14.6. Special Precautions for User
This section provides information on special precautions that users must take or be aware of in relation to transport within or outside their premises. It covers regulatory requirements, practical measures, and best practices to ensure safe transport of dangerous goods in accordance with international regulations such as ADR, IMDG, IATA, and the UN Model Regulations.
Important for SDS compliance: Section 14.6 of a Safety Data Sheet must include any special precautions that a user needs to be aware of or comply with in connection with transport. This information is mandatory under REACH Annex II and is critical for ensuring safe transport operations.
What Are Special Precautions?
Special precautions for transport are specific measures, beyond standard handling procedures, that must be taken to ensure the safe transport of dangerous goods. These precautions address unique hazards or characteristics of the material that require additional attention during transport operations.
Special precautions may include:
- Specific handling requirements
- Temperature control needs
- Segregation from incompatible materials
- Special loading, unloading, or stowage procedures
- Emergency response considerations
- Personnel protection measures
- Special packaging or containment requirements
Regulatory Context
Special precautions are often linked to specific regulatory provisions:
Special Provisions
Alphanumeric codes in transport regulations (e.g., SP 274, SP 601) that specify additional requirements for particular dangerous goods.
Packing Instructions
Detailed requirements for packaging that may include special handling or operational provisions.
Stowage and Segregation
Requirements for how goods must be positioned during transport and kept separate from incompatible materials.
Limited/Excepted Quantities
Special provisions that apply when transporting smaller amounts of dangerous goods.
Mode-Specific Special Precautions
Road Transport (ADR)
- Vehicle marking and placarding requirements
- Tunnel restriction codes
- Driver training certifications
- Route restrictions
- Parking and supervision requirements
- Temperature monitoring for temperature-controlled transport
Sea Transport (IMDG)
- On-deck vs. under-deck stowage requirements
- Segregation from other dangerous goods
- Special stowage provisions
- EmS emergency response procedures
- Marine pollutant considerations
- Container packing certificates
Air Transport (IATA/ICAO)
- Passenger aircraft vs. cargo aircraft only restrictions
- Pressure differentials consideration
- Shipper's Declaration requirements
- Operator variations
- State variations
- Magnetized material precautions
Rail Transport (RID)
- Wagon marking requirements
- Shunting restrictions
- Special provisions for high-consequence dangerous goods
- Marshalling yard requirements
- Specific rail transport documentation
- Hot axle box detection systems
Temperature-Controlled Transport
Some substances require transport under controlled temperatures to prevent hazardous situations such as decomposition, polymerization, or pressure build-up.
Self-Reactive Substances
May require temperature control to prevent dangerous decomposition.
- Control temperature: Temperature at which emergency procedures should be implemented
- Emergency temperature: Temperature at which emergency procedures must be implemented
Organic Peroxides
Often require temperature control during transport to prevent hazardous decomposition.
- Refrigerated vehicles or containers may be required
- Temperature monitoring and recording systems
- Emergency response procedures for temperature control failure
Critical information for SDS: If a substance requires temperature control during transport, the control and emergency temperatures must be specified in Section 14.6 of the SDS.
Example: Temperature Control Requirements
For a Type B Self-reactive substance:
- Control temperature: +30°C
- Emergency temperature: +35°C
- Special precautions: Transport under refrigeration with temperature monitoring. Vehicle must be equipped with temperature recording devices and alarm systems.
Special Provision Codes
Special provision codes are alphanumeric designations in transport regulations that specify additional requirements or exemptions for particular dangerous goods. These codes are assigned in column 6 of the Dangerous Goods List in the UN Model Regulations and corresponding modal regulations.
| Code | Description | Impact |
|---|---|---|
| SP 274 | Requires the technical name to be included with the proper shipping name | Medium |
| SP 601 | Pharmaceutical products ready for use are not subject to the regulations | Low |
| SP 640 | Physical and technical characteristics requiring different tank types | Medium |
| SP 363 | Special provisions for machinery or apparatus containing dangerous goods | Medium |
| SP 375 | Environmentally hazardous substances in single/combination packagings ≤ 5L or 5kg not subject to other provisions | Low |
| SP 386 | Substances stabilized by temperature control not accepted for transport | High |
Note: Special provisions can vary between different transport regulations (ADR, IMDG, IATA). Always check the specific regulations applicable to your transport operation.
General Transport Precautions
Handling and Loading
- Secure packages to prevent movement during transport
- Maintain proper orientation of packages with orientation arrows
- Ensure proper weight distribution in the transport unit
- Verify compatibility with other cargo
- Check for leaks or damage before loading
- Use appropriate handling equipment
During Transport
- Maintain required temperature conditions
- Ensure proper ventilation if required
- Regularly check load security during longer journeys
- Monitor for leaks or container damage
- Follow designated routes if applicable
- Adhere to parking and supervision requirements
Documentation
- Carry all required transport documents
- Ensure emergency information is readily available
- Verify all documentation is complete and accurate
- Include any special instructions for carriers
- Provide emergency contact information
- Include temperature control records if applicable
Emergency Preparedness
- Carry appropriate emergency equipment
- Ensure drivers/operators are trained in emergency procedures
- Have spill control materials available
- Know emergency contact procedures
- Understand first aid measures for the material
- Have fire suppression equipment if required
Personal Protection During Transport Operations
Personnel involved in transport operations may need specific protective equipment based on the hazards of the materials being transported:
| Hazard Type | Recommended PPE | When Required |
|---|---|---|
| Toxic materials | Respiratory protection, chemical-resistant gloves, eye protection | During loading/unloading, handling damaged packages |
| Corrosive substances | Chemical-resistant gloves, face shield, chemical-resistant clothing | During loading/unloading, sampling, connecting/disconnecting transfer hoses |
| Flammable materials | Flame-resistant clothing, anti-static footwear | During bulk transfers, tank loading/unloading |
| Cryogenic liquids | Insulated gloves, face shield, protective apron | During loading/unloading, connecting/disconnecting transfer equipment |
Transport workers should be trained in the proper use of personal protective equipment and understand when it is required based on the materials being transported.
Case Study: Special Precautions for Lithium Batteries
Lithium batteries present unique hazards during transport and require specific precautions:
- Packaging: Must be packed to prevent short circuits and damage
- Documentation: Specific declarations and markings required
- Quantity limitations: Restrictions on number of batteries per package
- State of charge: Lithium ion batteries often limited to 30% state of charge for air transport
- Damaged batteries: Special provisions for transporting damaged or defective batteries
- Temperature sensitivity: Must be protected from extreme temperatures
These special precautions have been developed in response to numerous incidents involving lithium batteries in transport, including fires on cargo aircraft.
Training Requirements
Personnel involved in the transport of dangerous goods must receive appropriate training:
General Awareness Training
Basic understanding of dangerous goods regulations and hazard recognition.
Function-Specific Training
Detailed training on specific responsibilities and tasks related to dangerous goods transport.
Safety Training
Training on hazards, safe handling, and emergency procedures.
Security Training
Training on security risks and measures to reduce security vulnerabilities.
Important: Training requirements vary by transport mode and jurisdiction. For example, ADR requires drivers to hold a specialized dangerous goods driver training certificate, while air transport requires IATA DGR training certification.
Properly Completing Section 14.6 of an SDS
Example for a flammable liquid requiring temperature control:
14.6 Special precautions for user
- Transport within user's premises: Always transport in closed containers that are upright and secure.
- Temperature control required: Control temperature +10°C, Emergency temperature +15°C.
- Tunnel restriction code: (D/E)
- EmS: F-E, S-D
- Segregation group: None
- Special provision: 274, 601
Example for a non-temperature controlled dangerous good:
14.6 Special precautions for user
- Transport within user's premises: Always transport in closed containers that are upright and secure.
- Ensure containers are properly labeled and sealed.
- Ensure that persons transporting the product know what to do in the event of an accident or spillage.
- Tunnel restriction code: (C/D)
- EmS: F-A, S-B
Best Practice: When preparing a Safety Data Sheet, include all relevant special precautions that apply to the material. Consider all transport modes that might be used and include mode-specific information. If special provisions apply, list them with a brief explanation of their implications for the user.