Welcome to the May issue of the NCEC newsletter.
In the last issue, we highlighted the consultation exercise on the Emergency Action Code (EAC) system launched at the Hazmat 2012 event. The consultation has generated some interesting responses so far, such as questions about how EACs are formulated. So, I’ve gone into a bit of detail to help explain the process. It may feel like the scene where they pulled back the curtain in the Wizard of Oz!
Speaking of consultation, many thanks to those who responded to our customer questionnaire. This was invaluable in understanding your requirements and how we can offer the support that you are looking for. We have listened to what you have said. As well as being useful in highlighting what we do well (and thankfully it seems we do a lot well), it’s indicated where we can make some changes and improvements, and we will be putting plans in place over the coming months to address these.
Having technical articles in this newsletter was one area that you highlighted as being important to you. In this issue we include an update on Registration, Evaluation, Authorisation and restriction of Chemicals (REACH) and its impact on safety data sheets (SDS) in Europe. In addition to providing information ourselves, we always try to highlight useful external sources of information where we find them. Examples include the Chemical Hazards Communication Society (CHCS) guide to the Classification, Labelling and Packaging Regulations (CLP) labels and the Emergency Response Guidebook (ERG).
Since the last issue, we have held our inaugural First Aid for Chemical Exposure training course, which I’m pleased to say generated some very positive feedback from the delegates. Back to that theme of feedback once again! I make no apologies for repeating it. It really is important to us. We are repeating the course in July and there are other courses on COSHH Assessment, 1st Response and Chemical Spill Response coming up.
We are already working on some exciting new ideas (as well as a new venue) for Hazmat 2013, some of which are based on, yes you’ve guessed it, excellent feedback we received from Hazmat 2012.
Lastly, there is our usual round-up of some of the more interesting emergency calls we have received, including an incident in a superglue packaging factory where thanks to our emergency responder’s good advice, no one came unstuck (bad puns is one area where I choose to ignore the feedback I get!).
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
In the last Newsletter, we explained how NCEC had opened a consultation exercise on the future of Emergency Action Codes (EAC) and posed some questions on seeming anomalies. We are pleased to say that, so far, we have had a good response to the consultation, although the stream of views has tailed off recently. This is to be expected, but it is not too late to have your say. The details on how to respond to the consultation, which will remain open until the end of June, are below.
One of the responses we received was not so much about the future design or applicability of the codes, but posed a specific question about why the EAC for aluminium phosphide was not assigned an ‘E’ to indicate a public safety hazard, given that it evolves a toxic gas on contact with water? Researching the response (and we’ll come on to that) started us thinking about how much is generally understood about how EACs are assigned to the list of dangerous goods. Our guess is ‘not a lot’.
EACs were originally intended for use on ‘bulk’ consignments of dangerous goods and are designed to offer advice in the initial phase of an incident. They differ from the International Carriage of Dangerous Goods by Road (ADR) Hazard Identification Numbers used on the continent as they give advice and don’t relay hazard information. However, the advice has to be based on the hazards of the substance concerned. So, how is this done? Well, let’s first break down the code into its constituent parts. The chart below shows how EACs are decoded to give the advice.
A series of yes/no questions, or decision tree of questions, are followed, which determine the best choice of fire-fighting agent and the other advice given in the code. The choice of fire-fighting medium is dictated by the properties of the substance. For example, coarse water spray is not usually recommended in dealing with chemical fires or spillages because of the risks created by the uncontrolled spreading of chemicals, which could increase the hazard and the scale of the incident. On the other hand, water should not be used on flammable liquid fires (foam is a better choice) and care should be taken in using water on chemicals that react violently with it. Additionally, the answer to the question 'Will the application of water increase the overall hazard?' may depend on the circumstances, such as the environment of the incident and the quantity (e.g. bulk?) involved.
The letter of the EAC dictates whether a release should be contained or diluted, the choice of personal protection also indicates the possibility of a violent reaction. There are further algorithms that determine the best choice of code to cover all of these aspects. For example, while most releases should be contained to minimise the risk of environmental damage, in the case of substances like pressurised gases, containment is not really a viable option and so containment advice should not be given for compressed gases.
Finally, the EAC may be assigned an ‘E’ to indicate a public safety hazard. One of the criteria for assigning the extra letter is 'are toxic, asphyxiant or flammable vapours likely to spread outside the immediate area during a fire or spillage?', which brings us back to the query about aluminium phosphide, which liberates toxic phosphine gas in contact with water. Aluminium phosphide cannot be transported in bulk, which is why the ‘E’ had not been assigned as it was judged that not enough toxic gas could have been produced to spread from the immediate area. However, on reflection we think this is a moot point and we are re-examining this example and several others. One of the reasons for looking at it again is how EACs are used. As well as being mandatory for bulk loads of dangerous goods, they are also used as an indication of danger. While EACs were not really designed for this purpose, if they are being used as an indication of hazard, then this is something that we need to consider.
During the consultation exercise, it is hoped to capture these views, how codes are being used and how the stakeholders continue to intend to use them (or not). You can contribute to the consultation here until the end of June.
With the constant flow of stories on updates to global chemical regulations, it is easy to lose track of specific regulatory updates. We thought it would be a good time to consider a specific regulatory topic and look at the important changes that are in the pipeline. You can also receive our regulatory changes bulletins by following this link http://the-ncec.com/regulatory-updates-subscription
In this article, we look at the impact of the REACH regulation on the European Safety Data Sheet.
The REACH Regulation places many responsibilities on organisations in the chemical supply chain. Registration is the highest profile activity, with substances placed on the market at 1,000 tonnes or more requiring registration by December 2010. The next deadline for substances on the market at 100 tonnes or more is rapidly approaching (May 2013). However, REACH does have a broader scope than just registration, with particular impact on the SDS. Two changes to current progressing are:
1. Adjusting SDS format and structure to match that given in the amended REACH Annex II.
2. Authoring of Extended safety data sheets .
REACH Annex II – Requirements for the Compilation of Safety Data Sheets
REACH Annex II was updated in 2010 to reflect the phase-in of CLP information onto the SDS. At the same time, significant changes to the content and structure of the SDS were also made, with the aim of improving the standard of information provided.
As with the CLP Regulation there are phase-in time periods for the SDS update requirements. The first of these has passed, but significant actions are still required before the update is fully implemented:
Transition 1: December 2010
Safety data sheets for all substances must meet the revised REACH annex II requirements.
Safety data sheets for all new mixtures (placed on the market after December 2010) must be authored according to the new requirements.
Transition 2: December 2012
Safety data sheets for all mixtures require update to the new REACH Annex II format.
During these two transition stages classification information from both the older regulatory systems (Dangerous Substances and Preparations Directive) and the new CLP regulation can be given on the SDS.
Transition 3: June 2015
Safety data sheets for all substances and mixtures to be available in the final format given in REACH Annex II. From this transition point, only the CLP classification information will be on the safety data sheets.
Therefore the deadline for ensuring that all substance and mixture safety data sheets meet the format requirements of the revised Annex II requirements is very close. Starting to plan and develop actions are required to make sure that this work can be completed for the December deadline.
A key part of the REACH registration process is to compile a chemical safety report (CSR) for the substance. Where a substance is placed on the European market at 10 tonnes or more per year, and is hazardous then the CSR must contain exposure scenarios (ES).
The ES result from communication up and down the supply chain. They allow the manufacturer/importer to communicate how the product is used (occupational conditions) and the protective measures that downstream users should consider to ensure that they are using the substance safely (risk management measures).
Once the ES have been produced it is a further requirement to communicate the information through the supply chain. The method used to do this is to append the ES to the SDS – converting it to an ESDS.
As the first registration deadline passed at the end of 2010, exposure scenarios have been written for many substances, resulting in the current challenge of passing these documents through the supply chain. The ES produced are detailed and often lengthy documents. As a result we now have the significant challenge of authoring this information in the SDS, and to ensure that it is translated into the required languages.
• REACH Annex II - updates to SDS format and content. SDS updates required by December 2012
• REACH registration - deadline for 100 Tonne per year substances May 2013
• ESDS– addition of ES to the SDS
We hope that you find this brief regulatory update useful. If you require any further information, have any questions, or would like to suggest an area of regulation that you would like us to provide updates for in the future, then please get in touch. You can also register to receive regular update bulletins by following this link http://the-ncec.com/regulatory-updates-subscription http://the-ncec.com/regulatory-updates-subscription
The 2012 version of the Emergency Response Guidebook (ERG) was released this month. The ERG is developed jointly by the US Department of Transportation (DOT), Transport Canada, and the Secreteriat of Communications and Transportation of Mexico (SCT). It is updated every four years. The ERG is a popular guide used by first responders in the fire services and police, and by other emergency service personnel. It contains a series of simple and generic guides to follow. A guide is selected from a table of dangerous goods ordered by UN number or name. Guidance is given for substances that are toxic by inhalation. Information from this table is included in Chemdata®.
The 2012 version of the ERG includes the list of dangerous goods taken from the 17th UN ˜Orange Book". Other changes include updated guidance on emergency response telephone numbers, the addition of a Boiling Liquid Expanding Vapour Explosion (BLEVE) Chart to the Fire and Spill Control Section, and a new Improvised Explosive Device (IED) Safe Standoff Distances Chart to the Criminal/Terrorist Section.
The guide is available as a printed book and an electronic download. Further details can be found on the US DOT website.
Many of you will be aware of concerns raised in recent months over:
• The lack of awareness and understanding of the new CLP label pictograms among
professional users and consumers.
• The lack of any high-profile campaign to educate these groups about the new pictograms.
CHCS has responded to these concerns by developing a new website(www.understandthelabel.org.uk )which is aimed at these target groups. The website provides simple explanations for the new pictograms, together with some basic advice on safe handling.
A press release campaign will be undertaken over the next few weeks which it is hoped will result in this issue being raised in a wide variety of trade and consumer magazines. If you have any suggestions for publications you think CHCS should be targeting, then contact CHCS at the following email address firstname.lastname@example.org.
CHCS is also making use of social media to raise the profile of the campaign.
For those of you who use these media, why not 'Like' their new sites and help spread the word among your family and friends. You are also welcome to link to the new website from your company website.
If you would like more information or have any comments on the new campaign, contact CHCS at: email@example.com
The survey ran for four weeks during March and April. We received over 100 responses,
thank you to all those who provided feedback, this is greatly appreciated and will help us improve our existing products and services and help us develop new ones.
Congratulations to Mr Iain Brunning from Boots who was the lucky recipient of the iPad that was the prize for entering our 2012 satisfaction survey.
We have been busy working through the data and your feedback, and here are some of the early headline statistics:
Along with all the statistical data we received a large number of positive comments such as;
˜Don't change it. Very important to have a quick pick up by a 'human' when seeking emergency assistance. Clear English language is imperative for good communication on sometimes complex matters. Staff to date have been eager to help and even follow up to ensure things are in order."
"Your emergency responders bring a calmness to what would otherwise be a stressful situation."
"Advice beyond and above the emergency phase which was greatly appreciated."
We have been in contact with a number of respondents already and this will continue over the next month. We are following up interest in our new services, but also responding to those who provided specific feedback. If we haven't been in touch already we will be soon.
Feedback is appreciated at any time, so if you would like to comment on any of our services, good or bad, please get in touch using the contact us form.
Our ambitious plans for growth means a new senior vacancy on the NCEC management team has been created. We are recruiting for a New Sales Manager position, this would suit someone with a strong interest in sales, excellent interpersonal and communication skills, and good knowledge, of chemical regulations or the chemical industry in the UK and/or abroad. We need a highly motivated and professional individual to join the team and take the lead on this exciting opportunity.
This new vacancy provides excellent opportunity for personal development and exposure to AEA's senior management team. We welcome applications from people either in established sales roles or with the vision, skills and commitment to progress their career in a new direction. Please visit www.ricardo-aea.com/cms/careers/ for further information about the role or to apply.
NCEC's trainer recently provided a ˜Practical Spill Response" course to Sibelco, a major supplier of industrial minerals.
The morning sessions dealt with identifying hazards and understanding how physical properties affect the way a chemical behaves. These were followed by a session on good practice when responding to a spill. During the afternoon, the delegates were then given the opportunity to deal with a leaking 1,000 Litre intermediate bulk container that was releasing its contents (purported to be hydrochloric acid) down a slope towards a drain.
After the day had finished, Malcolm Spence, one of the response team being trained, noted: ˜Although the written material is excellent, the stand-out benefit of this course is the chance to act out a scenario, as the real reaction can be very different from how you think."
For more details on this courses or the other courses available click here
NCEC exhibited at the 2012 Safety and Health Expo in May and met many familiar and new faces. At the event, we were able to launch the campaign for Hazmat 2013 and introduce our latest training course, First Aid for Chemical Exposures. The winner of our prize draw was Keith Robinson from Babcock DynCorp.
Keith wins a Pocket ChemdataÂ® licence which he was keen to have the opportunity to try out after being impressed by the brief demo at the show, congratulations Keith!
NCEC recently received a call from a HazMat Officer at a major fire at a superglue packaging company on an industrial estate. About 40 tonnes of cyanoacrylate adhesives and an unknown quantity of accelerator aerosols were alight. The Hazmat Officer wanted to know the hazards of the products and if water was the most appropriate firefighting medium.
Our Emergency Responder advised the HazMat Officer that cyanoacrylates are irritating to the eyes, respiratory system and skin, and produce toxic or irritant fumes in a fire, so breathing apparatus and fire kit should be worn. Our Emergency Responder also advised that the aerosols are extremely flammable and dangerous to the environment, so explosions were likely to occur and fire water should be contained. The Emergency Responder explained that foam was more effective than water for firefighting and that the thermal decomposition products posed a risk of pulmonary oedema for up to 48 hours after exposure.
NCEC's chemists have access to a range of hazardous material databases, including Chemdata®, and draw on their extensive chemical knowledge to provide advice within minutes of receiving a call.
NCEC recently received a call from a Fire Station Manager who was dealing with a barn fire late in the evening. The barn was constructed of asbestos and contained two tonnes of ammonium nitrate fertiliser. The Station Manager was concerned about the environmental impact of the fire water due to the ammonium nitrate fertiliser.
Our Emergency Responder advised the caller that ammonium nitrate is not toxic to the aquatic organisms, but caused eutrophication (an algal bloom that uses all of the oxygen in the water as if decomposes, causing fish and other aquatic organisms to die). When asked if ammonium nitrate was toxic in fire, the Emergency Responder explained that nitrogen oxides would be produced, which pose a risk of pulmonary oedema, and that firefighters should be monitored for 48 hours after exposure.
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.
A 20 Litre spillage of sodium cyanide and m-nitrobenzene sulfonate had been placed in a bund containing an unknown acid from a previous spill. The site had been evacuated and no one was injured. The Fire Officer at the scene suspected that hydrogen cyanide would be produced, but wanted confirmation.
Our Emergency Responder confirmed that hydrogen cyanide would be produced by reaction of the acid with sodium cyanide and advised that the gas is highly toxic and flammable. Our Emergency Responder explained that gas tight chemical protective suits and breathing apparatus should be worn, and that sodium carbonate could be used to neutralise the acid and prevent further production of hydrogen cyanide.
NCEC's Emergency Responders use their knowledge of chemical reactions to determine the hazardous products and, when practicable, how to quench a reaction and prevent further harm.
Barcelona will host the 27th Chemspec Europe, which will see over 400 exhibiting companies from around the globe and over 5,000 attendees are expected.
Still unrivalled as Europe's only dedicated fine and speciality chemicals event, Chemspec Europe is focused on providing its attendees access to, and networking opportunities with, blue chip and small and medium sized enterprise (SME) suppliers from around the globe.
Visit us on stand B13.
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. egistration 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.
[STOP PRESS: THIS COURSE HAS BEEN CANCELLED]
13 June 2012 - Gemini Building, Harwell
This short-day course will help you understand what the COSHH Regulations require of you, chemical hazards and risks, and the steps for making an assessment.Â You are invited to bring your own assessments for discussion.
Cost: £215.00 +VAT
[STOP PRESS: THIS COURSE HAS BEEN CANCELLED]
14 June 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
28 June 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
5 July 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 or telephone +44(0)870 190 6621.
[end of newsletter]
- How Emergency Action Codes are assigned
- Europe SDS Regulation
- ERG 2012
- Pictogram publicity
- NCEC Customer satisfaction survey 2012
- Practical spill response training
- SHE 2012
- Fire at superglue packaging company
- Barn fire
- Sodium cyanide spillage