If you are responsible even for the transport of adhesives in small tubes you need an emergency phone number, not only for airfreight shipping documents but also for the safety data sheet.
By Ulrich Mann
GBK GmbH Global Regulatory Compliance, Ingelheim, Germany
Having an emergency telephone number is a legal requirement for:
- US-Transport: DOT § 49 CFR 172.604 (Docket HM-126 C)
- Air freight: IATA-Dangerous goods regulations – Deviations of the Governments and Airlines
- Sea freight: IMDG-Code
- Safety data sheets: REACH Annex II Requirements for SDS – EU-Regulation 1907/2006 (Registration, Evaluation, Authorization and Restriction of Chemicals)
If you do not comply with these requirements there can be several consequences, such as the refusal of transport by airlines and shipping companies. It can also lead to a breakdown of transportation flow due to official bans including the risk of fines of up to $10,000. The end result can also lead to product liability risks. In order to avoid these risks, there is a simple solution. GBK GmbH Global Regulatory Compliance can take care of these responsibilities on your behalf. You supply us with the necessary data and we can take care of everything else. We will provide you with the following support services:
- Access to our emergency call center (24 hours / 7 days)
- Emergency call service in 170 languages
- Fulfillment of your legal obligations
- Transposition of the airline and shipping company requirements
- Medical advice in case of poisoning
- Additional in the USA: Disposal service
US-DOT definition of “emergency response information”
The US-DOT definition of “emergency response information’’ means information that can be used in the mitigation of an incident involving hazardous materials and, as a minimum, must contain the following information:
- The basic description and technical name of the hazardous material as required by Sec. Sec. 172.202 and 172.203(k), the ICAO Technical Instructions, the IMDG Code, or the TDG Regulations, as appropriate (see Sec. 171.7 of this subchapter);
- Immediate information regarding hazards to health;
- Risks of fire or explosion;
- Immediate precautions to be taken in the event of an accident or incident;
- Immediate procedures for handling fires;
- Initial procedures for handling spills or leaks in the absence of fire; and
- Preliminary first aid measures
- Further requirements regarding Emergency response (DOT):
- a) A person who offers a hazardous material for transportation must provide an emergency response telephone number, including the area code or international access code, for use in the event of an emergency involving the hazardous material.
The telephone number must be monitored at all times that the hazardous material is in transportation, including storage incidental to transportation.
- b) The telephone number of a person who is either knowledgeable of the hazardous material being shipped and has comprehensive emergency response and incident mitigation information for that material, or has immediate access to a person who possesses such knowledge and information.
and c) entered on a shipping paper in a clearly visible location. This provision may be used only if the telephone number applies to each hazardous material entered on the shipping paper, and if it is indicated that the telephone number is for emergency response information (for example: “EMERGENCY CONTACT: * * *). The telephone number required by paragraph (a) of this section must be the number of the person offering the hazardous material for transportation or the number of a competent agency or organization accepting responsibility for transportation and capable of providing detailed information concerning the hazardous material.
Requirement for an Emergency Telephone Number on Safety Data Sheets. Annex II of the REACh Regulation stated that under Chapter 1.4 of every Safety Data Sheet references to emergency information services shall be provided. If an official advisory body exists in the Member State where the substance or mixture is placed on the market (this may be the body responsible for receiving information relating to health referred to in Article 45 of Regulation (EC) No 1272/2008) its telephone number shall be given and can suffice. If availability of such services is limited for any reasons, such as hours of operation, or if there are limits on specific types of information provided, this shall be clearly stated. In addition to the above mentioned specifications, an Emergency Telephone Number of the company and/or an appropriate public information service as well as a commercial private support service provider of an emergency center can be given.
Don’t forget product Safety aspects
For compliance in other areas like detergents, the integration of the emergency response system into the companies is needed. It is also necessary that a toxicologist can be called in on demand. Last but not least, there are special national requirements for countries like China and Australia. In these countries, a national emergency response telephone number is required. The regulatory basis for the emergency telephone number on Chinese product labels, is “GB15258-2009 General rules for preparation of precautionary label for chemicals” and in “GBT 17519 2013 Guidance on the compilation of safety data sheet for chemical products.”
GBK – EMTEL® how it works in different modules
Module 1 – Providing the emergency telephone number for the transport documents (worldwide)
Module 2 – Providing the emergency telephone number for all MSDS (according EC-Guideline)
Module 3 – Providing the emergency telephone number for product labels (consumer product; just in combination with module SDS/MSDS)
Module 4 – Providing the emergency telephone number for China on the product label and in the MSDS
Module 5 – Providing the emergency telephone number for detergents
In order to be fully compliant, you have to fulfil the regulatory requirements regarding emergency response. The benefits of using the services of a professional provider include
- Capable solution for additional services concerning hazardous materials/goods
- Legal compliance
- Limitation of liability
- Reduction of internal costs and effort