Update – Annex VIII to GB-CLP – early details on how to comply from NPIS

Dear Friend,

Following on from yesterday’s email about Annex VIII to CLP being retained within UK law.

Our client has gone back to NPIS, who have confirmed the following:

For any product notifications you have made since Jan 1st 2021 to ensure compliance it would be best to re-submit in the harmonised format, just as you do for Northern Ireland. If you have already submitted safety information for Northern Ireland for an identical product sold in GB, then those will already be on the system – and can be considered as notified.

The only products that require action will be where NPIS was provided with only a safety data sheet.

RE timescales this information has not been cascaded to us as yet, as NPIS is not responsible for enforcing the regulation only to receive the information….

We have on our website (www.npis.org) guidance on how to use IUCLID to meet your obligations under Annex VIII – however we are currently trying to very rapidly update the information we have in light of these changes, but we hope this will be back online within the next 24h.

So my reading of the situation yesterday was correct:

• the method for informing NPIS of hazardous mixtures for mainland GB is the same as for Northern Ireland, that is you create a PCN IUCLID6 file ( .i6z file), and email it direct to NPIS on their public email sds.npis@nhs.net​
• if you have already done this for Northern Ireland, it will be deemed to cover the UK as well, so you don’t need to resubmit

Notes

1. The NPIS industry pages on their website do appear to have been taken offline at the time of writing, 8:30 am, Thursday 3rd February 2022.
2. Top tip – if you are going to email IUCLID6 files to NPIS – they are created as zip files, that’s what the z at the end of the filename stands for, so don’t re-zip them as it corrupts them (many thanks to Alan Ritchie of WSP for this, something I’ve been guilty of doing in the past)

Breaking news 3rd Feb – NPIS have just confirmed UFI will be required for GB Poison Centre Notification, but are unsure of how this will be generated.

I will be running a webinar on how to use the online IUCLID6 system for PCN for our affected client next week, drop me an email if you’d like to join us.

In the meantime, I’ll keep you posted if there are any developments. I’ve asked the Prime Minister about this via LinkedIn, but as this seems to be mainly used for PR purposes, I’m not expecting a sensible reply.

If any of our trade body contacts, eg CIA, CBA have any details on this, please let me know and I’ll circulate them.

Kind regards,

Janet

Janet Greenwood

TT Environmental Ltd

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