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or wrong classifications, mismatch between product form and SDS (powder vs aerosol, solids on ethanol), outdated or un-updated Section 14 entries after reformulation, and confusing or mode-specific exception claims (limited quantity, accepted quantity, consumer commodity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 Resources00:37 Meet Ken Sumner02:09 Why SDS Transport Data Fails05:05 How Ken Verifies Classifications07:57 Hand Sanitizer Case Studies11:11 When Testing Data Is Missing16:01 More Real World SDS Disconnects22:33 Exceptions Limited Quantity Confusion26:04 GHS Pictograms vs DOT EPA29:03 Environmental Hazard Nuances30:00 SDS Catch All Pitfalls31:19 AI Needs Human Judgment31:59 Warehouse Mercury Lesson33:37 Packaging From Section 1436:12 Accepted Quantity Testing38:45 Drop Stack Test Demo42:27 Documenting Your System44:05 Keeping SDS Current47:29 Trade Secrets Controlled Drugs52:43 Where to Include SDS57:48 Trust But Verify Wrap Up