Flagging of plastic and microplastic in offshore chemicals – an update.

Further to Cefas’ bulletin board announcement entitled “New labelling requirements for plastics and microplastics contained in offshore chemicals for the United Kingdom (UK) and Netherlands (NL) (Updated)” on 11 October 2023. Cefas are now in the position to provide an update on the future strategy to flag plastics and microplastics on offshore chemical (product) templates.

OSPAR Recommendation 2010/03 and OSPAR Agreement 2012-05 have been amended to reflect on the use of plastics and microplastics contained in offshore chemicals by the offshore oil and gas industry. The Harmonised Offshore Chemical Notification Format (HOCNF) form (Recommendation 2010/03) now requires chemical suppliers to identify whether their offshore chemical product(s) contain(s) plastics and microplastics in table 1.6b.

Since November 2023 Cefas have been able to flag any offshore chemical whereby the chemical supplier has indicated that their offshore chemical contains plastic/ microplastic and Cefas has flagged offshore chemicals on renewal or when newly submitted to the Offshore Chemical Notification Scheme (OCNS).

From April 2025, Cefas will conduct a review of offshore chemicals whereby a plastic or microplastic flag on a product template has already been given. A product list will be generated looking at the a chemical suppliers offshore chemicals containing the same plastic/microplastic substance and a blanket flag applied across their offshore chemical products. This will ensure that for substances where Cefas are already notified via the HOCNF that a plastic/microplastic is present that all offshore chemicals, from the same supplier, will receive a product warning flag (as demonstrated in the previous bulletin board notification).

Once the initial review has been completed Cefas will continue to apply blanket flags across multiple offshore chemicals where the substance is already flagged as plastic/microplastic by the same supplier on the HOCNF. This will form part of Cefas’ routine hazard assessment checks.

At the same time, Cefas will also focus on offshore chemicals where the presence of plastic/microplastic is heavily regulated. Currently only plastics or microplastics in Lost Circulation Materials (LCM) are prohibited from discharge in the UK and therefore any offshore chemical that meet the criteria as a LCM and contain plastic/microplastic will be flagged on the product template to inform the risk assessment.

Suppliers will receive updated offshore chemical product templates in due course. Supplier may also receive requests for information in cases where the information provided on the HOCNF is not clear to hazard assessors during the review. Any further updates to the strategy will be communicated through the Cefas Bulletin board.