Welcome to NCEC's October 2020 newsletter.
In this edition, we're taking a look at Brexit and its impact on REACH, updates to REACH Annex II and to Member States accepting harmonised poison centre notifications, what the SCIP database means for businesses and the resources we can offer your organisation to maintain resilience in the face of COVID-19.
We then take a look at NCEC's Next Generation Virtual Business Summits that will cover critical business themes including incident response management and poison centre notifications.
I hope you find this newsletter informative. Please feel free to contact me with any comments or suggestions for future content.
Director – NCEC
The Department for Environment, Food & Rural Affairs (Defra) has published guidance on how UK organisations can comply with REACH chemical regulations from 1 January 2021. Anyone making, selling or distributing chemicals in the UK and the EU needs to follow UK REACH and EU REACH rules.
Read the main themes from Defra's guidance here
We recently hosted a virtual business summit on 'Brexit – what happens next?'. Our Associate Director – Regulatory, Caroline Raine, was joined by CEO of Chemical Business Association, Peter Newport, as they focused on what businesses should be doing to comply with UK and EU REACH from 1 January 2021.
View the Brexit virtual business summit on demand
Annex II of the Registration, Evaluation and Authorisation of Chemicals (REACH) Regulation (EC) No 1907/2006 was amended in July 2020. The amendment, known as Commission Regulation (EU) 2020/878, will come into force on 1 January 2021. All EU safety data sheets (SDS) authored from this date will have to comply with the amendment.
Relevant UK authorities have indicated that the UK will not be adopting this update to Annex II after the UK leaves the EU (31 December 2020). This means that one SDS will not be compliant for UK REACH and EU REACH.
Find out what's changing
We strongly recommend that chemical suppliers begin the process of updating their SDSs as soon as possible. Please email us at [email protected] if you have any questions or concerns regarding these upcoming changes or want to understand what this could mean for your business.
We are now less than 3 months away from the 1 January 2021 deadline for the notification of products for consumer and professional use. The harmonised portal is now live, with six Member States accepting submissions. The portal is due to be updated in October, after which industry can expect to see a flurry of Member States coming on-line.
Read our full Poison centres Annex VIII round-up here
Chemicals for industrial use have till 2024 to be notified on the harmonised system. However, organisations planning to use a limited submission for industrial chemicals should consider their provision for the emergency contact phone number needed.
On 10 & 11 November, 13:00 (GMT), we will be hosting a Poison centres virtual summit where we will be joined by experts from government bodies, competent authorities & industry leads to take delegates through various aspects of poison centre notifications including UFI’s, notification updates, workability solutions, Member State intentions as well as UK's post-Brexit intentions. The delegate rate is only £195+VAT for both days.
Find out more and book your place at the summit here
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].
With the arrival of the European Green Deal, one of the top priorities of the new EU chemicals strategy is action on ‘very persistent chemicals’. This reflects a growing societal concern about these chemicals and the impacts they may be having on human health and the environment.
Find out what this means for businesses and how should you respond
We recently hosted a webinar on environmental persistence during which our ecotoxicology experts focused on the implications that potential new requirements surrounding environmental persistence may create for businesses, as well as best practices for assessing and managing issues related to chemical persistence.
View the environmental persistence webinar on demand
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 the European Union (EU) market. The first prototype for SCIP database has already been released by ECHA.
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
Ricardo’s crisis management expert, Evie Whatling, recently contributed to the Crisis Response Journal with her view on how stress can become overwhelming during a crisis event. Those affected may struggle to make effective decisions and communicate the right information to the right people.
An excerpt from the blog below:
'No longer can the emergency management cycle purely focus on processes and procedures – each stage should be expanded to include the ‘people’ element. In this case, it means including appropriate support and awareness of stress management and mental health needs at every stage. This is most effective when this extends over various levels – from the organisational culture, plans and structure, through to the response teams and leaders and to the individual.'
Read the full blog here
Ricardo is pleased to be working with the Crisis Response Journal and to contribute to the discussion on how care and support of crisis management teams and the maintenance of personal and organisational resilience can help sustain the performance of the crisis management framework.
If you have any questions regarding the blog, emotional resilience, crisis management plans/business continuity plans, business recovery or any other crisis related query in general, please do contact us at [email protected].
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 more on ensuring appropriate emergency response
Polling during a recent webinar, in partnership with UL, ‘How to make your safety data sheets compliant and ensure appropriate emergency response provision’ indicated that more than 50% of organisations perceived their level of supply chain risk mitigation and emergency response preparedness as being not totally compliant or compliant only.
While every organisation has different risk profiles, we would urge them to carefully assess their own risks and what they can do to mitigate them. A robust and reliable emergency response provision will not only protect your bottom line, but will protect your customers and employees making your organisation more resilient.
We are pleased to announce that we will be hosting a series of informative digital events covering critical business themes including:
Throughout the series, NCEC will be joined by industry experts, from both the private and public sector, who will explore key commercial issues. There will be an emphasis on discussion and debate, as well as audience participation through Q&As and interactive polls.
Find out more about these summits and register today
Ricardo has been working actively towards this goal of achieving Net Zero carbon emissions for some time, and we are proud to announce that Ricardo plc has now made a public commitment to its shareholders, customers and workforce to achieve Net Zero carbon emissions from its operations by the end of calendar year 2030. Ricardo has also been helping its broad client base in realising their own climate change mitigation targets.
Find out what steps we are taking to realise Net Zero carbon emissions
We were contacted by the local environmental regulator following the release of a huge quantity of fire suppressant foam at a large warehouse. Many commercial sites have drainage that can be diverted to a sump in order to prevent hazardous chemicals entering the environment. However, as these often require a manual input to begin diverting, a delay in reporting an incident can result in part of the spilled material entering the drain and potentially presenting a hazard to the environment.
In this case, there had been a delay of approximately one hour in reporting the spill, which had led to an unknown quantity of the foam going down the drain instead of being diverted and contained in a sump. The caller was concerned that even if the remaining foam was diverted to the sump, it might not be able to contain it all and become overfilled, presenting a further risk to on-site responders and to the environment.
NCEC’s emergency responder (ER) discussed the composition of the foam and advised on several ways the water around the warehouse could be tested to determine if the foam had entered the environment. We also provided advice on the potential health risks of the foam entering drinking water supplies. And in addition to suggesting ways that the foam could be cleaned up, we also provided contact details for third-party spill remediation companies that may be able to assist with the clean-up at the incident scene.
We were contacted by a fire and rescue service (FRS) who were attending to a barn fire, involving several tonnes of ammonium nitrate fertiliser and straw. Initially, the proportion of nitrogen in the fertiliser blend was unknown. Once NCEC’s ER highlighted the fact that fertilisers with a higher nitrogen content can potentially become explosive when involved in a fire, the FRS made it a priority to obtain information on the blend of the fertiliser involved. It was then confirmed that the fertiliser had a high nitrogen content and presented a significant risk of an explosion. Additionally, the fire was also producing large quantities of brown smoke due to the production of nitrogen oxide and the FRS needed assistance in detecting and monitoring this to aid their evacuation and protection plan.
Our ER advised that the fire should be fought defensively using unmanned water jets due to the high explosion risk. Since the water used to fight the fire would present a threat to the environment, it was suggested that this run-off be contained if possible, and if not, the Environment Agency should be informed. The ER also advised that the nitrogen oxides in the smoke would be toxic, corrosive and could potentially cause delayed health effects, therefore, practical ways to disseminate the smoke while from a distance were also discussed. The ER also kept in mind the downwind effect of this smoke and advised on downwind protection distances that should be considered and ways of monitoring the quantities of the gases in the air. This allowed for effective protection of members of the public downwind of the incident.
NCEC received a call from a member of the public who had witnessed a collision between a chemical tanker and a car, and had been asked by the injured tanker driver to contact the emergency number. The tanker was carrying methanol and since it was raining, it was difficult for them to discern if methanol was leaking out from the tanker.
NCEC’s ER advised that the caller should contact the emergency services as a priority. They also explained to the caller that the product in the tanker, methanol, is highly flammable and can burn with a flame that may not be visible to the naked eye. As it was possible there was a leak, the ER suggested the caller to advise people around the incident to vacate the area and retreat to a safe distance and that the caller should do the same themselves.
When the emergency services arrived on scene, they spoke to NCEC to understand the hazards of methanol, suitable precautions to be taken and personal protective equipment that should be worn when approaching the tanker to determine if there was a leak. This advice allowed the public to remain safe and the emergency services to carefully begin to remediate the incident.
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