Chemicals used in the exploration, exploitation and associated offshore processing of petroleum in the North Sea are required to be registered under the Harmonised Mandatory Control System (HMCS) for the Use and Discharge of Offshore Chemicals (OSPAR Decision 2000/2).
Companies are required to submit a Harmonised Offshore Chemical Notification Form (HOCNF) to notify chemical products that will be used or discharged in the marine environment. The HOCNF submission must include hazard data derived using OSPAR approved test protocols relating to:
In addition to submitting the HOCNF, companies registering chemicals under HMSC need to demonstrate compliance under REACH.
Our team of experts can assist you with the preparation of the HOCNF submission for chemical use and discharge in the North Sea. We can complete a data gap analysis, develop testing strategies, facilitate communication with the Competent Authorities and assess REACH compliance as part of the preparation of your HOCNF submission. We understand the challenges that the chemical industry is facing to meet regulatory compliance and we can provide the adequate support you need to guide you through the process. Our experts have developed years of experience with HMCS and REACH and can provide the required expert scientific advice and policy support on hazard and risk assessments for offshore chemicals.
We can assist you in the approval of chemicals for use in the offshore oil and gas industry in the North Sea. For new products requiring registration, we can recommend adequate testing strategies for HOCNF submission and conduct testing for you. For existing products requiring re-registration, we can conduct a completeness check of your HOCNF form and review compliance of the data with the OSPAR HMCS requirements.
A weight of evidence approach can be used to assess ecotoxicological endpoints required under OSPAR HMCS. This approach will help reduce time, costs and animal testing, whilst maintaining the highest degree of scientific thoroughness. We can formulate weight of evidence cases as part of your HOCNF submission, when appropriate under the scheme.
Offshore chemicals are subject to requirements under OSPAR, REACH and BPR depending on the type of chemical and/or its primary function. Different criteria and requirements apply to the same chemical under these three legislations. We can help you manage your obligations by assessing the impact of each regulation on your substance and advising on the applicable regulatory requirements. Learn more here
We offer substitution strategies, which incorporate the concept of Green Chemistry, and allow us to promote sustainable substitutions. If your products contain substances with an unacceptable hazard profile, or if their components become subject to restrictions, your business may decide to replace them with more benign alternatives. Our experienced development chemists and Green Chemistry experts can support you in creating a comprehensive substitution strategy, giving due consideration to the implications for your manufacturing processes and product applications. Learn more here