National Poisons Information Centre (NPIC) in Dublin, Ireland, has published the national requirements regarding to poison centre notification (PCN) and the Safety Data Sheets (SDS) of these chemicals. You can find the post from NPIC here.
Today I’ll go through document and give you only summary of what you need to know.
Let’s start with the emergency number.
You still need to include the poisons centre emergency number in Section 1.4 of the SDS. This is obviously nothing new and it’s well known from the REACH regulation (Regulation EC no. 1907/2006).
Here’s that part from the document:
“It is obligatory to include a poisons centre emergency number in Section 1.4 of the SDS for a chemical mixture placed on the market if it is classified as hazardous on the basis of its health or physical effects (REACH Annex II). It is permitted to include (in addition) an external emergency number, as appropriate.”
I mention the phone number because the NPIC added a fee – annual retainer - for use of its phone number:
“The National Poisons Information Centre of Ireland (NPIC) charges an annual retainer for use of its telephone number on the SDS of chemical products placed on the market in Ireland. The annual retainer is €650 per company (or €200 if notifying less than 10 products).”
This is important change as it might affect your business in Ireland.
So, what do you need to do know now?
There are 4 steps NPIC has envisioned before you can use NPIC’s telephone number.
First, you need to notify your chemical mixtures to the NPIC as authoritative body. “Mixtures for consumer or professional use can only be notified to the NPIC via the ECHA PCN portal.” You can access ECHA PCN portal directly here.
On the other hand, you have until 31st Dec 2024 to notify mixtures for industrial use directly the the NPIC. You also have the possibility of using ECHA PCN portal for this if it’s easier for you. You can find link to that portal here.
Second, you need to sign the Agreement and Indemnity – link to word document you simply fill and sign here. You send this document to chemicalsinfo@beaumont.ie so they can sign it as well. NPIC will then send you the details of the telephone number to use on the SDS. One detail you need to be careful about is time you state in SDS - you should state that NPIC emergency phone number is available from 8am – 10pm every day.
Third, if you’ve already done your PCN notifications through ECHA PCN portal then just email a list o notified products or mixtures to NPIC.
And fourth, you’ll get an invoice from Beaumont Hospital for the annual retainer 2-3 weeks after the Agreement & Indemnity has been signed.
I know what you’re thinking - are there any exemptions or specialties regarding this process?
There’s a way you can avoid paying annual retainer fee, but that’s only valid for biocides. Here’s what NPIC says:
“If all your mixtures are biocides or plant protection products you must still comply with steps 1-4 above. You will not however have to pay the annual retainer, as this is already included in the registration fee paid to the Department of Agriculture, Food and the Marine.”
What happens if you don’t pay that retainer fee? Well, if you don’t pay it within 3 months of the invoice date then Agreement & Indemnity is no longer valid. But I didn’t see any fees for such misbehavior which doesn’t automatically mean there no penalty for that.
You also have to add additional emergency number if there is a delay in updating the SDS with the NPIC emergency number after the notification process is complete. “If there are any limitations to its use, this should be clearly stated in the SDS, until such time as the SDS is updated with the NPIC number”.
“When placing hazardous chemical products on the market in other EU Member States, the respective poisons centre/appointed body number, where established, is required to be included in Section 1.4 of the SDS. The poisons centre number in one EU Member State may not be used for other Member States.”
As you can see, keeping up with the chemical legislation is a demanding process.
If you wish to save time and focus on your work and sales, let me know. Write me an e-mail at luka.rifelj@bens-consulting.eu and let me know what challenges you are facing.
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