ChemRegs Newsletter – June 2018
New inspections for internet sales of hazardous chemicals
The European Chemicals Agency (ECHA) Forum for Exchange of Information on Enforcement (the Forum) recently published the findings of a pilot enforcement project focusing on the control of internet sales of hazardous chemicals (see our April Newsletter).
The Forum is a network of authorities responsible for the enforcement of the REACH, CLP and PIC regulations in the EU, Norway, Iceland and Liechtenstein.
The project looked at whether the advertisements of hazardous chemical mixtures offered for sale on the internet complied with the requirements of Article 48(2) of the Classification, Labelling and Packaging (CLP) Regulation. This provision requires that an advertisement for a chemical classified as hazardous under CLP has to state the hazards in the advertisement itself, if the chemical can be purchased without first seeing the label.
Inspectors checked various types of distribution websites such internet auctions/platform, professional suppliers’ internet shop, private advertisers and others, including do it yourself (DIY) online shops and global distributors of various products.
Out of a total of 1 314 internet advertisements checked, over 80 % were found to be non-compliant with the requirements of Article 48(2) of CLP.
Based on this high rate of non-compliance, ECHA issued a set of recommendations, including that the Forum consider including the topic on the control of internet sales in a future REACH-EN-FORCE (REF) enforcement project.
REACH-EN-FORCE (REF) projects are designed to harmonise enforcement in each Member State and check the current level of compliance with regard to particular obligations imposed on industry by the REACH, CLP and PIC regulations.
The REF-projects are carried out by inspectors based in the national authorities in the participating Member States e.g. the HSE in the UK. The resulting information is collected by ECHA and the Forum Working Group and a final report on the findings of the REF-project is then produced.
The Forum held its 30th meeting on 19-20 June 2018 in Helsinki and decided that the eighth major Forum enforcement project (REF-8) will concentrate on online sales of substances, mixtures and articles.
The detailed scope to be checked under REF-8 is yet to be defined, but is expected to include restrictions and labelling duties for hazardous chemicals. The project will be prepared in 2019 and carried out in 2020, with the report expected to be published by the end of 2021.
Other News
REMOVE: Guidance on removing hazardous substances
REMOVE: Guidance on Removing Hazardous Substances is now available on the National Counter Terrorism Security Office (NaCTSO) web site.
This guidance is designed to help people respond safely to incidents involving hazardous substances, including ‘acid attacks’.
The REMOVE web-page contains a variety of downloadable material, including graphics and downloadable pocket guides and a ‘How to embed REMOVE into your organisation’ guide.
Security personnel and other staff may be the first responders to an incident where people have been exposed to a hazardous substance. The REMOVE REMOVE REMOVE protocol is closely aligned to guidance for the Emergency services and provides simple, consistent advice on early actions following:
- Suspected deliberate or accidental exposure to a hazardous substance (vapour, powder or liquid) or
- An ‘acid attack’
REMOVE REMOVE REMOVE is specifically designed to be easily understood, remembered and applied. The advice can be implemented without specialist protective equipment and is relevant for any potential hazardous substance incident, enabling any responder to provide an effective initial response until the emergency services arrive and beyond.
The protocol is endorsed by Public Health specialists, as well as all three emergency services who are embedding it throughout the UK.
ECHA Guidance and tools for downstream users
ECHA has published the latest edition of its factsheet that provides an overview of guidance and tools for users of chemicals.
This factsheet is available in 23 EU languages and can be found in the Communication in the Supply Chain section of ECHA’s website, or can be downloaded from our website here du_in_brief_en
ECHA believes that quality information is critical for all actors along the supply chain – from companies manufacturing and importing chemicals who need to assess their safety, to users wanting to ensure safe handling.
The factsheet gives links to web pages, videos and guidance to help users get the information they need to handle their chemicals safely.
IMDG 2018
The latest version of the International Maritime Dangerous Goods IMDG Code, 2018 Edition (inc. Amendment 39-18) and IMDG Code Supplement, 2018 Edition will be published in September 2018.
The IMDG Code has undergone many changes over the years, in both format and content, in order to keep up with the rapid expansion of the shipping industry.
Amendment 39-18 includes revisions to various sections of the Code and to transport requirements for specific substances. It was adopted by IMO’s Maritime Safety Committee (MSC) at its ninety-ninth session in May 2018.
The IMDG Code lays out the regulatory framework for all aspects of handling dangerous goods and marine pollutants in sea transport, but does not include all details of procedures for packing of dangerous goods or actions to take in the event of an emergency or accident involving personnel who handle goods at sea.
The IMDG Code Supplement includes the publications associated with the IMDG Code that cover these aspects of the transport of dangerous goods.
The 2018 edition of the Supplement features:
- The Revised EmS Guide
- The Medical First Aid Guide
- Recommendations on the safe use of pesticides in ships
- The INF Code
- Other appropriate resolutions and circulars pertaining to the transport of dangerous goods
Amendment 39-18 of the Code is mandatory as from 1 January 2020 but may be applied in whole or in part on a voluntary basis from 1 January 2019.
For more information on anything in this Newsletter, please contact us at info@chemregs.co.uk

