİK, Official Gazette 23.06.2017, No. 30105 repeated). The headings are fixed; their names, numbers and order cannot be changed:
- Identification of the substance/mixture and of the company
- Hazards identification
- Composition/information on ingredients
- First-aid measures
- Firefighting measures
- Accidental release measures
- Handling and storage
- Exposure controls/personal protection
- Physical and chemical properties
- Stability and reactivity
- Toxicological information
- Ecological information
- Disposal considerations
- Transport information
- Regulatory information
- Other information
Why is section 14 decisive in transport?
The transport information section contains the UN number, the UN proper shipping name, the transport hazard class, the packing group, environmental hazards, special precautions for the user and, where applicable, bulk sea transport according to IMO instruments. The forwarder and carrier match this information against ADR Table A to determine the labels, packing instruction, transport category and tunnel code.
Section 14 should not be read on its own. The hazard classification in section 2 follows the GHS/CLP system, while section 14 follows transport legislation; the two systems can give different results for the same substance. For example, a resin classified as a skin sensitiser may not count as dangerous goods in transport. The difference is explained in the entry on GHS/CLP labels vs ADR labels. The flash point in section 9 and the class in section 14 must also be consistent: for a liquid with a flash point below 23 °C, the statement "not dangerous for transport" is a sign of an error.
Who prepares and updates the SDS?
- Responsible party: The supplier placing the substance on the market, i.e. the manufacturer, importer or distributor.
- Preparer: An SDS preparer certified by a certification body. An importer also has the SDS of the imported product prepared by persons with the same qualification.
- Language: Turkish. A translation of a foreign-language SDS alone is not sufficient.
- Delivery: Provided to the recipient free of charge, in writing or electronically.
- Update: Carried out without delay when new information or a restriction affecting risk management emerges. Under the 2014 regulation, the updated sheet is sent within one month to recipients who have received the product in the last 12 months.
Where is the SDS required during transport?
The consignor carries out the classification based on the SDS; the dangerous goods safety adviser also uses the same document when assessing the company's activities. The Regulation on the Carriage of Dangerous Goods by Road (Tehlikeli Maddelerin Karayoluyla Taşınması Hakkında Yönetmelik) requires the consignor or carrier to present the SDS in printed or digital form if the contents are suspect during a roadside inspection. In storage, sections 7 and 10 are the basis for racking and segregation decisions; the rules are in the entry on dangerous goods storage rules. In dangerous goods (ADR) transport, pricing and vehicle planning cannot be done without reading section 14 of the SDS either.
Common mistakes
- Shipping with an old SDS even though the formulation has changed
- Leaving section 14 blank; if no information applies, the regulation requires the reason to be stated with wording such as "not applicable"
- The product's trade name not matching the name in the SDS
- Using a single sheet for different concentrations of the same product