Submission procedure

Water-based mud systems

Water-based mud 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.

You should discuss the substance with us, and we will discuss it with the UK government's Department of Energy and Climate Change (DECC). If there is agreement that your substance is suitable, you should draft an 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 DECC, that the chemical is suitable for PLONOR status. If DECC 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 in Mechanism for adding new chemicals to the OSPAR PLONOR list (PDF, 9.10 KB).

Re-brands of existing products are permitted under the OCNS, either as the same or a different name. Notification requires letters of authorisation from the company that owns the rights to the appropriate data on the HOCNF. (In rare cases this may be jointly owned.)

In addition, an HOCNF from the company, requesting the re-brand detailing their intended use and discharge of the product, is needed. A declaration that the formulation has not been altered from that of the original product may also be required.

This is likely to be because your company's recommended dosage is different from your supplier's.

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.

This common problem is easily solved by asking the manufacturer to provide the confidential details directly to Cefas, referencing your submission. The third party has our assurance that the data will be treated as "Commercial in Confidence" and will not be released to any other party, or used for any other purpose, without their specific written permission.

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.

Cefas maintains all the records of product submissions made to the OCNS on behalf of the UK's Department of Energy and Climate Change (DECC). This includes issuing the List of Notified Chemicals and product templates, which makes us responsible for the accuracy of entries on them.

It should be remembered that HOCNF documents are our only guide to the format of entry that is required on the list, and we will reproduce both the syntax and spelling of the company and product names as shown on these documents.

If changes to the text in the list or other documents are required, for any reason, we can be contacted directly in writing (email, fax or letter) and we will alter the database, if appropriate.

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, on a PON 15C.

This is due to variations in the toxicity test, biodegradation and partitioning data, and the dosages supplied by each company.