(Feasibility study on making submission of Safety Data Sheet (SDS) as mandatory obligation.)
Q.
In order to have Safety Data Sheets (SDS) for shipments submitted by the Shipper in a timely manner, is it feasible to make the submission of SDS mandatory at time of delivering the cargo and related documents to the airline at the airport of departure. Please also advise if there are any points that may need to be addressed such as exception of certain shipments from this requirement? Kindly give us your advice.  (31 May 21)
A.
Shippers have a duty to fully explain his shipment in question.

On the bottom left of the DGD (left of shipper’s signature) there is a pre-printed statement that all entres are correct. A similar declaration is written on the front side of the AWB where the shipper places his signature. Also in DGR 1.3 the responsibility of the shipper is written in details. To demand submission of SDS on all the shipments is exercising the rules too far out. When there is a question on the shipment, the arline can demand submission of data, certificates, tests results and SDSs which the shipper would have to follow. If the shipper refuses to submit the required reference documents, the airline may refuse to carry the shipment. To demand submission of SDS for every shipment is going too far and considered as excessive practice. When there is a doubt about a shipment, the current practice is to ask for references which the shipper will comply.


In the case of a new product, due to patent rights, some shipper may be reluctant to produce the SDS. This is understandable, and the airline should be flexible and accept just the Transportation Section #14 of the SDS.

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