SDS Section 14: Transport information

The one section written for somebody else

Every other section of a safety data sheet addresses the person who opens the container. Section 14 addresses the person who never opens it. REACH Annex II says so in its opening line: this section provides basic classification information for the transport or shipment of the substances or mixtures named in section 1, by road, rail, sea, inland waterways or air.

That word basic is doing real work. Section 14 summarises decisions taken elsewhere, under a different body of law, and copies them onto the sheet so that the people packing and dispatching the product can see them without going to the source. It is not the shipping paper and not a dangerous goods declaration; filling it in discharges nobody’s transport obligations. It tells a reader which regime the product falls into and gives them the values they need to look up the rest.

The transport class is not the GHS class

This is the mistake that dominates section 14, and it is worth stating flatly: the classification in 14.3 comes from a different system than the classification in section 2. A substance can be hazardous under one and not under the other, and neither result implies anything about the other.

The difference is structural, not cosmetic. Subsection 14.3 asks for the transport hazard class assigned on the basis of the predominant hazard the product presents under the UN Model Regulations, with subsidiary risks noted alongside. UN GHS Annex 4 uses the same phrasing — “the most predominant hazard”. One headline answer, chosen because a package can carry only so many placards and a responder at a roadside needs one dominant instruction.

Section 2 works the opposite way: it reports every hazard class and category the product meets, with no predominance rule and no ranking, because a worker handling the substance needs the complete picture.

The consequence follows directly. A product classified only for a long-term health endpoint can be undeniably hazardous in section 2 and carry no transport class at all, because carriage does not create that exposure. Equally, a material can be regulated in transport for a physical hazard that generates a modest GHS classification. “No UN number” is a statement about carriage, never a statement about safety.

The four identifiers: 14.1 to 14.4

14.1 — UN number or ID number

Regulation (EU) 2020/878 renamed this subsection. The 2015 text said “UN number”; the current heading reads “UN number or ID number”, and the body explains why: the identifier is the four-figure number of the substance, mixture or article preceded by the letters UN or ID, taken from the UN Model Regulations, the IMDG Code, ADR, RID, ADN or the ICAO Technical Instructions. Neither OSHA’s Appendix D nor UN GHS Annex 4 carries the alternative — both still print “UN number” alone. If you are comparing an EU sheet against a US one and the identifiers look different, this is the first place to check.

14.2 — UN proper shipping name

The EU text is unusually specific about where the name comes from — a named column of a named table in the Dangerous Goods List, supplemented with the technical name in brackets where that is required, and, for maritime carriage, with the IMDG technical name in addition. This is not a field the author writes; it is a field the author looks up.

Two conditionals also sit in this subsection, and both are easy to miss. The name need not be repeated here if it already served as the product identifier in subsection 1.1. And it need not be repeated per mode where the UN number and the name remain unchanged across modes — wording which quietly requires the author to have established that they do.

14.3 — Transport hazard class(es)

Class and subsidiary risks, on the predominance rule described above. The EU text then adds a requirement the US text has no counterpart to: for inland transport, the class assigned under ADR, RID and ADN is to be given as well. That is a second determination, not a restatement of the first.

14.4 — Packing group

Assigned to certain substances according to their degree of hazard. Both UN GHS Annex 4 and OSHA’s Appendix D keep the qualifier in the heading itself — “Packing group, if applicable” — while the EU moved it into the body of 14.4. A correctly completed section 14 will often say “not applicable” here, and that is a finding, not a gap.

Environment, precautions and bulk: 14.5 to 14.7

14.5 — Environmental hazards

Two questions, sourced from two different instruments and answered separately: one under the criteria of the UN Model Regulations as reflected in the inland regimes, one under the IMDG Code. UN GHS Annex 4 goes further on the maritime side, distinguishing a “marine pollutant” from a “severe marine pollutant”, and the EU adds a third case for products carried by inland waterway in tank-vessels.

OSHA’s version of the same item is “Environmental hazards (e.g., Marine pollutant (Yes/No))”. The illustration is a binary because Appendix D does not enforce the section — and a sheet written to that example, then shipped into the EU, will be short of answers.

14.6 — Special precautions for user

Any precaution a user should or must take, or be aware of, in connection with transport or conveyance — within or outside their premises. The premises wording matters more than it looks: moving a drum across a site is inside the scope of this subsection, which is why it interacts with section 7 rather than standing apart from it. The EU adds “for all relevant modes of transport”; OSHA does not.

14.7 — Maritime transport in bulk according to IMO instruments

The second heading Regulation (EU) 2020/878 renamed. The 2015 text confined it to “Annex II of Marpol and the IBC Code”; the current subsection is triggered by a considerably wider set of IMO instruments, listed in the checklist above.

It is also the only subsection in section 14 with a hard on/off switch, and the only one whose required content turns on the physical form of the cargo — liquid, solid and liquefied gas each get a different answer — rather than on the hazard. That is why “not applicable” is both the commonest and frequently the correct entry here: bulk carriage is a way of shipping, not a property of the product, and most products are never offered that way.

The section OSHA does not enforce

Appendix D prints the heading as “14. Transport information (Non-mandatory)”, and OSHA’s own guidance is that it does not enforce the content of sections 12 to 15 because those areas are handled by other agencies. For transport that agency is the US Department of Transportation, whose Hazardous Materials Regulations designate what is a hazardous material for carriage; the Hazardous Materials Table at 49 CFR 172.101 assigns proper shipping names, hazard classes, identification numbers and packing groups.

The practical reading is narrow. Section 14 on a US sheet is informational: nothing in it is enforced by the Hazard Communication Standard, and nothing missing from it excuses a transport duty that exists independently of the sheet. On an EU sheet the same seven subsections are a supplier obligation. The same page of the same document carries different legal weight on the two sides of the Atlantic.

How section 14 connects to the rest of the sheet

• Section 1 is cross-referenced twice by name: 14.2 lets the shipping name be omitted where it was used as the product identifier in 1.1, and 14.7 asks for the bulk product name only where it differs from the one given there.
• Section 2 holds the GHS classification, which is a different system with different criteria — the single most common misreading of this section.
• Section 9 holds the measured properties a transport classification is reasoned from. Where section 9 and section 14 imply different things about the same product, one of them has not been reviewed.
• Section 12 holds the ecotoxicity data behind the environmental determinations reported in 14.5. Section 12 has the evidence; 14.5 has the transport consequence.
• Section 13 covers what happens to residues and contaminated packaging — which then have to travel, under the precautions 14.6 covers, whether they leave the premises or not.
• Section 16 carries the revision date, and section 14 is the section most exposed to it: the transport instruments named in 14.1 to 14.7 are external documents with their own editions.

What a good section 14 looks like

1. Can you tell which regime each value belongs to? A bare class number says nothing about whether the author checked the inland, maritime and air regimes separately. The EU text requires the inland class alongside the UN Model Regulations class precisely because the answers can differ.
2. Does it say something in every subsection, including the ones that do not apply? “Not classified as dangerous goods for transport” and “14.7 — not applicable, product not carried in bulk” are complete answers. Empty fields are not, and GHS Annex 4 is explicit that a lack of relevance must be stated.
3. Does it agree with sections 2, 9 and 12 without pretending to be them? Section 14 should be reconcilable with the classification and the data elsewhere on the sheet, and it should never be the place a reader learns for the first time whether the product is hazardous.