Under Article 45 of the European Regulation on classification, labelling and packaging of substances and mixtures (CLP) the telephone number of an officially appointed national advisory body must be displayed as an emergency number on safety data sheets (SDS) for each country in which the product is placed on the market. In plain English, where an official national poison centre exists, its number must be displayed on the relevant SDS.
It sounds simple, but in an informative blog post last year, NCEC’s Jon Gibbard drew attention to some of the many legal, practical and operational issues facing companies trying to comply with this legislation. Efforts are underway to create a harmonised network of poison centres and, if successful, we predict this will vastly reduce the compliance burden placed on industry.
However, the debate about poison centres rarely touches on another important point - the emergency support offered by poison centres is insufficient to deal with all types of emergency. REACH requires an emergency telephone number to be available and CLP requires the poison centre number to be shown, but how do these requirements cater for when a spillage, fire or reaction occurs?
A common response to this shortcoming by industry is to engage with multiple emergency response providers to support different elements of their needs. Poison centres for the provision of medical advice and an outsourced provider, such as NCEC, for other types of call. The problem here is that the scope of debate about harmonising poison centres is not wide enough. Even if European poison centres are harmonised, industry will still have to rely on multiple service providers to handle multiple types of emergency – the result being additional cost, risk and continued multiple SDS registrations.
One aim of the REACH regulation is to provide a high level of protection of human health and the environment from the use of chemicals*. Therefore, would it not be sensible for ECHA to set standards for what competencies are required from telephone emergency support to unify these elements of protection? A single, European-wide system for handling all types of chemical emergencies would reduce the burden on industry and reduce non-compliance. Such a centre would need to operate 24/7, have a wide range of technical competence and be able to handle emergency calls in multiple languages.
NCEC welcomes a wider debate about the role of the poison centre and of the emergency response provider in ensuring a safe chemical environment in Europe. We invite views on the matter via our survey in partnership with Chemical Watch: https://www.surveymonkey.com/s/EUPoisoncentres (survey is open until 10 February 2014).