1 OSPAR Commission Summary Record OIC 2003 OIC 03/15/1-E, Annex 6 

### ANNEX 6 (Ref. § 3.11)

OSPAR CONVENTION FOR THE PROTECTION OF THE MARINE ENVIRONMENT OF THE NORTH EAST ATLANTIC

MEETING OF THE OFFSHORE INDUSTRY COMMITTEE (OIC)
LONDON (SECRETARIAT ): 10-14 MARCH 2003

________________________________________________________________________________________________ 

## OSPAR Guidelines for Completing the Harmonised Offshore Chemical Notification Format (HOCNF)

(Reference number: 2003-1)



### Introduction

1. The Harmonised Offshore Chemical Notification Format (HOCNF) 1 applies to all chemicals used in connection with offshore explorati on & production activities in the OSPA R maritime area. Exact chemical composition of preparations will be held in commercia l confidence in the relevant governmental bodies, and will not be published or transmitted to third parties.



### Data Requirements

2. For the purpose of these OSPAR guidelines, the following data requirements apply:
a. "mandatory data" must always be provided;
b. "conditional data" become mandatory when th e defined conditions mentioned in Appendix 1 of the OSPAR Recommendation 2000/5 on a Ha rmonised Offshore Chemical Notification Format (HOCNF) or in these guidelines are met;
c. "optional data" should be provided by the supplier if available and relevant.

3. The following text of these OSPAR guidelines rela tes to the provisions and requirements stipulated in Appendix 1 of the OSPAR Recommendation 2000/5 on a Harmonised Offshore Chemical Notification Format (HOCNF) and the 'parts' and 'paragraph numbers' mentioned in the headings and subheadings refer to that Appendix of that OSPAR Recommendation.



## PART 1: General information on substances and preparations

§ 1.3 Use

4. Information on quantities used and discharged an d on application categories is required based on standardised reference installations or, where appropria te on site specific use and discharge. The function is defined as the process for which the substance/preparation is normally or primarily used, e.g. drilling fluid, biocide, scale-inhibitor, demulsifier.

5. If the submitted chemical is suitable for assess ment by CHARM, choose an application from one of the four main CHARM algorithms: “Cementing”, “D rilling”, “Production” or “Completion/Workover”. Since the CHARM model incorporates Utility and Stimulation chemicals into the combined “Completion/Workover” algorithm, please do not select “utilities” or “stimulation” but indicate as a footnote

1 cf. Appendix 1 of OSPAR Recommendation 2000/5 on a Harmonised Offshore Chemical Notification Format (HOCNF)2 OSPAR Commission Summary Record OIC 2003 OIC 03/15/1-E, Annex 6 whether the chemical is a stimulation or utility ch emical. If the submitted product is a cementing chemical choose “other” and state “cementing”.

6. If the submitted chemical is not suitable for assessment by CHARM, advice should be sought from authorities on what information is requested in additi on to that required in the HOCNF. Such information may be that necessary to allow assessment by models other than CHARM.

7. The entry sections "state function(s) of the s ubstance/preparations" and "to which process system will the chemical be applied?" should confirm the func tion of the chemical and its mode of use. The function of the chemical should be taken from Appendix 2. If none of the listed functions are appropriate, enter the function as ’other’ and ensure that a clear written description is pr ovided confirming mode of use, fate and effect. The application process stream should define the process stream into which production chemicals will be dosed; or list the sections of a well in which the drilling chemicals will be used; or should reflect one of the four CHARM sub-algor ithms for cementing or completion chemicals.

8. For water based drilling chemicals, all the well sect ions, in which the product is likely to be used should be stated. The normal dose rate should be based on optimal technical performance and the appropriate sections of a standard well of the CHARM mode l (171/2’’, 121/4’’ and 81/2’’ sections) or, where appropriate, on site specific informa tion. Units should be clearly stated.

9. For production chemicals, state either “water” or “total fluids” as the pro cess system into which the chemical will be applied. “Total fluids” should be selected for chemicals dosed into single-phase hydrocarbon streams (either oil or gas) and the dosage should be based on the sum of the produced water and hydrocarbon production of the appropriate CHARM model platform. “Water” should be selected for injection chemicals and surfactants. St ate whether the production chemical is to be used on a gas or on an oil platform.

10. For all cementing chemicals except spacers, “mixwa ter” should be stated as the process system. For chemicals used in spacer fluids, enter “spacer” as the function of the chemical.

11. For completion chemicals, enter the function “su rface and well cleaning” for products used as rig washes or “other completion/workover” for any other products used in completion and workover operations.

12. If a product is used in several different app lications, data on function, process stream dosage, discharges etc. Should be applied on additional page s (§1.3 and §1.4) in the same HOCNF data sheet.

13. If the above sections have been filled in as indicat ed, then no more information is required to run the CHARM model. However, an estimation of the “freque ncy of treatment” and “probable scale of use” should be reported in this section of the HOCNF to inform site-specific risk assessment.

§ 1.4 Discharge

14. A substance/preparation should be assigned to the category "closed system" only if it remains within a reactor or is transferred from vessel to vessel thro ugh closed pipework and therefore accidental spillage is the only likely cause for human exposure or environmenta l contamination. Substances/preparations that are used in closed systems, but as a consequence of norma l use might be released into the environment after use or where significant discharges into the environment cannot be excluded during u se, should be assigned to the "open system".

15. Data in §1.4 must be given for all offshore chemicals.3 OSPAR Commission Summary Record OIC 2003 OIC 03/15/1-E, Annex 6 § 1.5 Fate

16. A description of the likely fate of the substance/pr eparation can be explained in general terms.. This should include whether the substance/pr eparation is likely to change its form on use and/or will end up in the sediment, the water column, the air or biota.

§ 1.6 Composition

17. In all applications concerning chemicals used offshore, the names of all deliberately added substances within a preparation sh all be reported to the competen t national authorities. Sufficient information must be available to operators to a llow them to properly assess the chemicals they use.

18. When providing this form to non-governmental organisations, info rmation regarding composition as normally given on a Safety Data Sheet (SDS) should be provided.

19. The full chemical composition must be given when submitting the form to government bodies. The complete and precise composition of the substance or pr eparation should be reported, including each "active" substance, "inert" substance, solvent and additive substance and their proporti ons, using CAS numbers and recognised chemical formulae or recognised chemical names for all substances.

20. Constituent substances should be named and concentration ranges given in accordance with the allowed variation 2 . The concentrations of each substance should be specific, but if these concentrations are variable the range should be quoted. If the toxicity test s are carried out on a preparation, the concentrations of each substance in the formulation used in the toxici ty tests should be quoted to enable authorities to assign correct relevance to these test values.

21. All substances, know n to be deliberately added, including tho se present at less than 1% by weight of an entire preparation, should be declared. Substances (except those stated in paragraph 1.7 of the OSPAR Recommendation 2000/5 on a Harmonised Offshore Chemi cal Notification Format (HOCNF)), which are not deliberately added and are present at less th an 1% by weight should not be declared.

22. Where a CAS number is not available for polymer s give the CAS number for the monomer on which it is based. The latest OSPAR List of Substances / Pr eparations Used and Discharged Offshore Which are Considered to Pose Little or no Risk to the Envi ronment (PLONOR) can be found on the OSPAR website (www.ospar.org).

23. Where generic descriptions are given such as tall oil soaps, polyoxyalkylated glycols, phenol/formaldehyde resins, reaction-products, copolym er series (on non-confidential HOCNFs supplied to operators) the source materials should be given, togeth er with the best description of the range of major substances/preparations present. Where solvents or ot her additives are refinery or petrochemical products consisting mainly or entirely of hydr ocarbons, the generic description (e.g. straight-chain alkenes, 3-5 ring aromatics) should be given together with the concen trations of any aromatics, and the method used for determination should be stated.

24. Please note that trade names will not be accepted as compositional information.

2 Concentration ranges:

Initial concentration range of the constituent Permitted va riation in initial concentration of the constituent

< 2,5% + 15% > 2,5 < 10% + 10%

> 10 < 25% + 6%

> 25 < 50% + 5%

> 50 < 100% + 2,5%4 OSPAR Commission Summary Record OIC 2003 OIC 03/15/1-E, Annex 6 § 1.7 Contents

25. For substances/preparations fo r which knowledge of the raw ma terials and manufacturing processes involved indicate that the substances will not be presen t, select the 'NO' box for all categories. Supportive evidence for the above should be provided where available in the 'Comments' box.

26. Annex 2 of the OSPAR Strategy with regard to Hazardous Substan ces and the latest version of the OSPAR List of initially selected substances of po ssible concern can be downloaded from the OSPAR website (www.ospar.org).



## Part 2 Ecotoxicological Information

27. Ecotoxicological information can be mandatory, co nditional or optional. If the offshore chemical is on the PLONOR List or all the relevant ecotoxicological information has already been submitted to the authority, Part 2 of Appendix 1 to OSPAR Reco mmendation 2000/5 on a Harmonised Offshore Chemical Notification Format (HOCNF) need not be completed.

28. Ecotoxicological data will only be accepted from test s performed according to international standard protocols or guidelines (as e.g. the OSPAR guidelines, ISO test guidelines and OECD test guidelines) and prepared by laboratories working in compliance with the OECD Good Laboratory Practice or laboratories approved by national authorities. Test laboratories shoul d follow the OSPAR Guidelines for Toxicity Testing of Substances and Preparations Used and Discharged O ffshore whenever samples are received for testing. The testing laboratories should confirm to the supplie r, in every case, that the validity criteria for the reference test have been met. Literature data of high quality (testing according to acceptable protocols and GLP or equivalent accreditation) should be accepted. References should be provided for literature data.

§ 2.1 Partitioning and bioaccumulation potential

29. N-octanol water partitioning data are required for all organic substances with the exception of those with surface active properties. For preparations, indivi dual information on all delib erately added substances is required. This can be estimated by measuring or calculating the partitioning of the substances between water and n-octanol (Pow).

30. Log Pow is used for two purposes. In the pr e-screening (OSPAR Recommendation 2000/4) to advise on bioaccumulation potential and in the CHARM model to estimate how a substance partitions between oil and water with the aim of predicting the environmental concentration (PEC). As a consequence of this dual use of log Pow data, whenever a range of log Po w values is quoted in the report, the maximum and minimum value should be stated in the HOCNF. The maximum values will be used for estimating bioaccumulation potential and the minimum as an indication of the potential of the s ubstance to partition into the water phase.

31. A standard method (shake flask ) for the determination of Pow is : OECD Guidelines for Testing of Chemicals, 1981-107. The shake flask method is applicab le for substances that are water soluble and which do not dissociate or associate. The method is not app licable for lipophilic organic substances (of low water solubility), preparations, complex substances, orga no-metallic compounds and surf ace active substances. Log Pow values in the range –2 to 4 can be measured by this method.

32. A standard method (HPLC method) for the estim ation of the log Pow is: OECD Guidelines for Testing of Chemicals, 1989 - 117. This method is app licable for preparations and complex substances. For HPLC estimations for complex substances the log Pow ra nge needs to be stated. Ionisable substances should be measured in their unionised form under appropria te pH conditions (pH range of natural seawater). The HPLC method is not applicable to strong acids and bases, metal complexes, substances reacting with the eluent or surface active substances. Log Pow values in the range 0 to 6 can be estimated using the HPLC method.5 OSPAR Commission Summary Record OIC 2003 OIC 03/15/1-E, Annex 6 33. Reliable methods are now available for calculation of log Pow for many types of organic substances and often laboratory testing can be avoided. Ex amples of reliable methods are CLOGP, LOGKOW and AUTOLOGP (cf. European Commis sion (1996), Technical guidance documents in support of the Commission Directive 93/67/EEC on risk assessment for new notified substances and the Commission Regulation (EC) No. 1488/94 on risk assessment for exis ting substances. Part III. Care should be employed when using models to assess substances for wh ich the protocols have not been verified.

34. If the calculated or experimentally determined log Pow ≥ 3, bioaccumulation will be assumed unless experimental bioconcentration factor (BCF) test s indicate the opposite. While high molecular weight compounds are less likely to bioaccumulate a precise threshold is not recognised. BCF data are relevant for all deliberately added substances whose log Pow >3. The BCF is determined on the basis of the ratio of animal tissue concentration to water concentration of th e test substance at equilibrium, or on the basis of the ratio of the uptake and depuration rate constants. The au thority should be consulted beforehand to ensure that the test method proposed is suitable. In general, for fu lly water miscible substances/preparations, either a fish or a bivalve mollusc bioaccumulation test would usua lly be appropriate (e.g. OECD 305 or ASTM E1022), whereas a substance/preparation that gives rises to su spended particles may be more suitably tested with a filter feeding organism such as a bivalve mollusc.

35. The presence of surface active substances may in crease the bioavailability of other substances in preparations. Therefore a bioconcentration test may be required for such preparations. In such a test, exposure to the preparation should be followed by analys is of the test animals conducted on a substance by substances basis. The relevant bioconcentration test should be agreed in consultation with the authority. Where an inappropriate test for a particular preparat ion/substance has been used, the authority will reserve the right to classify the preparation/substance as bioaccumulative. The Mytilus or a fish species would be suitable as test organisms, but other test species may also be appropriate.

§ 2.2 Biodegradability

36. Data on biodegradability in the marine environm ent are relevant for all organic substances. For preparations or complex mixtures, individual informat ion for all substances deliberately added is requested.

37. If the substance is found not to be readily biodegr adable or if a ready aerobic biodegradation test has not been performed, it will be assumed to be persistent in aerobic conditions unless an inherent test is performed which indicates the opposite. The relevance of an inherent biodegrad ation test should be agreed in consultation with the authority.

38. Substances for which no biodegrad ation data are available shall be tested according to the standard test methods for biodegradability: OECD Guidelines for Testing of Chemicals, 1992, 306, or any of the four protocols published in the report “Biodegradability of chemicals in sea water”. Results of a ring tests undertaken by OSPARCOM, were reported by Elf Akvamiljö, September 1996.” Authorities may accept data from freshwater tests according to OECD Guidelines for Testing of Chemicals, 1992, 301 A-F if these are already available. The OSPAR ring test is available on the OSPAR website (www.ospar.org).

39. The highest value for percentage of biodegradati on during the 28 days of testing shall be used as the biodegradation potential provided that it is not an outlayer. The substance w ill be considered persistent if the biodegradation is <20% in 28 days.

40. Aerobic inherent biodegradability may be require d by authorities. The standard test methods for inherent biodegradability are: OECD Guidelin es for testing of chemicals, 1981 302 A-C.

41. Tests on substances known to be toxic to microbes (e.g. biocides) should follow the recommendations in Annex II of OECD 1992 301. (U K to review and advise on alternative text)

42. Biodegradability tests on poorly soluble materials should follow the recommendations set out in ECETOC Technical Report No. 20 (1986) Annex III of OECD 1992 301 and ISO Guidance Document ISO 10634.6 OSPAR Commission Summary Record OIC 2003 OIC 03/15/1-E, Annex 6 43. For substances or substances in pr eparations which qualify for a sediment reworker toxicity test, an anaerobic biodegradation test may be conducted in addition to aerobic tests. If such a test is not conducted, the substance will be assumed to be no n-biodegradable in anaerobic conditions.

44. Anaerobic biodegradability testing should be ca rried out following the recommendations set out in e.g. the draft OECD guideline: “Aerobic and anaerobic transformation in aquatic sediment systems”, OECD 308, OECD 2000. Data from anaerobic screening tests conducted with digested sewage sludge (e.g. ISO 11734) cannot be used for predicting the biodegrada tion potential in sediments. Anaerobic biodegradability data are not relevant for water soluble materials which do not adsorb to surfaces.

45. Authorities may require add itional biodegradation data, e.g. seawater simulation studies, seabed

survey.

§ 2.3 Taint

46. Preparations/substances known or expected to cau se taint (the ability of a substance to impart a foreign flavour or odour to the flesh of fish and she llfish) will receive a taint warning. A list of compounds liable to cause taint is included in the OSPAR List of Substances/Compounds Liable to Cause Taint, which is available on the OSPAR website (www.ospar.org).

§ 2.4 Aquatic toxicity

47. Toxicity data must be provided for all prepar ations or their constituen t substances, unless they appear on the PLONOR List. Marine data should be provided where possible but competent authorities may at their discretion accept freshwater toxicity data in place of marine data.

48. The relevance of toxicity test data other than that specified in this notification format should be agreed in consultation with the relevant authority. Ho wever, for freshwater data or non-OSPAR marine data, application of safety factors as required by the C HARM model may be needed. For certain substances, additional marine toxicity data may be required at any time if evidence supports doubt on the relevance of existing test data.

49. For new substances and preparations and, where re levant, for re-notificati on of existing substances or preparations, testing on representative algae, crustacean and fish species is mandatory 1 . The full OSPAR marine toxicity data set comprises:

a. Skeletonema costatum; to ISO/DIS protocol 10253

b. Acartia tonsa ; to ISO protocol TC 147/SC5/WG2

c. Scophthalmus maximus (juveniles); to Part B of the OSPAR Protocols on Methods for the Testing of Chemicals Used in the Offshore Industry (published by OSPAR in 1995, available from the OSPAR web site www.ospar.org )
A comparative suite of alternative marine or freshwate r species are also acceptabl e if tests are conducted to recognised protocols.

1 If testing another species has already identified a subs tance for substitution, the fish test is not mandatory although it may still be required at the discretion of the competent authority.7 OSPAR Commission Summary Record OIC 2003 OIC 03/15/1-E, Annex 6 50. Additionally substances and preparations which:
a. are "sinkers"; or

b. have a K oc >1000 (see 2.5); or

c. have a log Pow>4; or
d. are in any other way known to adsorb to par ticles or end up in the sediment (e.g. contains surface active substances of the type wh ich enhance adsorption to particles);
require a sediment reworker test with Corophium spp using Part A of the OSPAR Protocols on Methods for the Testing of Chemicals Used in the Offshore Industry.

51. If available, long-term toxicity test data should be provided.

52. Where freshwater data is provided, tests must be conducted on representative algae, crustacean and fish, and conducted to recognised International standards. Data must be generated by laboratories working to Good Laboratory Practice or equivalent internationally recognised standards and a full reference must be given for the source of the data. In the case of published data, a copy of the original paper must also be provided detailing a full description of the test procedures.

2.5 Adsorbability

53. The organic carbon adsorption coefficient (K oc ) is only applicable for individual substances. The

K oc can generally be calculated from the octanol/water partition coefficient (log P ow ) and the organic carbon content of the sediment and suspended solids. Wh ere this cannot be done, Shake-Flask measurements of K oc using marine sediments and seawater may be provided. Suitable methods of calculation and measurement are described in Karickhoff, S.W., Brown, D.S.,. and Scott, T.A. (1979), Water Research 13:241-248.

54. For surface active substances, measured Koc da ta are mandatory and the methodology used should be stated. SEBA 2000 recognised that at present there ar e no standard test methods available which would provide reliable and robust K oc data for surface active substances. SEBA 2000 therefore agreed to initiate the collection of information and literature re ferences to evaluate existing methodology.

2.6 Mammalian toxicity

55. Data from mammalian toxicity test for food chain risks should be stated if available.



## Part 3 Confirmation Statement

56. The confirmation statement is a written declara tion renewable every three years to confirm that:
a. The information in the form still applies precisely to the substance/preparation being manufactured or supplied under that specific trad e name. Any change in formulation, by the addition of any new substance, or the removal of any existing substance, other than by trace quantities (<100 ppm or <0,01%), necessitates the immediate action to consider whether new data are required. Any change in composition, i.e. , in the concentrations of a substance, unless within the previously accepted range of vari ability, similarly necessitates the immediate evaluation of the new composition. Any change of name, coding or number requires an immediate declaration that the existing format now applies to this renamed preparation;
b. All tests referred to in Appendix 1 to OSPAR Recommendation 2000/5 on a Harmonised Offshore Chemical Notification Format (HOCNF ) were carried out in accordance with the OECD principles of Good Laboratory Practice (cf. also § 20 above).8 OSPAR Commission Summary Record OIC 2003 OIC 03/15/1-E, Annex 6 57. Suppliers may be asked at any time to submit samples of substances/preparations to governmental bodies for analysis or testing. Offshore users may also be asked at any time to submit to governmental bodies a sample of the preparation currently in use.

58. Before the renewal date the no tifier should consult the national aut horities. More relevant or missing data on substances/preparations which were pr eviously accepted for use, may be required.9 OSPAR Commission Summary Record OIC 2003 OIC 03/15/1-E, Annex 6 

### Appendix 1

Glossary and Definitions of Terms

1. For the purpose of these guidelines and for th e purpose of the Harmonised Offshore Chemical Notification Format (HOCNF) as at Appendix 1 of OSPAR Recommendation 2000/5 on a Harmonised Offshore Chemical Notification Format (HOCNF):
a. "authority" means the competent national auth ority of a Contracting Party to the OSPAR Convention;
b. “discharge” means the operational release of offshore chemicals or their degradation and transformation products in to the maritime area;
c. "EINECS" means European Inventory of Existing Commercial Chemical Substances;
d. “ELINCS” means European List of Notified Chemical Substances;

e. “offshore chemicals” means all chemicals intentionally used in connection with offshore exploration and production activiti es in the maritime area. Of fshore chemicals comprise both substances and preparations;
f. "persistent" means a substance bi odegrades less than 20% in 28 days;
g. "PLONOR" means the OSPAR List of Substan ces/Preparations Used and Discharged Offshore Which are Considered to Pose Little or No Risk to the Environment

h. “P ow ” is equivalent to Kow and means the partition coefficient of a substance between octanol and water, measured or calculated according to the HOCNF;
i. “preparation” means a mixture or solutio n composed of two or more substances;
j. “SDS” means Safety Data Sheet according to EC Commission Directiv e 91/155/EC of 5 March 1991 defining and laying down the de tailed arrangements for the system of specific information relating to dangerous preparatio ns in implementation of Articl e 10 of Directive 88/379/EEC or any document that may supersede this.
k. "sinkers" means those chemicals with a density greater than that of sea water and with a low water solubility;
l. “substance” means a chemical element or compound in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product and any impurity deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition;
m. "trace" means a substance is represented with less than 0,01 % (<100 ppm) in a preparation;
n. “use” means application of any offshore chemic al in connection with offshore exploration and production activities in th e maritime area that mi ght result in discharge.

2. Further definitions and information can be found in:

• OSPAR Decision 2000/2 on a Harmonised Mandatory Control System for the Use and Reduction of the Discharge of Offshore Chemicals;

• OSPAR Recommendation 2000/4 on a Harmonised Pre-screening Scheme for Offshore Chemicals;

• OSPAR Recommendation 2000/5 on a Harmonised Offshore Chemical Notification Format (HOCNF);
which are available for downloading from the OSPAR web site (www.ospar.org).10 OSPAR Commission Summary Record OIC 2003 OIC 03/15/1-E, Annex 6 

### Appendix 2 *



### Functions of Chemicals referred to in paragra ph 7 of the OSPAR Guidelines for completing the HOCNF

Acidity Control Chemical Antifoam (Hydrocarbons) Antifoam (Water Injection) Asphaltene Dissolver Asphaltene Inhibitor

Biocide Brine (Completion)

Carrier Solvent Cement or Cement Additive Coagulant Coolant or Coolant Additive Corrosion Inhibitor Crosslinking Chemical Cuttings Wash Fluid

Defoamer (Drilling) Demulsifier Deoiler Detergent / Cleaning Fluid Dispersant Drilling Lubricant Dye

Emulsifier

Filter Cake Removal Chemical Filter Media or Filter Media Additive Filtrate Reducer Flocculant Fluid Loss Control Chemical

Gas Hydrate Inhibitor Gelling Chemical

Hydraulic Fluid Hydrogen Sulphide Scavenger Lost Circulation Material

OPF Additive OPF Base Oil OPF Base Synthetic OPF Oil based Drilling fluid OPF Synthetic-based Drilling Fluid Oxygen Scavenger

Pipe Dope Pipe Release Chemical Pipeline Hydrotest Chemical Pipeline Pigging Chemical Proppant

Scale Dissolver Scale Inhibitor Shale Inhibitor / Encapsulator

Thinner Tracer chemical

Viscosifier

Water Based Drilling Fluid Additive Water Based Drilling Fluid Water Clarifier Wax Inhibitor Wax Dissolver Weighting Chemical Well Stimulation Chemical Well Bore Clean-up Chemical

Other

* This appendix has now been agreed in a written procedure between OIC Heads of Delegation.