Submission procedure
1. How do we report usage and discharge of drilling fluids to the EEMS database?
Water based mud systems (WBMs):
Water based muds (WBMs) containing <5% water-immiscible liquid should be reported as individual component products.
Organic phase mud systems:
Oil based muds (OBMs), synthetic drilling fluids (SMs) and emulsified water based muds containing >5% v/v water-immiscible liquid should be reported as made-up mud systems i.e. as shipped offshore. This should include any additional whole mud made up offshore. Additives and contingency chemicals put into the mud on the drilling rig should be reported separately.
2. I want to use a substance, which I think would be suitable as a PLONOR. How do I get it added to the PLONOR list?
You should discuss the substance with Cefas who will discuss it with DECC. If they both agree that your substance is suitable you should put together a HOCNF containing a data set that meets the criteria laid out the preamble to the PLONOR list (preferably in electronic form). References must be given for eco-toxicological data and a brief supporting justification should be added.
Cefas will review the data to ensure that the criteria for candidate PLONORs are met and that they are satisfied with the data presented. They will then pass their recommendation that the chemical is suitable for PLONOR status to the DECC and if DECC are content, Cefas will register the chemical as a Temporary OCNS Group E until 3 months after the next meeting of OIC (or the following meeting if the chemical is submitted within 20 weeks of the next meeting).
If OIC decide that the candidate substance is not suitable for addition to the PLONOR list, Cefas will notify the supplier, who will be required to submit a full HOCNF data set before a full 3-year certification is granted.
The full procedure is described in the attached document: Adding new PLONORs (PDF, 15 KB)
3. What data is required if I wish to re-brand another company's product?
Re-brands of existing products are permitted under the OCNS either as the same or a different name. Notification requires letters of authorisation from the company that owns the rights to the appropriate data on the HOCNF (in rare cases this may be jointly owned) and an HOCNF from the company requesting the re-brand detailing their intended use and discharge of the product. A declaration that the formulation has not been altered from that of the original product may also be required.
4. One of my products is a re-brand of an existing notified product, why has Cefas placed it in a different hazard band?
This is likely to be because your company's recommended dosage is different from your supplier's.
5. If I provide a letter of access for data on a chemical, which I manufacture and/or supply to be used in the certification of a re-brand or as a component in another company's product, can that permission be time bound?
It is common for manufacturers or suppliers of products to require letters of access to enable read across of their product test data to be requested each time that the product is recertified. This permission can be bound to a specific period of time or, if left unspecified, Cefas will commonly request a new letter of access after three years. The arrangement may be changed or terminated at any time by a written request to Cefas from the owner of the original data.
6. I wish to notify a product but the manufacturer will not give me confidential formulation details, what can I do?
This common problem is easily solved by asking the manufacturer to provide the confidential details directly to Cefas referencing your submission. The third party has our assurance that the data will be treated as 'Commercial in Confidence' and will not be released to any other party, or used for any other purpose, without their specific written permission.
7. Can I have a product classified under the UK OCNS, but not have it listed on the List of Notified Chemicals?
This can be easily arranged and can be useful in situations where a company wishes to market a product that they do not supply directly for use offshore themselves, but which will be re-branded by other companies for use offshore. All that is required is an accompanying letter from the company concerned requesting that this action be taken.
8. What can I do if I notice an error in our Company's entry on the List of Notified Chemicals or product templates?
Cefas maintains all the records of product submissions made to the OCNS on behalf of the DECC. This includes issuing the List of Notified Chemicals and product templates, which makes Cefas responsible for the accuracy of entries on them. It should be remembered that HOCNF documents are our only guide to the format of entry that is required on the list and we will reproduce both the syntax and spelling of the Company and Product names as shown on these documents. If changes to the text in the list or other documents are required, for any reason, Cefas can be contacted directly in writing (email, fax or letter) and we will alter the database if appropriate.
9. Do chemicals used in commissioning submarine oil and gas pipelines need to be notified to the OCNS?
The use and discharge of pipeline commissioning and hydro test chemicals are covered by the Offshore Chemical Regulations 2002 and suppliers of such chemicals are therefore required to submit an HOCNF as they would for any other offshore chemical. Pipeline operators are required to submit risk assessments discussing the use and discharge of pipeline chemicals on a PON 15C.
10. Several companies sell similar generically named products, why do they all have different HQs?
This is due to variations in the toxicity test, biodegradation and partitioning data and the dosages supplied by each company.
