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Other | July 25, 2019

Do you know the saying that history is life's teacher (Historia, magistra vitae)?

The current situation involving the UFI code and PCN notification, which will enter into force in January 2020, shows that we are not very good students.

To understand why I dare write this, let's return to 2015 for a moment.

After 47 years (and a long transitional period), we finally transferred from DPD to CLP legislation that year.

The transition involved transferring from "orange X square boxes" as I had often heard, to "superman pictograms".

Even though deadlines were known, information and materials were available, and people knew and were warned about which and in what way the matter would be checked, panic started.

Until the last moment, companies had tried to catch the deadline and some of them had even stopped trading with chemicals for a short time.

Too much unnecessary stress and bad temper for something that could be turned into a competitive advantage of the company. 

Happening around UFI and PCN in 2019 reminds me about this period four years ago.

Deadlines are known in this case, too. We all know what must be done and how it will be checked.

But even now, by the last moment, nobody really believes UFI and PCN will happen.

The time necessary for appropriate and timely preparation for new legal requirements is underestimated again.

We have received a few calls, but until now, just a few companies have seriously started preparing for the arrival of the UFI code and PCN notification.

When I talk to people, I often hear about the hope that the transitional period will be extended or that inspectors will give them additional time. This hope, as we were able to see in 2015, can cost you a lot of money.

Everything that happened four years ago is happening today.

The lesson from 2015 obviously wasn't painful enough.

"UFI and PCN do not represent such a major difference as the transition from DPD to CLP legislation," you might say.

That's true. I won't argue that.

Physically, the only visible change will be the added UFI code on the label. Nothing major to worry about, right?

Not quite so. This time the big change is in the background, outside our field of sight.

This is a comprehensive change involving the submission of information about hazardous chemicals and communication along the supply chain. UFI and PCN affect the entire supply chain.

The key words here are "supply chain".

The time, necessary for proper regulations, can be extremely long.  Just think about 2015, when you needed new original safety data sheets. How long did you wait for them? How much effort was necessary to be able to explain to your suppliers why they were obligated to send them to you.

If you think that this time is going to be easier, I assure you that you are wrong.

What is our role in all this?

We have already made the first step. Namely, training connected to UFI and PCN. Some information have been posted on BENS blog and BENS LinkedIn website.

The other part is presented in videos on BENS Youtube channel.

The third step involves active help and searching for solutions that will simplify your life. We have sent template letters in English to our monthly clients, who can simply use them when communicating with their suppliers.

We have prepared solutions with regard to a timely application to the ISC for clients who place hazardous chemicals on the market in Slovenia, thus enabling the deferral of obligations until 2025.

Finally, for the past few months, a team of our programmers has been developing a solution that will help you manage requirements with regard to the UFI code and PCN notification.

As you can see there is a possibility to avoid the troubles that occurred in 2015.

All you have to do is to act in time. Take small steps, like writing letters to your suppliers. It is important that you begin.

If you need help with that or you don't have the time and energy to do that, contact me.

I am convinced that we can still help you get things sorted in time. I will not be able to give you that promise at the end of the year.

Disclaimer:
Information on this blog is prepared with utmost care, but it is not about (chemical) consulting, and the provider does not assume any responsibility or liability for the correctness, accuracy and up-to-dateness of published content. If you need advice for a specific case, you can write to us at bojan.dimic@bens-consulting.com

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