Two years ago transshipments of bottled Scotch Whiskey from Hong Kong to other locations via mother vessels and feeder vessels ran into a major gridlock due to carriers insisting Safety Data Sheet (SDS) to accompany the consignments. I had written an article during that period.
This requirement of SDS for bottled Alcoholic Beverages pops up again and again causing delay to shipments, predominantly in Asia hence here is the clarification once again.
Let us first 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%).
The danger of whiskey during transportation is the flammability of same. Flashpoint of distilled beverages varies according to Alcohol by Volume (ABV) in it.
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 liters.
Hence, Scotch Whiskey packed in bottles further placed in cartons are not subject to any provisions of IMDG Code for sea transport.
Why Carriers ask for SDS?
Self believe carriers asking SDS for whiskey is due to some misunderstanding of the provisions of IMDG Code in the booking desk or approval desk of certain shipping lines. Unless SDS do increase the safety by assisting with additional information in case of an incident involving fire, which it does not.
How to resolve this situation?
In case any shipping line ask for SDS for shipment of bottled whiskey shipper can offer
- SDS, if same is available, or;
- A non-hazardous declaration quoting special provision 145 of IMDG Code, or
- Prepare SDS and submit, carriers’ commercial decision for documents demanded cannot be overruled.
This is applicable to all Alcoholic Beverages falling under PG III of UN 3065, be it Vodka, Rum, Gin, Raki or anything. Here “Ghost” is the SDS not Jim Beam Jacob’s Ghost White Whiskey!
But, did you know that shipper can still offer bottled whiskey as Dangerous Goods in Limited Quantities?
Above misunderstanding reiterates the requirement of Training in IMDG Code or should one ask for Safety Data Sheet and read it before taking a shot of whiskey?