Emergency Response Compliance – Providing Clarity in a Challenging Regulatory Arena

In this article, CHEMTREC provides a snapshot of the complex emergency telephone number requirements around the world and points out the challenges of complying with ever-changing supply and transport requirements for emergency response provision.

In Annex 4, the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) lays down its requirements for the provision of an emergency phone number in Section 1 of the Safety Data Sheet (SDS), namely:

“References to emergency information services should be included in all SDS. If any restrictions apply, such as hours of operation (e.g. Monday - Friday, 8:00 a.m. - 6:00 p.m., or 24 hours) or limits on specific types of information (e.g. medical emergencies, or transportation emergencies), this should be clearly stated.”

During the implementation of the GHS at the national level, many countries have supplemented the GHS requirements with their own requirements for 24-hour availability, in-country (local) phone numbers, and responses in national languages. Some countries even set the type of phone number required, such as a landline or freephone/toll-free number.

On the transport side, while most of the modal regulations, apart from air transport (ICAO/IATA), do not technically require the provision of an emergency phone number on the SDS, several countries require an emergency phone number to be displayed on the vehicle placard or on the shipping documentation.

It is important to note that even where an emergency phone number is not required by the regulations, many transporters/logistics providers have made it their policy to ask for a 24-hour emergency number for all dangerous goods shipments. The reality is that you will find it extremely difficult to move your dangerous goods without having to provide an emergency phone number, whether regulatory requirements exist or not.

Beyond regulatory requirements and emergency services, users of the product and regulators will expect to be provided with a phone number in their country and to be able to speak their own language. An organization placing products on the market and/or shipping internationally also needs to carefully consider these expectations.

The table below provides a non-exhaustive list of specific emergency telephone number requirements throughout the world.

The days of having a single emergency phone number for your organization are most likely over. If your organization requires more than one emergency phone number, you will have to tackle the following operational issues:

• Obtaining the right type of telephone number with a sufficient level of resilience in the various countries you need. This can be very challenging, especially if you do not have a physical presence in those countries, due to increasingly stringent local telecommunication regulations; and
• Your team of emergency responders may not speak all the languages you require or be available on a 24/7 basis. You will need to source an over-the-phone interpretation service that is able to provide you with an interpreter without a prior appointment on a 24/7 basis, which again is a challenging task.

As the world’s leading Emergency Response Information Provider (ERIP), CHEMTREC had to find solutions to these challenges to offer our customers a complete emergency response solution supporting international compliance with both regulations and callers’ expectations. We encourage you to contact CHEMTREC or CIRS for support or guidance on how to keep your company compliant and protect people, the environment, assets and reputation while keeping your supply and transport chains running smoothly, avoiding penalties or holdups, and helping you avoid penalties and fines for non-compliance.

CHEMTREC is a division of the American Chemistry Council (ACC) and is the world’s leading ERIP, supporting over 30,000 public and private sector organizations worldwide.

For more detailed information on the emergency phone numbers regulatory requirements worldwide, download the CHEMTREC guide available at https://www.chemtrec.com/CIRSguide.

CHEMTREC will be sponsoring our Global Chemical Regulation Conference in London on October 5, you can find out more here and have the opportunity to meet members of the team at the event.