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LangJonathan BW
Jon Lang, Emergency Responder and Chemical Regulatory Consultant

SDS Section 1.4 – what numbers are needed?

17/05/2016

Any obligations to have an emergency telephone number is due to the implementation of the Global Harmonised System of Classification and Labelling of Chemicals (GHS) A4.3.1.5

The European translation of this is in Sub-section 1.4 of Annex II of Regulation (EC) No 1907/2006 which refers to the use of an emergency telephone number.

˜References to emergency information services shall be provided. If an official advisory body exists in the Member State where the substance or mixture is placed on the market (this may be the body responsible for receiving information relating to health referred to in Article 45 of Regulation (EC) No 1272/2008 and Article 17 of Directive 1999/45/EC), its telephone number shall be given and can suffice. If availability of such services is limited for any reasons, such as hours of operation, or if there are limits on specific types of information provided, this shall be clearly stated".

The above mentioned Articles 45 and 17 state that a Member State shall appoint a body responsible for receiving information including the chemical composition of mixtures classified as hazardous on the basis of health or physicochemical effects. Such information could be needed to formulate preventive and curative measures in a chemical emergency.

The ECHA guidance document notes that in some Member States, the official advisory body may be solely for medical personnel to contact. In such cases, the SDS should clearly state that the number is intended for use by medical professionals only. In addition reference must be made to an emergency number belonging to a supplier or to a competent third-party emergency provider (for example, NCEC's Carechem). In all cases, irrespective of the number used, suppliers should contact the service provider to confirm its number can be given and to clarify if any conditions apply, prior to using it on SDSs.

Simply put, if an official advisory body (Poison Centre) is available then it’s number must be used in section 1.4. If not, (or in addition), the emergency service may be provided by the supplier or a third party. In many cases, the appointed advisory body is a toxicology information centre and, hence, advice may be limited to health effects. They may not be able to provide information on non-health emergencies such as fires or spillages.

Some centres do not operate a 24/7 service or simply provide an answer machine message. Moreover, the guidance states that all emergency service providers need to be contacted prior to adding their number to the SDS. Although this isn't a registration process as such, it is important to ensure the correct details are used on the SDS and that they have the SDS for use in an emergency. Placing substances on the market in many Member States may result in the onerous task of contacting the many different advisory bodies.

On the ECHA web page listing of national helpdesks, Member States have, on ECHA's invitation, voluntarily listed links to telephone number(s) of appropriate national emergency information services to be used in sub-section 1.4 of the SDS. The NCEC has also developed more in depth information on the provisions of different Member States.

Many companies raise the question of having to provide multiple emergency numbers in section 1.4 of their SDSs. As the SDS should be written in the official language(s) of the Member State, then the corresponding emergency number(s) in that Member State must be added if one exists. If not, then the Carechem24 number could be used to achieve compliance.

Even if an official body does exist, the addition of the Carechem number in Section 1.4 can provide your company with a service that goes beyond compliance and would be a key pillar in the duty of care any company should provide.

For more information in regards to compliance with Poison Centres, please visit our Poison Centre landing page where we have a number of resources available.

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