NCEC have been working with many organisations across Europe who are displaying only the local poison centre numbers on section 1.4 of the safety data sheet (SDS). Whilst compliant for poison centre requirements and meeting the minimum REACH regulation requirements, these organisations are exposed to significant supply chain risks, as the poison centre number is intended to give medical advice to medical professionals only, and therefore are not equipped to provide meaningful advice and support to wider incidents such as chemical spills.
According to the REACH Regulation, when a telephone number is not available 24/7 or is limited in its use (e.g. for use by medical professionals only), this should be stated on the SDS and additional emergency numbers belonging to a supplier or competent third party should be stated.
Whilst supporting our customers with their regulatory compliance challenges, NCEC have identified several French SDSs that only used the ORFILA (French poison centre) number. This number is free to use, provided the product is already declared in France. We contacted the French poison centre to confirm what happens with non-medical emergency calls such as a chemical spill.
The poison centre has confirmed that they redirect any non-medical calls to the manufacturer. This has two significant ramifications: exposure to non-compliance with REACH, and also – perhaps more critically – potential exposure to greater financial, legal, and reputational impact during a supply chain incident.
We are currently undertaking a wider discussion with other poison centres in the market to determine if further guidance for manufacturers is required about what numbers are required on SDSs. However, it is likely that – for organisations who are only displaying poison centre numbers on SDS throughout Europe – similar exposure to risk is likely.
Considerations for manufacturers
Ensure that there is a poison centre number as well as an additional emergency response number on your SDSs.
We recommend following the Cefic Guidelines for Level 1 Chemical Emergency Response and ensuring that your approach to emergency response number display is not focussed solely on complying with regulations. It must also consider risk management and response, crucially providing robust support to those involved in an incident with your products quickly, accurately and in a form they can understand and implement. If you only use a poison centre number on your SDSs, when a stakeholder calls about a non-medical emergency incident, they will face delays in receiving support. Delays can have significant implications on the scale and outcome of an incident.
Non-medical calls might get directed back to your organisation, but only when you provide an appropriate number to them, but in some cases you are unlikely to be told that an incident involving your product ever occurred.
If a poison centre does redirect the caller to you, you need to consider if you have the capabilities to provide 24-hour emergency response for your products. Do you have the capabilities of providing support in the local language of callers throughout your supply chain and the chemical knowledge required to provide actionable advice, rather than just product information?
If you only use a poison centre number on your SDSs and you do not have these capabilities or are not made aware of an incident involving your product, you are exposed to the very real risk of harm to your stakeholders, the communities in which you operate, the environment, your organisation’s assets, reputation and ultimately your bottom line.
Why you should choose NCEC as your telephone emergency response partner
1. You need a telephone emergency response partner who puts your needs first. At NCEC, we build partnerships with our customers by working closely with you to understand your needs, so we can create a bespoke service that supports your organisational requirements, such as global compliance, risk management and sustainability obligations.
2. You want a trusted telephone emergency response partner, who is available at all times to provide advice to callers at an incident. Our emergency responders are qualified chemists with tactical awareness, combined with ‘real-life incident intervention’ experience, which enables them to support callers to safely intervene at the scene of an incident.
3. You need an emergency response partner to reduce your financial and operational risk throughout the supply chain, by mitigating the impact of incidents before they escalate, causing disruption throughout the supply chain and impacting your assets and reputation. Our emergency responders provide advice that is proportionate to the incident, to reduce over-responding that could result in unnecessary costs.
Our service is available 24/7, 365 days of the year, through a network of international telephone numbers and local language speakers, so it looks and feels like a local service. Our team take into consideration your organisation’s needs, as well as any global regulations, to build a service that will meet your requirements, rather than a one-size-fits-all approach.
If you would like to speak to a member of our team to see how you can get support from a telephone emergency response provider you can trust, then please contact us through the form at the side of this page or email us at [email protected].