Recently movement of bottled Scotch Whiskey from Hong Kong to other locations via ocean going vessels and feeder vessels are getting delayed due to shippers insisting Material Safety Data Sheet to accompany the consignments.
Let us look at the classification criteria of Dangerous Goods Transport regulations for Scotch Whiskey and analyze what is the basis of above requirement whether it is necessary or not.
In Dangerous Goods Regulations Alcoholic Beverages are listed under UN Number 3065 as below
- UN 3065, Packing Group II , ALCOHOLIC BEVERAGES with more than 70% alcohol by volume
- UN 3065, Packing Group III, ALCOHOLIC BEVERAGES, with more than 24% but not more than 70% alcohol by volume
Scotch Whiskey falls under second entry, Packing Group III, (more than 24% but not more than 70%)
Below are the entries in Dangerous Goods Regulations with special provisions for UN 3065 Packing group III
Above clearly states that, as per special provision 145, Scotch Whiskey, falling under UN 3065 Packing Group III, is not subject to provisions of IMDG Code if capacity per receptacle is less than 250 litres.
Hence, Scotch Whiskey packed in bottles further placed in cartons are not subject to any provisions of IMDG Code for sea transport.
Why shippers are insisting for MSDS?
Self believe this sudden requirement of MSDS asked by Hong Kong shippers are due to the same being asked by some of the shipping shipping lines. Somewhere in the booking desk or approval desk of certain shipping lines misunderstanding of the provisions of IMDG Code has demanded the MSDS for verification and this has sent a wrong message among shippers that all shipping lines need MSDS for transport of bottled Scotch Whiskey.
How to resolve this situation?
In case any shipping line ask for MSDS for shipment of bottled whiskey shipper can offer a non-hazardous declaration quoting special provision 145 of IMDG Code.
Above misunderstanding reiterates the requirement of Training in IMDG Code.