Welcome to the final newsletter of 2020.
With the end of the Brexit transition period just days away, we are highlighting critical REACH and poison centre deadlines which will impact organisations based in England, Scotland and Wales. We also look at the importance of testing your emergency response provider and how organisations can continue to adapt, recover and learn from the impact of COVID-19.
Reflecting back, 2020 has been an unprecedented year, with both COVID-19 and Brexit impacting our everyday lives. I am very proud of our team and our stakeholders who have shown unparallel resilience to maintain business as usual.
I, along with everyone at NCEC, would like to extend our warmest wishes for the festive season, and wish you a prosperous and peaceful new year. We look forward to continue providing support for each one of you in 2021, come what may.
I hope you find this newsletter informative. Please feel free to contact me with any comments or suggestions for future content.
Director – NCEC
*T&C's and other costs apply.
According to ECHA, nearly 700 substances held by UK-based registrants have yet to be transferred to an EU legal entity. If your organisation has yet to transfer their EU REACH registration(s) to an EU legal entity or your REACH Only Representative (OR) has not yet actioned this on your behalf, NCEC can help!
NCEC, as part of Ricardo, a multinational company, have legal entities already in place across Europe (and the world) and are ready to act as an EU OR from a REACH perspective from our Netherlands entity. Companies have until 24 December to apply for our special offer wherein we will waive our REACH Only Representative (OR) transfer fees in order to support organisations in retaining their registrations and continue trading in the EU after 31 December 2020.*
We have helped many companies understand the implications of REACH on their business, and already have transitioned organisations to our EU legal entity to maintain their business continuity.
Find out more and take advantage of this offer
The European poison centre requirements (under Annex VIII of CLP) put the obligation of notification of hazardous mixtures (for health and physical effects) onto the organisation placing products on the market within any given EU Member State. For non-EU organisations, who do not have an EU-based legal entity, including those based in England, Wales and Scotland after the Brexit transition period ends, the obligation to notify will become the responsibility of the importer (your customer, distributor or the end user of your product).
To protect confidential information but still enable your customer to comply, you can make a voluntary notification using a European legal entity and then share the Unique Formula Identifier (UFI) with your customer for them to make a UFI based notification.
Find out how NCEC can help support you and your supply chain
We are now days away from the 1 January 2021 deadline for the notification of products for consumer and professional use. To help our customers the best we can, we recently hosted a poison centres event focused on Annex VIII with multiple Member State representatives joining us. The event covered IT tools, compiling information, workability solutions for industries with variable formulas, different EU country’s adoption of the harmonised submission portal, Brexit and Annex VIII's implementation across non-European regions.
Register your interest in purchasing the recording
If you need any assistance in understanding Annex VIII, what it could mean for your organisation or require help for your poison centre notifications, then please don’t hesitate to contact us through the form on the side or email us at [email protected]rdo.com.
On 13 November 2020, the second amendment to Annex VIII of the Classification, Labelling and Packaging (CLP) Regulation was published, focused on providing clarity on the workability concerns raised by specific industry sectors – namely the construction, paints and petroleum industries.
Concerns expressed by these industries contained a common theme – the unpredictability and variability of product composition. In this article, our regulatory experts take a look at the concerns posed by these three industries, the solutions provided by the second amendment to mitigate these specific concerns and what that means for duty holders.
Read more on the workability solutions
We are pleased to announce that our environmental scientists have recently published a peer-reviewed paper on the persistence assessment of phenanthrene.
Increasing societal interest in sustainability and tackling environmental pollution, as illustrated by the European Green Deal, has led to the issue of chemical persistence moving up the priority list of regulators and the public. The latest clear example of increased interest is the plan to introduce criteria for persistent, mobile and toxic chemicals into EU regulation as part of the recent Chemicals Strategy for Sustainability.
These developments will raise significant new challenges for industry and make the reliable assessment of persistence of chemicals of critical importance for chemical companies.
Find out what this means for businesses
You can read our published paper here.
If you have any questions related to persistence assessment of chemicals, biodegradability assessments or any other regulatory queries, please contact us so that we can provide you the right expertise for your products and improve regulatory outcomes for your business.
Image copyright: European Chemicals Agency
The Substances of Concern In articles, as such or in complex objects (Products) SCIP database will come into effect from 5 January 2021, when ECHA will require companies to submit information on any Substance of Very High Concern (SVHC) that are used in articles/complex products that an organisation places on the EU market.
The database has already been launched and as of 2 December 2020, ECHA has already received over 50,000 notifications. Of these submissions, 93 % turned out to be successful.
Enforcement of this law may differ depending on the Member State in which your company submits its notifications and therefore, brings additional challenges to organisations. We maintain an extensive database in conjunction with the ECHA lists – updated with the SVHCs on the Candidate List – and can offer tailored support and guidance for your product submissions.
Find out more on SCIP database requirements
To address the current issues faced by the emergency services and those in the chemical industry who have to respond to and manage hazmat incidents, we have developed a training platform which uses the best technological advancements, training software and delivery methods. Known as the Hazmat Academy, it will provide off-the-shelf and bespoke hazmat training that can be delivered in person, via distance-based learning or through a combination of both.
Please keep a look out for our announcement early next year. In the meantime, the first of the courses from the academy – Hazardous Materials Adviser Initial course – has already opened for booking, commencing from 1 February 2021. We have had an unprecedented response and only have a few places left.
You can find out more about our hazmat and chemical training courses through our training prospectus.
Book the Hazardous Materials Adviser Initial course
Download Hazmat Academy training prospectus
If you'd like to know more about the course, book your place or be the first one to know when our Academy launches, please email us at [email protected] today.
The on-going spread of COVID-19 is having far reaching effects and is continuing to cause business uncertainty. When planning your organisations recovery from COVID-19, or any incident, it is important to consider the short, medium and long term recovery requirements.
We recently hosted a free webinar on organisational and personal recovery in COVID-19. The webinar discussed how organisations can continue to adapt, recover and learn from the impact of COVID-19, and use this unprecedented global crisis to become a more resilient organisation.
Watch the recovery webinar on-demand
Ricardo’s business continuity specialists have developed an easy-to-use toolkit that can be used to create a business continuity and recovery plan.
The completion of this toolkit will provide organisations a series of intervention activities to mitigate the potential impacts that arise during a pandemic and a plan to manage the ongoing continuity of your business. We also have a free checklist which includes clear, concise and practical actions that an organisation should look to complete to create business continuity plans.
Find out more about the toolkit here
Download the checklist here
If you have any concerns about how to go about preparing or updating a business impact assessment, crisis management plan, business continuity plan or a pandemic response plan, please do contact us at [email protected].
Find out what happens when your emergency response systems aren't tested
A member of the Rotterdam fire service, in conjunction with the cefic Intervention in Chemical transport Emergency (ICE) programme of which NCEC is a part, wrote this blog about an incident at the largest port in Europe, surrounded by oil and chemical industry infrastructure.
In this incident, the 24hr emergency response number was not reliable – it was an outsourced provider who simply did not answer the phone for several hours, and then couldn’t immediately help when the phone was answered.
Can you trust your provider to be there when it matters?
Our emergency responders are qualified chemists with significant experience of emergency response, who can provide immediate and actionable advice to emergency responders in these circumstances. We have an incredibly resilient service offering, with each process and system having at least two levels of redundancy, ensuring that every call will be received.
Since 2004, when NCEC expanded its operations to provide 24/7 chemical emergency response from its offices in Oxfordshire, there have been teams of chemical emergency responders working throughout the festive period.
You would be forgiven for thinking that our teams will have a quiet shift during the holiday period. In reality, we receive a surprisingly high volume of calls, ranging from festive themed spills to potentially high-consequence industrial chemical emergencies.
Find out what type of calls we receive over the festive period
The next event in our series of informative digital events will answer 'Why do you need a specialist telephone emergency response helpline?', on 21 January, 14:00 (GMT). The event will demonstrate the tangible and proactive benefits of emergency response to your organisation.
Our emergency responders will be joined by Andrew Barnes (Head of hazardous materials at the Environment Agency), and Amanda Cockton (HM Inspector of Health and Safety at the Health and Safety Executive (HSE)). Using a variety of real life incidents, the panel will explain the difference in response that is required when dealing with a diverse range of incidents such as a call from a member of the public, call from a professional chemical user and a call from a scene of a large scale incident.
Register for the emergency response summit here
Over the past year, the Net-Zero Task Force, which Ricardo is part of, comprising of experts in areas including renewable energy, transport, planning, waste and the environment, has developed the Devon Carbon Plan that aims to deliver a net-zero future for the county. All the actions within the Interim Devon Carbon Plan address suggestions from the public and highlight issues suggested for further consideration by a Citizens’ Assembly.
Find out what actions are included in the Devon Carbon Plan
We received a call from a fire and rescue service (FRS) that was dealing with an ongoing incident at a domestic property. The evening before the call to us, the FRS went to the property because the carbon monoxide (CO) detector had gone off. The CO level measured by the crew was 107 parts per million (ppm) – people who have been exposed to that level may experience headache, nausea, dizziness, sore throat, confusion and a dry cough. As a consequence of this, the residents had been evacuated to a nearby hotel and the gas supplier had isolated all potential sources. The house was left to ventilate overnight. When the FRS crew returned the next morning the CO level was still unacceptably high at 70ppm. This indicated that the source was still producing the colourless, odourless and tasteless gas. It was suspected that a newly laid concrete floor might be causing the problem.
Our emergency responder (ER) advised that, while there is some anecdotal evidence that supports the theory of the concrete being the source, there was no clear evidence from the concrete manufacturer or supplier. In the absence of a definite source to isolate, our ER advised that it would be wise to leave the property empty for a further few days and see if readings were still high once the fresh concrete had fully dried.
It was thought the setting concrete may have been producing a gas that was causing a false positive reading on the domestic and FRS carbon monoxide detectors.
A FRS was called to a site where a barrel containing a chemical solution had over pressurised and burst. A chemist at the site provided information to the FRS about the chemicals involved. It was reported that the reaction had produced meta-Chloroperoxybenzoic acid (MCPBA) – a friction-sensitive explosive compound that had coated the walls, floor and ceiling of the room.
NCEC was contacted for advice. We provided information on the hazards of any remaining precursor reagents and of the MCPBA. Our ER agreed with the advice provided by the on-site chemist that neutralisation by applying a solution of sodium bicarbonate was possible, but cautioned that the neutralisation reaction would likely produce heat and carbon dioxide. Information was also given on the appropriate personal protective equipment (PPE) to be used. We advised that, while gas-tight suits would provide the best protection, the risk of a fire would need to be considered as well given that the product could violently react in the presence of heat. We informed the crew that the sodium bicarbonate could be used to decontaminate the fire-fighting equipment.
We were contacted by a member of staff at a chemical site in Belgium where 400 litres of a resin solution had been spilt from a drum. The drum was not being delivered to the site, but had fallen from the back of a vehicle while the product that had been ordered was being unloaded. While the majority of the product had been absorbed using sand, the intention was to use high-pressure water hoses to wash any remaining residue to a drain.
NCEC’s ER advised that using sand to absorb the product and then collect it for specialist disposal was appropriate. However, we advised that the remainder should only be washed away if the drains were part of an isolated system that could be emptied for disposal rather than flushed to the main drain. It was confirmed that the drainage system was isolated and could be pumped for disposal. As the product is an irritant, our ER provided information on what PPE should be worn to protect staff involved in the clean-up.
The caller also wished to discuss who would be responsible for the cost of having the drain pumped as it was thought this should not be the responsibility of the site owner. Our responder passed the caller’s details to the manufacturer of the goods to discuss this directly. Subsequently, we received a call from the manufacturer the following day and we were able to provide contact details of several third-party spill response companies to assist with the disposal.
Get in touch
If you would like further information on any of the topics covered, have any questions on Brexit and REACH, how to maintain business continuity in the face of a pandemic, environmental persistence or on any other wider chemical emergency response, regulatory compliance or crisis management matters, then please do not hesitate to contact us.
Director – NCEC