NCEC, part of Ricardo, was invited to address the Association of Southeast Asian Nations (ASEAN) Regulatory Cooperation Project (ARCP) in Singapore this week. The 2022 ARCP workshop is the 10th session organised since the inception of the ARCP initiative in 2015. The active participation by ASEAN Member States representatives in the past ARCP workshops has facilitated the progress in achieving their goal of greater regulatory coherence through enhanced cooperation and coordination efforts in this region, with a specific focus on the convergence of the Global Harmonised System (GHS) adoptions across the region.
Giles Hobson, NCEC Business Manager, explains his role in the meeting this week in this blog.
It’s been great to be back in Singapore again and I have had a great week with representatives from ASEAN regulators and chemical companies. As well as contributing to many discussions about how to address regulatory coherence within the region, particularly focusing on adoptions of GHS, I was invited specifically to discuss how to raise the standard of Level 1 Chemical Emergency Response from both a regulatory perspective, but also within each organisation itself.
Our experience in the region is that chemical manufacturers and suppliers who are responsible for the response associated with their products fall into broadly three groups:
Being fully prepared, with a comprehensive measure in place to support those handling and using their products
Have some arrangements in place, but these are often basic, inherently limited and with room for improvement
Have no meaningful measures in place.
The general view of the conference has been that probably the majority of organisations fit within the final group, and it is likely there are some major manufacturers within here. So why, why a lack of action? Too often, this is because of complacency, ‘we’ve never had an incident’, ‘we’re too small’, ‘our products are safe’. Or they view this as not a priority against their other demands. Potentially the short-term cost implications (and not offsetting this against the saving against an incident). Or because there is no pressure in the region to do better.
This last point is the real crux at the heart of my presentation – the regulations within the region don’t encourage good practice. Regulations in the region range from non-existent, through weak to some which are phrased in a way to introduce weaknesses in the response.
For instance, Thailand and Vietnam simply don’t have any. Countries like Malaysia talk about it but make the requirement optional ('If the hazardous chemical is imported, the foreign manufacturer’s contact number (24 hours) may be included for advice during an emergency.'). Whereas the Philippines and Singapore both have well-considered regulations, but introduce language which means organisations could potentially provide an office-only number '…include restrictions such as hours of operation' / '…should indicate the phone operating hours'. An office hour-only number means that this is available for help for less than 25% of the year.
Of course, regulation is just one reason why emergency response should be implemented, and encouraging organisations and regulators to understand the impact more broadly was a crucial part of our discussions this week. The underlying objective is really…
To enable the rapid around-the-clock provision of expert advice in the caller’s language to help reduce the impact of a chemical incident on People, the Environment, Assets, Reputation and Liability.
All organisations putting products on the marketing within ASEAN, and indeed globally, should be considering whether their emergency response provision achieves these three summary points:
A global service capable of operating 24 hours a day, reliably.
Support that ‘looks and feels’ local, with a local language response and options to access the response through local telephone numbers
Actionable advice, informed by tactical response knowledge, which meaningfully helps the caller (going beyond what is available on SDS)
Too often the focus, from the regulations themselves to the way organisations structure their emergency response focuses on the first two (and often not well) without really considering that last, and arguably most critical point – the quality of the response itself.
I’ve been encouraging the regulators within ASEAN to consider these points as they improve chemical hazard communication regulations within the region. However, organisations should not be waiting for regulators to enforce the chemical safety of their products and should be putting best practice arrangements in place now.