Welcome to the July issue of the NCEC newsletter.
Earlier this month, the Olympic torch relay passed close to us as it travelled through Oxfordshire. These events have been real crowd pullers throughout the UK and I was lucky enough to be one of those who sampled the wonderful atmosphere generated by the throngs of people lining the route in Chipping Campden. Of course, any event that draws a lot of people requires meticulous planning. I was able to experience the amazing level of cooperation between the organisers and the
emergency services to ensure that the event proceeded safely and successfully. You never like to tempt fate but, by the time the next newsletter is published in September, we hope to be able to report on a successful performance by Team GB and the multi-agency emergency response teams. I’m sure you’ll join me in wishing good luck – not only to all of the athletes, but also to those working at the event or behind the scenes.
In the last newsletter, I mentioned the consultation exercise on emergency action codes (EAC). I’m pleased to say that we received many responses offering thought-provoking opinions. This was the first major consultation exercise carried out since EAC was introduced in the 1970s. As a result, we’ve realised that it is going to take a little longer to complete the thorough consultation than originally planned. In addition, we have decided to ask some new, specific questions. Because of this, the consultation has been reopened and will close at the end of September. If you’ve already sent in your views, then we will still take them into consideration, but you are welcome to offer any further views on the latest questions.
This issue includes an overview of the Classification, Labelling and Packaging of Substances and Mixtures (CLP Regulation), including the reasons for its implementation, what changes have already been made regarding product labelling and safety data sheets (SDS), and what changes are still to be made. There is also a link to the latest guidance on SDS extended exposure scenarios. If you’re still unclear about what the CLP Regulation means to you, you can talk to us and we can help you.
In a new development, we are pleased to be offering some free webinar ‘taster’ sessions for our ‘COSHH Assessments’ and ‘First Aid for Chemical Exposures’ training courses. Make sure you check out the dates in August and September. Speaking of dates, we now have a venue and dates for Hazmat 2013 – and the first delegate has already registered!
Our satisfaction survey highlighted that you would like us to include regulatory updates in the newsletter. Therefore, in this issue, we have provided details about the Government’s recent announcement that it intends to introduce mandatory reporting from April 2013 for all UK companies listed on the Main Market of the London Stock Exchange.
We also have our usual round-up of interesting calls that our Emergency responders have dealt with
If, after reading this newsletter, you would like to know more about the work of the NCEC, please visit our website or contact us via email or phone. The social networkers among you can also follow me on Twitter (@BillNCECHazmat).
Bill Atkinson, Knowledge Leader
CLP overview and update
In May’s newsletter, we provided an update on the REACH regulation and its impact on safety data sheets (SDS). This month, we thought it important to carry out a review of the Classification, Labelling and Packaging of Substances and Mixtures Regulation (CLP) and the status of the phase-in schedule as it progresses towards completion in June 2015.
The CLP was published in December 2008 and entered into legal effect in all EU Member States on 20 January 2009, subject to a lengthy transitional period. It defines the requirements for the classification and labelling of hazardous chemical products in Europe. It replaces two pieces of legislation that had covered these requirements – The Dangerous Substances Directive (DSD) and The Dangerous Preparations Directive (DPD).
Why change the regulations?
The old DSD and DPD regulations were generally well understood and end-users of the products were familiar with the symbols on labels, and with the risk and safety phrasing. So, why fundamentally change the requirements?
The CLP is the European implementation of the United Nations Globally Harmonised System of Classification and Labelling of Chemicals (GHS). GHS aims to set a standard approach to chemical hazard evaluation and communication that can be adopted by countries around the globe. The EU is going through the process of adopting GHS now – other countries have either completed their implementation (e.g. South Korea) or are in the early stages (e.g. USA).
What changes have we already seen?
We are already seeing changes to the language of chemical hazard communication, with key elements of the changes described below:
Symbol → Pictogram
Risk Phrase → Hazard Statement
Safety Phrase → Precautionary Statement
The CLP also introduced a completely new requirement to notify the European Chemicals Association (ECHA) of classification of substances that are being put onto the European market to ECHA. This notification is applicable to substances placed on the market as a single substance – or when they are present in mixtures. For hazardous substances, it is also important to note that there is no minimum tonnage you have to exceed before notification is required. The notification requirement came into force in December 2010, with a one-month window during which the notification must be made. So, notifications for substances already on the market were required by the start of January 2011 and it continues to be a requirement for a company to notify any new substances it places onto the European market within a 1-month period.
The deadline to update labels for substances to CLP requirements was also December 2010. The only exception is for products that were already packaged, labelled and on the market in December 2010. For these products, the date is extended to December 2012.
What transitions are still to come?
A major change that is still to be implemented as a result of the CLP is the reclassification and labelling of mixtures. The deadline date for this change is June 2015. Again, there is extra time available for products that are already packaged, labelled and on the market in 2015. For these products, the date is extended to June 2017.
The regulators understand that people will want to make reference to both the old and new regulations until people become completely familiar with the CLP Regulation and that, in some cases, information from the old classification system is required to meet the requirements of other regulations (e.g. The Seveso Directive).
Therefore, specific guidelines on how the SDS has to be updated to include the CLP and/or DSD or DPD clssification information are also provided.
The table below summarises the requirements.
|Substances||Mixture DPD label||Mixture CLP label|
Label information - CLP
Classification - CLP and DSD required
Label information - DPD
Classification - DPD
DSD classification for hazardous substances
CLP classification also required, where available
CLP label information may also be shown.Â Recommnended in section 16
Label information - CLP
Classification - CLP and DPD required
DSD and CLP classification for hazardous substances
When put together with the more detailed requirements on the overall content and structure of the SDS introduced by the new REACH Annex II, it is clearly a hugely demanding time for companies to meet their chemical hazard communication commitments. If you would like to talk to one of our consultants about this topic, then please ring us on 0870 190 6621.
The ECHA has published a practical guide for downstream users on exposure scenarios. The new guide provides tips for checking whether the uses and use conditions of a chemical substance are covered by exposure scenarios provided by suppliers with the SDS. It includes advice on the action to take based on the outcome of this check.
With the London 2012 Olympic Games underway. The eyes of the world are on our country as we host the biggest sporting occasion on the planet. A huge amount of planning has gone into the Games and the building of the venues. Less obvious to the public eye, but just as important, has been the activities behind the scenes to ensure the resilience of the event. NCEC is a key resource to the emergency services and as always are on standby if our services are needed.
The Olympic torch relay has provided a rehearsal for this multi-agency resilience and a wonderful occasion for the crowds attending the route. We hope that those of you in the UK managed to see the torch and we all get to enjoy a successful Games.
Even the planning of the flight from Greece to the UK with the Olympic flame had to consider the relevant dangerous goods regulations. As reported in the article www.bbc.co.uk/news/uk-18006750 a safety assessment by British Airways's Dangerous Goods Team was required prior to the flight taking place. A special provision exists in the IATA Dangerous Goods Regulations detailing the requirements for carrying a ‘symbolic flame’ on board an aircraft. This includes arrangement for supervision of the flame and the placement of fire extinguishers.
With the Olympic Games underway and the additional transportation and security issues it brings, it is a good time to double check that dangerous goods consignments are correctly classified, labelled and the associated documentation is up to date and accurate.
To give you an idea of what an NCEC training course is like, we will be providing some free ‘taster’ sessions during August and September.
These will take the form of half-hour webinars, which will give you the opportunity to watch and listen to excerpts from two of our courses – COSHH Assessments and First Aid for Chemical Exposures.
The taster sessions will be run on Thursday 23 August and Thursday 13 September with one in the morning and one in the afternoon of each day.
Places are limited, so for more information on how to join in, please contact us on 0870 190 6621 or email (email@example.com).
At Hazmat 2012 in March, NCEC launched a consultation exercise on EACs. As expected, the respondents were overwhelmingly based in the UK, but were drawn from a mixture of emergency responders, those who handle dangerous goods or deliver training. The results of the consultation and comments made (with minor edits for clarity) are presented here.
Question 1: Do you think that the EAC is still an appropriate emergency response tool?
There was a clear majority - 73% to 27% - who agreed that the EAC is still an appropriate emergency response tool. Those agreeing with this statement were mostly involved in emergency response, exactly the people the code is aimed at.
Question 2: Should the existing EAC system be changed?Â If YES then how?
This question saw a clear majority in favour of changing the existing system. Some of those who wanted to change it were in favour of adopting the ADR Hazard Identification Number (HIN) system – sometimes referred to as the ‘Kemler’ system. For example, “we are in Europe and the current, old-fashioned and outdated EAC should be scrapped… let’s get real and modernise” and “ADR in Europe is so simple to use and is understood by all who come into contact with chemicals”. Two respondents also commented that EACs were no longer appropriate due to developments in communication technology, the introduction of smartphone apps, such as Chemdata®, and increased use of, and access to, the internet.
However, the majority opinion favoured retaining the EAC. The most powerful comment to this effect came from an Australian fire service “it was commented that if the EAC is discontinued it would result in having to undo 30 years of training and ingrained culture”. But even those who favoured retaining the EAC were seemingly aware of its limitations and contradictions (some of which had been pointed out in the initial consultation), and the need for training in understanding these points. This was most succinctly put by a UK firefighter “EAC is a very good starter for emergency responders. It is, however, crucial that on-going training emphasises that the EAC is a guide for the first few minutes of any incident (e.g. snatch rescue) and that it is designed to apply to bulk loads. Many people in my experience… will attempt to use it to run a protracted incident rather than seeking further, more detailed advice as the incident develops. Also, I have seen things such as PPE and decontamination advice rigidly applied to a very small spillage or leak, when it is clear that the EAC is aimed at a bulk-load-sized incident.”
Many of the users gave some quite detailed comments, which were very much appreciated and will be absorbed. They also highlighted some further issues, such as “the letter ‘E’ is not well understood by many responders”. Similarly, “some police and fire service personnel still think the ‘E’ means evacuate”. More supportive comments included “EAC gives excellent first-response information for the firefighter [with] no expertise [enabling them] to assist with a chemical” and “In our opinion, the EAC is a far better system than the HIN numbers. General training on the system seems to vary across services. Some of the problems or lack of understanding of the system could be achieved by better training. This is assisted, in part, by the visits that NCEC undertakes to various fire and rescue services”.
Personal protection issues
One of the issues raised in the initial consultation was that, while EAC advice commonly stipulates liquid-tight chemical protective clothing (LTS), this is not carried by UK fire services which, instead, revert to gas-tight suits (GTS). However, deploying in GTS is not an initial action. Not many respondents dealt with this issue head-on. One exception was a UK metropolitan fire service “While the donning of GTS may take several minutes, we feel that this is an initial action as it will be an essential part of the emergency response process”. Intriguingly, the same fire service also suggested the use of other respiratory protection (not breathing apparatus) in hotzone working. Others suggested adding the Additional Personal Protection (APP) code and the alcohol resistant ‘dot’ to the Hazchem plate.
So where is this all going?
The short answer is – it is still to be decided. It is clear that the EAC remains a popular means of easily communicating actions to take during incidents involving hazardous or dangerous goods. However, many think the system could, or even should, be changed, but it isn’t clear exactly how it should be changed. This is why we have decided to reopen the consultation and ask further, specific questions. These questions are in a new questionnaire on the NCEC website.
Do I need to respond to the second consultation if I have already made a submission to the first consultation?
It is not necessary to respond a second time unless you have anything specific to add to your earlier submission. Many of the initial respondents did indicate their willingness to be involved further in the process of reviewing EAC. We will be in contact with those people separately.
As a final word, NCEC staff would like to offer their sincere thanks to those who went to the trouble of submitting so many insightful and thoughtful comments. Whatever the outcome, it has been a valuable learning experience in informing us of how EAC is viewed and valued.
Return to top/contents
Under a scheme announced by Deputy Prime Minister Nick Clegg at the Rio+20 Summit, all UK firms listed on the Main Market of the London Stock Exchange will have to report their levels of greenhouse gas emissions in their annual reports.
Mr Clegg said “British companies need to reduce their harmful emissions for the benefit of the planet, but many back our plans because being energy efficient makes good business sense too. It saves companies money on energy bills, improves their reputation with customers and helps them manage their long-term costs too”.
The announcement, the most stringent in the world, will see the UK become the first country to make it compulsory for listed companies to include emissions data in annual reports.
Many businesses claim they are already reporting some of this information, which enhances their corporate reputation. However, with the introduction of mandatory reporting it will be even more important to get it right and provide information upon which investors can base their decisions.
The Environment Agency’s most recent report on environmental disclosures by quoted companies shows that in 2009/10 annual reports, only 22% were reporting, this information in accordance with Government guidance. This shows that even the most proactive quoted businesses may need to reconsider their approach to annual reporting when the new rules come in to force.
A number of things will now happen
In the autumn, we expect to see a formal published consultation, which will lead to a statutory instrument being laid before parliament in early 2013. Then, at the end of that year (or early 2014), there will be updates on the current guidance documentation on how to measure and report greenhouse gas emissions.
The scheme could also be extended to all large UK businesses over the next 4 years as a way to calculate green taxes. Ministers will review the regulations in 2015 to decide whether to extend them to privately owned companies.
NCEC is part of the AEA group, AEA has an active team working in the areas of energy and climate change. If you'd like more information on how to respond to mandatory reporting please contact us.
To read the full announcement visit: www.defra.gov.uk/environment/economy/business-efficiency/reporting/
To read the full announcement visit: www.defra.gov.uk/environment/economy/business-efficiency/reporting/
Helen Walker joined NCEC as an Emergency Responder this month. She graduated from the University of Leeds in June last year with a Bachelors in Chemical Engineering.
Helen was working for Anglian Water as part of its wholesome water quality checking process prior to joining the NCEC. Outside of work Helen has a keen interest in canoeing and kayaking, and has been teaching both for a number of years.
Polyurethane foam manufacturing fire
NCEC recently received a call from a fire and rescue service station manager who was dealing with a major fire at a factory where polyurethane foams were manufactured. Police and ambulance service personnel were also in attendance. The station manager was concerned about the chemicals used in the process – isocyanate solutions, polyols and solvents. He wanted advice about the hazards, thermal decomposition products, personal protective equipment (PPE) and decontamination.
Our Emergency Responder advised the station manager that the isocyanate solutions posed the greatest hazard and explained that they were flammable, toxic, irritant, skin sensitising and hazardous to the environment, and that they may be absorbed through the skin. Our Emergency Responder also explained that hydrogen cyanide and nitrogen oxides were likely products of thermal decomposition. The emergency action code for isocyanate solutions is 2X. Therefore, the Emergency Responder advised the use of liquid-tight chemical protective clothing with breathing apparatus and explained that soap and water should be used for decontamination of equipment. In addition, our Emergency Responder liaised directly with the manufacturer of the products to provide the most up-to-date safety data sheets to the fire and rescue service.
NCEC’s chemists work closely with the emergency services and the chemicals industry to provide impartial expert advice in the event of a chemical incident.
Overheated lithium battery
A lithium battery measuring 25 x 20 cm was undergoing testing at an electrical equipment testing company. It overheated on a workbench and released smoke and fumes. The fire and rescue service was in attendance and had evacuated the building. A fire fighter contacted NCEC for advice on the level of PPE required to enter the building and isolate the battery, and the decomposition products.
Our Emergency Responder explained that different types of lithium battery would produce different decomposition products, but inhalation of metal oxides can cause metal fume fever, which has a delayed onset and causes flu-like symptoms. The Emergency Responder recommended suitable PPE including breathing apparatus, in accordance with the emergency action code (4W) for lithium batteries.
Furthermore, our Emergency Responder advised the firefighter that dry agents, such as sand, should be used to smother the battery fire and that the area should be thoroughly ventilated before employees were allowed back into the building.
NCEC can provide guidance to companies on the safe handling and transportation of lithium batteries, and offers an emergency telephone advice service that is dedicated to providing advice on lithium batteries. For more information, please call 0870 190 6621 or email (firstname.lastname@example.org).
UN2927 drums washed up on beach
NCEC recently received a call from a fire and rescue service group manager who was working with the police to deal with 12 drums that had been washed up on a beach and were labelled UN2927 (toxic liquid, corrosive, organic, N.O.S.).
Our Emergency Responder advised the caller that if the drums had been at sea for some time, it was likely that the original contents had been displaced by sea water, but urged caution as drums were sometimes used to illegally dispose of hazardous waste. The Emergency Responder recommended that people be kept upwind and that investigating officers wear gas-tight chemical protective clothing with breathing apparatus until the exact nature of the drum contents could be established. Eleven of the drums were found to be empty and the twelfth contained engine oil.
Our Emergency Responders are available 24 hours a day, 365 days a year to provide chemical advice to the emergency services, helping them to protect people, property and the environment.
Global Regulatory Compliance Seminars, 11-20 September 2012
NCEC is presenting at the Global Regulatory Compliance seminars this autumn. Please visit www.cvent.com/d/qcqzgb/1Q for more information.
The seminars are hosted by our partners, The Wercs, and focus on the latest regulatory compliance topics impacting all global manufacturers, distributors, consumers and users of chemicals today.
NCEC will be presenting alongside Chemadvisor, Royal Haskoning and The Wercs, with topics including the USA adoption of the Globally Harmonised System (GHS) and extended safety data sheets.
The Emergency Services Show, Stonleigh Park, Conventry, 21-22 Nov 2012
NCEC is pleased to announce that Hazmat 2013 will be held on the 7 and 8 March 2013 at Eastwood Hall, Nottingham.
Now in its 6th year, the Hazmat conference is an essential opportunity for Hazmat specialists to share experiences and knowledge with like-minded professionals working in the hazmat and chemical incident industry. The conference draws on the knowledge and experience of a range of hazmat professionals and industry leaders, as well as that of NCEC's own Emergency Responders and experts.
Using delegate feedback gathered at the previous conference, Hazmat 2013 will now incorporate interactive syndicate exercises and workshops on a cross-section of subjects as part of the two-day conference. We intend to run parallel, themed, syndicate exercises and will be working with our exhibitors so that you will also have access to relevant equipment to gain some hands-on experience of how the equipment works.
Delegates will have the opportunity to register for specific workshops and syndicate exercises nearer the event, when the topics have been finalised. Registration for the conference has now opened and further details are available on our website including the super-early-bird rate which is applicable until 30 September.
A summary of the 2012 conference is also available on our website.
Chemical Spill Response
5 September 2012 -Gemini Building, Harwell
A one-day training course that is ideal for those who are considering setting up, or already have, a spill response team in their workplace.
Cost: £265 +VAT
Hazmat 1st Response
6 September 2012 - Gemini Building, Harwell
A one-day training course to prepare you and your organisation for dealing with a chemical incident. The course provides practical and up-to-date information on what is expected of you during a hazmat incident.
Cost: £235 + VAT
First Aid for Chemical Exposure
25 September 2012 - Gemini Building, Harwell
Our First Aid for Chemical Exposures course combines first aid with chemical hazard awareness, and is aimed at those who work with chemicals or work in an environment where chemicals are handled.
Cost: £265 +VAT
To book a place, please contact us on 0870 190 6621 and/or email email@example.com
[end of newsletter]
- CLP Regulation overview and update
- Other legislation news
- The Olympic torch relay
- Training 'taster' sessions
- Emergency Action Code consultation results
- Does Mandatory carbon reporting affect you?
- Polyurethane foam manufacturing fire
- Overheated lithium battery
- UN2927 drums washed up on a beach