Harmonisation REACH and CLP requirements for natural gas, natural gas condensate and crude oil by Dutch Operators.
In 2012-2013, in response to some findings from the State Supervision of Mines (SSM) as competent authority,
the NOGEPA Action plan to harmonise the product definition and main REACH & CLP requirements for the upstream production of natural gas, natural gas condensate and crude oil was prepared. This was a joint effort of Jongerius Consult and the NOGEPA Taskforce Chemicals.
In 2013-2014, Jongerius Consult supported NOGEPA to practically implement the NOGEPA Action plan amongst the participating Member Companies. A specific NOGEPA Guidance to determine the role and responsibilities for the upstream operators was developed. It contains a descision tree & documentation template that takes notice of the complex cooperation forms of operators in the upstream production and distribution of natural gas, natural gas condensate and crude oil. A harmonised set of NOGEPA CLP classification and labelling proposals was developed. This was used to facilitate a CLP Group notification for the relevant Operators. Finally, a NOGEPA SDS Template (in English and Dutch) was developed using the SDS Templates of Jongerius Consult. The individual Operators were supported how to use and implement the deliverables of the project were needed under their own responsibility.
Further strategic and practical REACH & CLP support is nowadays provided under a chemical management framework agreement.