April 2017 Edition

ChemRegs Newsletter – April 2017

REACH May 2018 SME Guidance

The UK Chemicals Stakeholder Forum (UKCSF) has updated its 2015 SMEs and downstream user guidance on the 2018 REACH Registration deadline. The revised guidance is dated 27 April 2017 and provides a brief introduction to the registration element of REACH.

UKCSF advises government on managing risks to the environment and to human health that may result from the production, distribution and use of chemicals. The forum has 24 members, drawn from industry, environmental/animal protection/conservation and consumer organisations, trade unions and the scientific community. It works alongside other departments and government bodies including the HSE, the Department for Business Innovation and Skills and the Environment Agency.

The 31 May 2018 deadline is a key milestone that applies across the EU and in the UK to substances that are manufactured or imported into Europe annually in volumes between 1 and 100 tonnes. This is regardless of the UK’s current EU exit negotiations as REACH will continue to have legal force in the UK until the exit process is formally completed.

The European Chemicals Agency (ECHA) has estimated that the likely number of registration dossiers for the 2018 deadline will be greater than the combined number of dossiers submitted for the corresponding 2010 and 2013 registration deadlines for higher tonnage substances. Moreover, ECHA is also expecting a significantly higher number of small and medium-sized companies to be involved in the process, compared with the previous deadlines.

The aim of revised guidance is to raise awareness of the deadline and to help companies consider what they have to do, in particular to prepare and submit dossiers to ECHA. It is also aimed at downstream users who need to assess the potential for disruption to their supply chains if any substances that they depend are not registered.

The guidance is made up of three separate elements:

i) A 13-page generic note covering what SMEs need to know about the registration deadline, including flow charts to illustrate and explain the relevant processes. It explains about Substance Information Exchange Forums (SIEFs), registration costs and alternatives to animal testing;

ii) A 14-page self-assessment guide for SMEs, which are downstream users of low volume chemical substances (as formulators or end users) or distributors. It aims to help companies understand and create their product “portfolio” for registration purposes. There is advice on how to use the ECHA Registration database, how to engage with suppliers (including a template letter), and what to do if a substance is not going to be registered;

iii) A 3-page self-assessment questionnaire for SMEs who manufacture or import articles, to help them understand their registration and other obligations. A range of other useful information from official sources, and in particular, from sector-specific bodies, is also signposted.

The guidance can be downloaded from the UKCSF website at:

https://www.gov.uk/government/groups/uk-chemicals-stakeholder-forum

Other News

THE DANGEROUS GOODS EMERGENCY ACTION CODE LIST 2017

The Dangerous Goods Emergency Action Code List 2017 (EAC 2017) has been produced by the NCEC (National Chemical Emergency Centre) with the co-operation of the Home Office and is published by the Stationary Office (TSO).

The EAC List 2017 supersedes the 2015 list and is effective immediately in connection with the use of ADR/RID 2017 and is mandatory from 1st July 2017, which means EAC 2015 should no longer be used from that date.

Duty holders are required to use the EAC 2017 for the application of the appropriate Emergency Action Codes for tanks in Great Britain (GB) under the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (CDG 2009) (as amended), and in Northern Ireland (NI) under the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations (Northern Ireland) 2010 (CDG 2010) (as amended).

Emergency Action Codes, also known as Hazchem Codes, are designed for use by the emergency services in GB to indicate actions that may be necessary during an incident involving dangerous goods. They are displayed above the UN Number of the product on the orange Hazard Warning Panel.

Different requirements apply to GB domestic journeys and international journeys. CDG 2009 implements a national derogation that requires GB registered vehicles on GB domestic journeys to be marked with the EAC Code and to include a telephone number for advice in the event of an emergency. Vehicles with tanks etc on international journeys carry the HIN (hazard identification number – sometimes called the Kemler code) and are not required to display a telephone number.

EAC 2017 includes:

  • The new UN numbers (3527-3534);
  • Updates for UN Numbers, which been amended due to the addition of new sub risks, HIN, name changes or the fact that they are no longer ‘not subject to ADR’;
  • Changes have been made to EAC codes related to ammonia, changing the codes to advise ‘Contain’ rather than ‘Dilute’. Changes have also been made to EAC codes related to ammonium nitrate to indicate the possibility of a violent reaction. These changes have been made based on feedback from the emergency services.
  • Changes have been made to the HIN codes 40 and 768, reflecting changes in the 2017 edition of ADR;
  • Changes to APP codes. The APP (advice on additional personal protection) code provides additional information for emergency responders, but does not appear on the Hazchem plate. The APP code for UN1744 has been changed from B– to A(!) to take account of the potential for Bromine to damage Personal protective Equipment (PPE) materials and the APP code for UN2910 has been corrected from A (c) to B based on the boiling point of Bromine chloride.

EAC 2017 can be bought as a hard copy from TSO or downloaded for free at the NCEC website:

http://the-ncec.com/the-dangerous-goods-emergency-action-code-list-2017

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