The need for a 24-hour emergency telephone number

By Marko Buchholz, UMCO

The safety of people and the environment is paramount when chemicals, mixtures and hazardous goods are being transported. Nonetheless, should an accident occur despite all safety precautions, it is essential that the necessary steps be taken swiftly and reliably. This is ensured by requiring companies to include an emergency telephone number on their transport documents and safety data sheets. However, given that regulations are usually set at a national level, the rules governing their implementation tend to vary from one country to the next.

This means that a swift resolution to problems can be hampered not only by language barriers, especially at the international level, but also by local vagaries. It would be helpful in such situations if a single, globally operating institution were on hand to initiate all the necessary procedures. All it would then take is for the person requiring assistance to make a single call and effective emergency crisis management would swing into action. In this article, we show why the current situation is more of a hindrance than a help, and what a globally operating institution, reachable under an emergency telephone number, along with proper safety data sheet management would change.

Emergency telephone number in safety data sheets

Article 31 and Annex II 1.4 of the REACH Regulation stipulate that safety data sheets must contain a 24-hour emergency telephone number. “If an official advisory body exists in the Member State where the substance or mixture is placed on the market […] 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.” However, despite the obligation under Article 45 of the CLP Regulation to provide product notification on dangerous mixtures, not all Member States provide emergency advice or only act as a contact point for medical personnel. In such cases, a company-based emergency telephone number or the number of an expert service provider capable of giving immediate expert emergency advice (preferably in the caller’s language) must be provided. In any event, REACH stipulates that the emergency telephone number of the official advisory body be listed in the safety data sheet and, if necessary, that of a second expert body if the official body does not provide emergency advice.

Both of these points are indicative of the scope of the challenges that start to emerge when safety data sheets are being compiled. To which countries do I want to send my products? Do they all have an official advisory body that can provide expert emergency advice? Where do I find the right emergency telephone number? Which language barriers need to be overcome?

Other lands, other numbers – different regulations

European regulation aside, other countries around the world also require that an emergency telephone number be provided in safety data sheets. However, the precise obligations governing this telephone number vary from one country to the next. These might not only stipulate that a national area code be included, but also require the responder to answer in the national language and to be available around the clock.

For example, SDS NOM-018-STPS-2015, the official Mexican standard governing the content of safety data sheets, stipulates in section 1.e of Annex D that a 24-hour emergency telephone number must be included. In Malaysia, the Globally Harmonized System (GHS) standard for the classification and labelling of chemicals (MS 1804:2008) also specifies that “the safety data sheet contain the domestic emergency telephone number (available 24 hours a day, including the area code) under which assistance can be obtained. Where a hazardous chemical is imported, the foreign manufacturer’s emergency telephone number (available 24 hours) can be provided for assistance during an emergency.” Moreover, safety data sheets must be written in both Malaysian and English.

Emergency telephone number in transport documents

And there are other occasions that require an emergency telephone number, such as hazardous goods transport. Calls for such a number first arose in the USA more than 20 years ago. Ever since then, a 24-hour emergency response telephone number must always be provided on the shipping documents (§ 49 CFR 172.604): “the shipper’s declaration for hazardous goods, as required by these regulations, must include an emergency telephone number in the event of an incident. During the entire transportation period of the hazardous goods, including incidental storage times, a person must be reachable at all times via this emergency telephone number [….].”

Over time, these provisions have become more and more specific and the requirements to be met have been enacted into law. Then there are the requirements laid down in the IATA Dangerous Goods Regulations. Here, again, the stipulations governing an emergency telephone number can vary greatly. An emergency telephone number is always required as standard. In addition, however, there may be requirements to have 24-hour availability, domestic area codes, or contact persons in the national language.

These stipulations vary not only at the national level but also by airline. (Section 2.8 of the IATA Dangerous Goods Regulations) China is particularly challenging in this regard: not only is 24-hour availability mandatory, but all hazardous chemicals must be registered before they can even be imported and transported. They must comply with Articles 5-6, Sections 2 and Article 22, Section 4, item 53 of the State Administration of Work Safety. These stipulate that only registration centres may be qualified to provide emergency services, one of which is the Chinese National Registration Centre for Chemicals (NRCC). The NRCC ensures that the emergency telephone number service is provided with the appropriate country code and contact person in the national language. Bear in mind that this only concerns registration for transport. Registration of products under the local chemicals legislation (comparable to REACH) is much more complex…

Challenges and opportunities

Furthermore, telephone communication may be difficult or even impossible in extremely urgent cases, such as those situations where the language in which the safety data sheet is written does not match that of the caller. Some organising is therefore essential to ensure that those needing assistance and e.g. the advisory body are able to make themselves understood to each other in the first place. Where do they get an interpreter in a hurry? Can they always be reached in the middle of the night?

Another problem is the accessibility of the specified emergency telephone number. While the provision of an official emergency telephone number may at first glance appear to be the simplest solution, the local contact body is not always staffed 24/7, a fact which means that at least one second contact person is needed.

In the worst case, the emergency caller comes up against a dead-end or first has to establish that the official body is not available before the alternative emergency telephone number is dialled, wasting precious minutes. It would make sense to have some sort of structure in place that would initiate all the necessary procedures and help the caller to deal with the situation swiftly and easily using the measures set out in his or her company’s own emergency plan. In that event, a globally operating institution would act as an interface and ensure that suitable experts are provided. Where details of the official advisory body to contact cannot be provided, many companies are faced with the difficulty of finding an expert contact person. The obvious solution would be to specify an in-house company employee whose mobile number is listed. However, it is doubtful whether that person can actually be reached 24 hours a day and whether he or she has the necessary knowledge and expertise to handle the situation properly in an emergency.

There is also the issue of data management. Some countries stipulate that safety data sheets always be available and that they be updated regularly. This in turn means that, to ensure compliance, a company must curate, transfer, and guarantee up-to-date data. This constitutes a major organisational exercise for suppliers that shift large numbers of products. Here, too, an external contact has to be provided if this task cannot be delegated in-house.