INTRODUCTION

With various legislation deadlines looming, we hope this edition of the newsletter helps keep you informed. Importers of chemical products into the EU need to pay particular attention to the actions needed to be taken in the next few weeks to ensure you remain compliant, avoid penalties and can continue to market and sell into the EU.

We'd also like to highlight new training dates coming up. We have recently added courses for CLP (the new Classification, Labelling and Packaging Regulations), COSHH (Control of substances hazardous to health) and lithium battery safe handling, and would like to thank everyone for the overwhelmingly positive feedback on the courses held so far.

If there are any topics you would like us to cover in future newsletters, then please let us know. We are always pleased to receive your comments, so call us on +44 (0) 1235 75 3654 or email ncec@ricardo-aea.com.

Happy reading.

Bill Atkinson
Head of Emergency Response
Email: ncec@ricardo-aea.com

NOTE TO CARECHEM 24 INTERNATIONAL CUSTOMERS

emergency responseChanges in Carechem 24 International telephone numbers

As all customers of the Carechem 24 International service will now be aware, our telephone numbers have recently changed. These changes apply only to users of the International (multilingual) service and those who use a USA (+1) number to reach our Emergency Response Team.

We will have provided you with the new numbers. Please ensure these numbers are forwarded to those within your organisation who may need to implement changes. These may include:

  • Colleagues who have access to the number
  • SDS Authoring companies
  • SDS management companies
  • Printers (for labels and packaging)
  • Printed Emergency Response Plans
  • Answer phone messages.

Download our pdf guide on managing Carechem 24 calls.

If you have any questions on the changes and how they may affect you, please contact Lynn Aitken (lynn.aitken@ricardo-aea.com) or Dan Haggarty (daniel.haggarty@ricardo-aea.com)

CHANGE IN REQUIREMENTS FOR EMERGENCY RESPONSE TELEPHONE NUMBERS LISTED ON SHIPPING PAPERS

The requirements for the emergency response telephone number listed on shipping papers (as specified in 49 CFR  -172.604) were amended in October 2009 and September 2010. The amendments take effect from 1 October 2010.

The main changes are as follows:

The emergency response telephone number should be made clearly visible on the shipping paper so that it can be quickly and easily found. For example, this might be done by highlighting, the use of a larger font or using a different font color to the rest of the text.

Where the emergency response telephone service is provided by a third party (e.g. NCEC's Carechem24), the organisation that has contracted that third party to provide the service should be clearly identified on the shipping document. The legislation indicates this should be done by listing the name of the supplier, or a contract number or other unique identifier, immediately before, after, above or below the emergency telephone number.  This change is designed to allow the telephone responder to quickly identify the name of the company involved, and enable them to access specific information on the material. Customers of Carechem24 should ensure their own company name remains prominent on the paperwork to enable NCEC Emergency Responders to establish the link to the customer's Emergency Response procedures.

We recommend using identifiers such as: '[Customer name]-NCEC29003'. This identifies the contract number, the supplier of third party Emergency Response services, and the party contracting those services.

When using a third party to provide its emergency response telephone service, an organisation must make sure that the third party holds the most current information on the material before it is offered for transportation.

Information about NCEC emergency telephone number services

1 DECEMBER 2010 - REACH AND GHS/CLP DEADLINES

GHS/CLP... ARE YOU READY?

GHS is being implemented in the EU via CLP. The first of the CLP deadlines is fast approaching and a large number of companies are yet to take any action.

The deadline for substance reclassification in the EU is 1 December 2010 and for mixtures 1 June 2015. More information on GHS can be found on our website.

How will classification, labelling and packaging differ after 1 Dec 2010?

For substances:

Classification: In accordance with The Dangerous Substances Directive (Directive 67/548/EEC, 'DSD') and CLP.

Labelling and packaging: In accordance with CLP only not The Dangerous Substances Directive (Directive 67/548/EEC, 'DSD') as previously.


For mixtures:
1 June 2015 is the final deadline for CLP compliance, with a phase-in period starting from 1 December 2010.


NCEC can help you with reclassification under CLP as well as advise on labelling and packaging.  Contact us to see how we can help with compliance.

REACH REGISTRATION

By 1 December 2010, phase-in substances, produced or imported in quantities greater than 1,000 tonnes per year, must have been registered in the ECHA system for manufacturers or importers to market and sell in the EU. This also applies to CMR and toxic substances (R50/53) with quantities in excess of 1 tonne per year.

If you are based outside the EU and have no registered offices in this area, you will need a representative to register your products with ECHA.  This is known as an 'Only Representative/OR'.  NCEC can act as your OR and register your products as well as represent you at REACH SIEFS - this means that commercially sensitive information on ingredients can remain unassociated with your brand.  We also offer this service to companies in the EU.

REACH services:

  • Third Party Representative
  • Only Representative
  • Classification of substances
  • REACH and GHS compliant safety data sheets - review and update
  • SIEF representation
  • Dossier preparation
  • Exposure scenario development
  • Chemical safety reports
  • Develop testing strategies
  • Socio-economic analysis

More information on REACH.

Contact us for help with REACH compliance.

 

CLP AND SAFETY DATA SHEET MANAGEMENT

**CHEMEDOX® - SPECIAL OFFER**

From 1 December 2010, there will be a phase-in period where safety data sheets (SDSs) will have two sets of classification and labelling.  During this time, SDS management systems need to be able to handle both sets of SDSs.

In response to this, NCEC, led by its legislation and emergency response experts, has developed an additional search interface in its chemical safety document management system - ChemeDox®.

This unique search interface allows users to search for CLP indexed SDSs by classification and also by hazard statement(s), precautionary statement(s) and EU hazard statement(s). ChemeDox® is the first system of its kind to be able to manage the conventional CHIP-led SDSs and the new generation of CLP compliant documents. As part of this, NCEC will also be able to offer clients a customisable facility for the production of CLP compliant labels.

If you sign up before 17 September 2010 you will be entitled to 25% discount on the price of our ChemeDox® Gold chemical safety documentation management system.

Find out more about ChemeDox.

CARBON REDUCTION COMMITMENT (CRC) ENERGY EFFICIENCY SCHEME

Could you face £500-a-day fines for non-compliance?

co2The CRC is due to create a new carbon market in the UK worth around £600 million per year by putting a price on CO2 emissions from energy use. If you’ve never heard of CRC then you can see if it will impact you on the AEA CRC impact page.

Each year, the Government will publish the CRC league table - publicly demonstrating how you are performing relative to other CRC scheme participants. More information on CRC league tables can be found on the AEA CRC league table page.

The CRC directly affects around 5,000 public and private sector organisation in the UK, many of which are yet to take any action.  The deadline for registration is 30 September 2010 and organisations must submit their initial registration at least 2 weeks before that date.  After September, organisations are subject to penalties for failure to register, starting from £5,000 and increasing by £500 per-day for up to 80 days thereafter.

AEA is in a strong position to help you meet your CRC compliance needs as we advised the Department of Energy and Climate Change (DECC) on the CRC scheme and continue to work with the Environment Agency during the implementation phase.

As part of our CRC consultancy services, you can now generate your own report using the eservices area of the AEA website.  Using this online service, you can produce a bespoke report providing organisation-specific information on potential loss/profit scenarios, an assessment of your footprinting requirements, a three-year compliance timeline, compliance checklists and more.

View the eservices area of the AEA website.

Find out more about AEA's CRC compliance services.

TRAINING AND EVENTS


TRAINING

Hazmat 1st Response
23/09/2010 - Location: BASF in Cheadle Hulme
15/03/2011 - Location: tbc

Chemical Hazard Awareness
07/09/2010  *Specific to Paramedics* - Location: Oxfordshire
15-16/09/2010 - Location: North Wales - FULLY BOOKED

CLP
07/10/2010 - Location: Harwell, Oxfordshire
20/10/2010 - Location: Harwell, Oxfordshire
09/11/2010 - Location: Harwell, Oxfordshire

Lithium Batteries: safe handling and transport
14/09/2010 - Location, Harwell, Oxfordshire

Register your interest for training or request further information.

As well as providing set courses, we also deliver bespoke training covering the above plus other chemical health and safety areas such as COSHH. 

View more training courses.

EVENTS

Annual Hazmat Event

The annual Hazmat Event is a great opportunity for a wide range of experts to connect, share experiences and learn about the latest developments relating to the Hazmat industry.

The Hazmat Event 2011 will be taking place in February (exact dates to be confirmed soon), so if you wish to register your interest for further information, please complete the online form.

Read the Hazmat Event 2010 review.

The Emergency Services Show 2010

Chemdata and Pocket Chemdata demos – come and try it for yourselves.

NCEC will be exhibiting at stand E20 in the Emergency Response zone... visit us and leave your business card for a chance to win a place at the Hazmat Event or a six-month Pocket Chemdata licence in our prize draw.

EMERGENCY RESPONSE - RECENT INCIDENT

Spillage of hydrochloric acid in Yorkshire

NCEC recently received a call regarding two failed tanks containing a total of 11 tonnes of hydrochloric acid. The product had entered the internal drainage system at the scene and there were concerns that the acid would enter the local watercourse.

Our Emergency Responder ensured that the necessary immediate actions had been carried out - such as evacuation of non-essential personnel and the correct level of PPE was being used. Our Responder then made the caller aware of potential risks such as the acid reacting with metal fittings and drain covers to produce hydrogen gas and the resulting potential for the formation of an explosive atmosphere. The incident was dealt with, no-one was harmed and the Environment Agency was informed of the incident.

Immediate access to advice like this means the incident can be dealt with in a calm and informed manner with all the risks and environmental aspects considered.

Find out about NCEC’s 24-hour telephone numbers.

Information about NCEC emergency telephone number services