TTE Newsletter 24–COMAH deadline, IUCLID6 release, Waste documentation changes etc

Welcome to the first of the new format TT Environmental newsletters, which you are receiving because you’ve signed up from our website; are a subscriber to our old newsletter; or are a client or contact of ours.

I hope you find it useful, but if you don’t want to receive future emails, please use the unsubscribe button at the bottom of the email, which will automatically remove you (and if this doesn’t work, send me an email separately to ).

COMAH deadline 1st June 2016

If your site comes under the COMAH 2015 regulations, , don’t forget that you need to reclassify your inventory for CLP and recalculate your COMAH liability, and re-notify the HSE using an excel form, by 1st June 2016, which should be sent to them at a dedicated email address.  Full details are available on the HSE website at .

You also need to send a report on the changes in classification, including any new COMAH liable materials and Major Accident or MATTE hazards, to your COMAH Inspector, or COMAH Intervention Manager (CIM) by this date as well.

There seems to be different expectations on the amount of information required, so check with your CIM to see what they are expecting to receive.  Some sites are being asked to produce a new Environmental Risk Assessment to CDOIF standards, which is usually takes quite a lot of time and effort, and we recommend that if you can put this back to your next 5 year rewrite (if Upper Tier), or until a later date (if Lower Tier), then this will save time as we run up to the deadline.

Another thing to watch out for is that if you are having to produce a CDOIF ERA, version 2 is due to be published soon, but version 1.0 is still on the HSE website, so you may want to ask your CIM for a copy of version 2 to ensure your report meets these requirements.  CDOIF information is available at .

Finally, there is also the new requirement to put limited site information on the HSE website, to comply with the Public Participation Directive part of the COMAH 2015 regulations, see .

For non-COMAH sites, you may need to check your COMAH liability to make sure you are still below the COMAH threshold.

Anyone who still needs to carry out their COMAH calculation, or would like to check that their calculation is accurate may be interested in our SevaluateTM software, which is a very quick and accurate way of calculating COMAH liability, .

Infocards from ECHA may be misleading

If you use data from ECHA, for example for obtaining CLP classifications of substances (e.g. for your COMAH reclassification, or for classifying mixtures where the component substances have CHIP classifications), you may have noticed that the chemical search function at ECHA changed recently, and that there are now different levels of information available.

Unfortunately, this can mean that misleading information is being provided unless you dig deeper into the databases, for details see here .

IUCLID6 has been released

If you are going to have to register one or more substances under REACH, the IUCLID software has just been updated to IUCLID6, for more details see .

This is one of the topics we will be discussing in the next Chemicals Regulation Self Help Group meeting on 7th June, for more details see www/ , and below.

Chemical Regulations Self Help Group

If you work in Regulatory Affairs, you may be interested in the Chemical Regulations Self Help Group.

We are a group of 45 chemical companies (plus a few helpful consultants) who meet quarterly to discuss problems with REACH, CLP and other chemical regulations.  The next meeting is on 7th June 2016, and as well as discussing how to install IUCLID6 safely, other topics include an overview of the REACH registration process; a report back on the ECHA Stakeholder meeting on 25th May 2016 (as I have been asked to speak on behalf of the group about SME experiences of registration, see ); cost share discussions; and what to do if a Harmonised Classification is contradicted by REACH registration data.

There are two types of membership – attending meetings, and just receiving the meeting notes, which is useful for some of our members.

Membership of the Self Help Group is by invitation, and if you’re interested in joining, email me and I’ll pass the request on to the management team.  More information is available at .

Changes to Hazardous Waste documentation

A member of HCF’s Environment Group has kindly sent round a warning about a change to hazardous waste documentation:

Hazardous Waste consignment notes are changing as of 1st April 2016:

We need to start using 2007 SIC as we do for non-hazardous wastes. In addition, we no longer have to register as a hazardous waste producer.

Although:“If you are a producer or holder of hazardous waste and your premises, on 31 March 2016, had a valid premises registration number (or did not require registration), you may continue to use the old coding standard until 30 June 2016. If your registration number expired before 31 March 2016, you must use the new coding standard from 1 April 2016.”


I hope this information is useful, and if you need any help with any of these regulations, please contact me on 01422 24 22 22, or on

Kind regards,


Janet Greenwood

TT Environmental Ltd

Disclaimer: The advice we can give in newsletters like this is generic, and given in good faith based on our understanding at the time of writing.  You should check your own situation, and any applicable regulations, before deciding whether to take any actions based on advice in this newsletter.

Download pdf of newsletter here – TTE Newsletter no. 24 19-05-2016 .