Submission Procedure

My certification template will expire soon, what should I do next?

Products are recertified in the same way they are initially registered. The chemical supplier needs to submit a HOCNF and SDS to the OCNS team at Cefas ( stating that they want to recertify their product. This can be done up to 6 months before the product expires. Please see section How to register a product to find more information.

Can I have a product classified under the UK OCNS, but not have it listed on the List of Notified Chemicals?

Yes. 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.

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, and we will discuss it with the UK government (BEIS) . If there is agreement that your substance is suitable, you should draft 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 ecotoxicological 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 we are satisfied with the data presented. We will then pass our recommendation to BEIS, that the chemical is suitable for PLONOR status. If BEIS are content, we will register the chemical as a temporary OCNS Group E, covering the period until three 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, we will notify the supplier. They will be required to submit a full HOCNF data set before a full three-year certification is granted.

The full procedure is described on page 3 of the Plonor Document.

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.

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. 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, as part of the application.

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?

If a supplier provides a letter of access allowing Cefas to refer to its data in the registration of a third-party product, the letter of access will be valid for the three-year registration period of the recipient product, even if a time restriction is stated in the letter of access. A new letter of access must be provided at each re-certification, dated appropriately

How do we report usage and discharge of drilling fluids to the EEMS database?

Water-based mud systems

Water-based muds containing <5% water-immiscible liquid should be reported as individual component products.

Organic-phase mud systems

Oil-based mud, synthetic drilling fluids, 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.