Regulatory Newsletter – August 2022
Examining the potential impact of Defra's consultation on?UK REACH registration deadline extensions
The UK government recently agreed to work with stakeholders to explore an alternative transitional registration model, which includes a review of the current full registration deadlines. Defra have proposed 3 options for deadline extensions.
Our Senior REACH Consultant, Laura Clement, reviewed the three options giving insights on the potential impact of each option on chemical manufacturers, formulators and downstream users, and advising on what should businesses be doing next, in?this report. While the consultation closed on 1 September we advise everyone to read Laura's analysis so you can prepare on what to do next in each instance.
Request support with?UK REACH at [email protected]
Our team is currently preparing for the potential impact of the consultation. We will be updating you with the results and stand ready to provide bespoke support to you no matter which option is chosen.?We are already supporting organisations across the world to manage the impact of UK REACH on their business from our legal entities in the UK and across Europe. We can help you navigate the complexities of UK REACH and significantly reduce the costs of compliance.
Meet our expert – Laura C. , Senior REACH Consultant
Laura has worked in the chemical industry for over 17 years and, during this time, has developed detailed knowledge of chemical regulation, product certifications and approvals in highly regulated industries.
As a quality and regulatory affairs professional, Laura has practical industry experience of delivering compliance on a range of regulatory requirements including REACH, GHS, CLP, and SDS authoring as well as advising and achieving global regulatory notifications, product certification and approvals across various industries.
She is experienced in leading technical training workshops and her industry experience gives her a strong understanding of the operational complexities and concerns that businesses may have in achieving regulatory compliance. In addition, Laura is a Chartered Quality Professional (CQP MCQI), which recognises her knowledge of quality management, assurance, improvement and governance.
Currently, she spearheads our customer's compliance with both UK and EU REACH and is also supporting organisations with our bespoke offering of REACH dossier improvement. Say hello to Laura
Poison Centre update?????????
Poison centre in Finland able to accept notifications which comply with?18th Adaptation to Technical Progress (ATP18)????????????????
The poison centre in Finland announced that they are able to accept notifications that comply with ATP18 with immediate effect. The amended Annex VI to CLP includes new and updated harmonised classifications for 56 substances including 6 which are particularly common. The new classifications will become mandatory from 23 November 2023. However, Finland are encouraging organisations to amend their notifications to comply before this mandatory deadline.?Read more here.
Belgium Poison Centre to charge double notification fees??????
When the European Chemicals Agency (ECHA) portal launched in 2021, the Belgium Poison Centre was unable to connect to it. Whilst they were waiting to connect, they advised organisations to still notify their products directly to the Poison Centre via email. This ensured that the Belgium Poison Centre had access to all of the relevant safety information in case of an emergency.?The cost to complete this notification is 200 euros per product.?
A number of organisations also?notified their product via the ECHA portal, hoping that upon connection to the ECHA portal, the Poison Centre will have access to their information and the business will be able to display the Unique Formula Identifier (UFI) on their product in Belgium.
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The Belgium Poison Centre has recently connected to the ECHA portal and is now enforcing a 200 euros per product fee onto the businesses that have notified via the ECHA portal. This means that many businesses trading in Belgium that have already notified will need to pay 400 euros per product in total.?This will cost businesses double the amount despite being compliant.????
Organisations relying on European poison centres for their emergency response provision are exposed to significant risks???????????????
NCEC have observed organisations across Europe displaying only the local poison centre numbers on section 1.4 of their SDSs. We contacted a poison centre to confirm what happens with non-medical emergency calls such as a chemical spill.?
The poison centre advised that they redirect the caller 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 an 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.?
We strongly recommend a poison centre number and an emergency response number is displayed on your SDS. At NCEC, we operate a global 24/7 market leading telephone emergency response service that provides advice, not just information in the event of an incident. Advice is available all year round, through a network of international telephone numbers and local language speakers. You can find out more about NCEC becoming your telephone emergency response partner?here.
Less than 4 months left until all EU SDS should be updated to new Annex II requirements
Annex II of the REACH Regulation (EC) No 1907/2006 came into effect on 1 January 2021, outlining the mandatory format for an SDS and general indicators of the information contained.?A grace period until 31 December 2022 has been given to update any EU SDS compiled according to the old Annex II requirements.
Outsourcing your SDS authoring and management to NCEC enables you to maintain compliance through our skilled and experienced authors. You can read more about our SDS services at our dedicated?SDS webpage.
Non-compliance with local adoption of GHS and in the EU with REACH Annex II can lead to business and reputational risks.?Part of this compliance is the mandatory inclusion of a telephone emergency response number in section 1.4 of your SDS.?Find out which numbers are required on your SDS.?At NCEC, we offer a market leading telephone emergency response service that provides advice, not just information. You can find out more about this service?here.
Key insights into the upcoming regulatory changes from SETAC Copenhagen 2022
In May 2022, NCEC’s Environmental Chemistry and Toxicology team and Ricardo’s Life Cycle Assessment team attended the 32nd SETAC Europe annual conference in Copenhagen, Denmark.
The team presented, co-chaired and attended discussions and are now sharing some key insights which we think are going to have the most impact on the chemical industry in the coming year, including the Chemicals Strategy for sustainability, persistence initiatives, per and polyfluoroalkyl substances (PFAS) and UK and EU REACH.
We recommend utilising our?horizon scanning service?that can perform a substance inventory check and identify whether your substances appear on any global regulatory lists, to understand the impacts of current and upcoming changes directly on your own portfolio.?You can download a sample of our horizon scanning and compliance report?here.
If you'd like further assistance?with REACH,?poison centre notifications,?SDS compliance and any other chemical regulation or?want to discuss your emergency response requirements, please contact our team at [email protected] or visit our?website.