Relying on European poison centres for emergency response exposes you to significant risk

08 Aug 2022

Ricardo have been working with many organisations across Europe who are displaying only the local poison centre numbers on section 1.4 of the safety data sheet (SDS). Whilst compliant for poison centre requirements and meeting the minimum REACH regulation requirements, these organisations are exposed to significant supply chain risks, as the poison centre number is intended to give medical advice to medical professionals only, and therefore are not equipped to provide meaningful advice and support to wider incidents such as chemical spills.

According to the REACH Regulation, when a telephone number is not available 24/7 or is limited in its use (e.g. for use by medical professionals only), this should be stated on the SDS and additional emergency numbers belonging to a supplier or competent third party should be stated.

Whilst supporting our customers with their regulatory compliance challenges, we have identified several French SDSs that only used the ORFILA (French poison centre) number. This number is free to use, provided the product is already declared in France, and when contacted the poison centre confirmed they redirect any non-medical calls 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 a supply chain 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.

Considerations for manufacturers

Ensure that there is a poison centre number as well as an additional emergency response number on your SDSs.
We recommend following the Cefic Guidelines for Level 1 Chemical Emergency Response and ensuring that your approach to emergency response number display is not focussed solely on complying with regulations. It must also consider risk management and response, crucially providing robust support to those involved in an incident with your products quickly, accurately and in a form they can understand and implement. If you only use a poison centre number on your SDSs, when a stakeholder calls about a non-medical emergency incident, they will face delays in receiving support - which can have significant implications on the scale and outcome of an incident.

Non-medical calls might get directed back to your organisation, but only when you provide an appropriate number, and in some cases you are unlikely to be told that an incident involving your product ever occurred. If a poison centre does redirect the caller to you, you need to consider if you have the capabilities to provide 24-hour emergency response for your products. Do you have the capabilities of providing support in the local language of callers throughout your supply chain, and the chemical knowledge required to provide actionable advice, rather than just product information?

If you only use a poison centre number on your SDSs and you do not have these capabilities or are not made aware of an incident involving your product, you are exposed to the very real risk of harm to your stakeholders, the communities in which you operate, the environment, your organisation’s assets, reputation and, ultimately, bottom line.

Why you should choose Ricardo as your telephone emergency response partner

We put your needs first. We build partnerships with our customers by working closely with you to understand your needs to create a bespoke service that supports your organisational requirements, such as global compliance, risk management and sustainability obligations.
A trusted partner, available at all times to provide advice to callers at an incident. Our emergency responders are qualified chemists with tactical awareness, combined with ‘real-life incident intervention’ experience, which enables them to support callers to safely intervene at the scene of an incident. Our service is available 24/7/365 through a network of international telephone numbers and local language speakers, so it looks and feels like a local service.
Reduce your financial and operational risk throughout the supply chain. By mitigating the impact of incidents before they escalate, causing disruption throughout your supply chain, impacting your assets and reputation, our emergency responders provide reliable advice that is proportionate to the incident. This reduces over-responding that could result in unnecessary costs.

Our experienced team take into consideration your organisation’s needs and global regulations to build a service that meets your requirements, rather than take a one-size-fits-all approach.