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Jon Gibbard

Problems with poison centres

20/12/2013

In Europe, there is a requirement under REACH to include emergency telephone numbers on safety data sheets (SDSs) and, where a member state has appointed an official advisory body (as defined under Article 45 of the CLP Regulation), the telephone number for this body must also be included to cover medical advice.

Although this sounds a relatively straightforward requirement, in reality, several factors can cause confusion. For example, an emergency telephone number is required for each country where a company supplies a product for sale However, some countries do not have official telephone numbers available for a national centre, so an alternative number is required. Germany has nine poison information centres, but none of them has official advisory body status, so suppliers can provide their own emergency telephone number providing certain conditions are met. For example, qualified medical advice in emergency cases must be provided in German. In addition, having access to a poison centre for medical advice does not negate the need for an emergency number in the event of a chemical incident where other information might be required or where a company’s emergency procedure needs to be enacted.

Therefore, a list of national advisory bodies and telephone numbers has been made available by ECHA to try to clarify the appropriate number to use. However, some countries (for example, Cyprus, Greece, Iceland, Italy, Latvia, Luxembourg, Poland and Slovenia) do not have telephone numbers for official national advisory bodies or poison centres listed. In addition, the poison centres in some countries – including Ireland and the Netherlands – are only open to medical professionals, so members of the public and professional users cannot call these centres.

So, an SDS could end up with a long list of numbers on it (for each country where the product is supplied) – including the company’s own number or the number of a third-party organisation that provides advice on the company’s behalf. This does not make it easy for the correct number to be identified in an emergency.

Some poison centres also require chemical products to be registered before their emergency number can be used, and some charge a fee for this registration. A survey of poison centres undertaken by the National Chemical Emergency Centre (NCEC) in the UK showed the problems of this inconsistency. Of the 13 centres that were sent questionnaires asking about the registration process and any fees required, only six replied. Of those, four indicated that SDSs must be registered before their number could be used. So, if you’re trying to establish a new product in Europe, this does not give the appearance of a simple legislative landscape or a simple registration process.

The contractual landscape is also unclear. It appears that none of the poison centres asks “customers” to sign a contract. This raises some far-reaching questions. What is the service that the poison centres/national advisory bodies provide? Can they guarantee 24/7 coverage, and how do they do this? Do they have contingency plans to ensure this? How do they protect the confidentiality of products and product data sheets? These are questions you would ask of an outsourced solution provider, but are not taken into account with current legislation or the lack of any commercial/contract arrangement between company and poison centre.

Thus, it is no wonder that the European Commission’s health and consumers directorate, and a number of key stakeholders, are exploring how to harmonise the process for registration with poison centres, so that it is not needed on an individual country-by-country basis Draft legislative text is expected in 2014.

In the UK, the Chemical Industries Association (CIA) took the lead in pulling together a joint industry paper that spells out some of the practical implications of a harmonised poisons centre network. This has been taken forward to the EU level. Overall, industry welcomes the move to harmonise the registration process for poison centres to ensure trained professionals are able to provide rapid advice on medical treatment.

However, says the CIA’s Nishma Patel, “any changes to the poison centre arrangements should remain within the existing scope of Article 45 to the CLP Regulation. We think a robust impact assessment/cost-benefit analysis should be carried out on any proposed changes to help avoid any disproportionate administrative burden on both industry and poison centres. In addition, confidentiality of business information must remain of paramount importance and assurance is needed to ensure that information provided to poison centres can be used only for the purposes set out in the CLP regulations. This is of significant importance to industry, and there is a need to ensure that publication of any commercially sensitive data is avoided which would otherwise prove damaging in terms of innovation and competitiveness to both industry and the EU.”

In the light of these issues, Chemical Watch and the NCEC will be conducting a survey of poison centres and people’s experience of them next year. The results will be used to inform a workshop on EU poison centres that will be held at Chemical Watch’s Global Supply Chain Network conference in Brussels, in March.

Please let Chemical Watch know if you would like to join us at the event , or have feedback to share on your interactions with poison centres or national advisory bodies.

The views expressed in contributed articles are those of the expert authors and are not necessarily shared by Chemical Watch.

In the UK, the Chemical Industries Association (CIA) took the lead in pulling together a joint industry paper that spells out some of the practical implications of a harmonised poisons centre network. This has been taken forward to the EU level. Overall, industry welcomes the move to harmonise the registration process for poison centres to ensure trained professionals are able to provide rapid advice on medical treatment.

However, says the CIA’s Nishma Patel, “any changes to the poison centre arrangements should remain within the existing scope of Article 45 to the CLP Regulation. We think a robust impact assessment/cost-benefit analysis should be carried out on any proposed changes to help avoid any disproportionate administrative burden on both industry and poison centres. In addition, confidentiality of business information must remain of paramount importance and assurance is needed to ensure that information provided to poison centres can be used only for the purposes set out in the CLP regulations. This is of significant importance to industry, and there is a need to ensure that publication of any commercially sensitive data is avoided which would otherwise prove damaging in terms of innovation and competitiveness to both industry and the EU.”

In the light of these issues, Chemical Watch and the NCEC will be conducting a survey of poison centres and people’s experience of them next year. The results will be used to inform a workshop on EU poison centres that will be held at Chemical Watch’s Global Supply Chain Network conference in Brussels, in March.

Please let us know if you would like to join us at the event , or have feedback to share on your interactions with poison centres or national advisory bodies.

This article originally appeared in December’s Global Business Briefing. Read it online on chemicalwatch.com.

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