Working with offshore chemical management on the Norwegian Continental Shelf, you’ll quickly come across terms such as HOCNF, NEMS, green and red chemicals, and discharge permits.
These are all part of Norway’s environmental management framework for offshore chemicals. Understanding how they fit together is essential for anyone working with chemical management, occupational hygiene, environmental compliance or HSE in the offshore industry.
This article explains how the framework works, how the different components are connected, and the role each plays in protecting the marine environment.
A Different Approach to Offshore Chemical Management
Norway’s approach to offshore chemical management is rooted in a long-term ambition to minimise the environmental impact of petroleum activities.
In 1997, the Norwegian Parliament adopted national zero-discharge targets for environmentally hazardous substances from offshore petroleum operations. Rather than prohibiting all chemical discharges, the objective was to eliminate or minimise discharges of substances that could harm the marine environment while encouraging the industry to replace hazardous chemicals with less environmentally harmful alternatives wherever possible. Over the following decades, this policy became one of the driving forces behind Norway’s environmental management framework for offshore chemicals.
The Building Blocks of the Norwegian System
Supporting this ambition requires more than simply knowing which chemicals are used offshore. Operators and authorities need consistent information about each chemical’s environmental properties, a common way of classifying environmental hazard, and a regulatory framework for controlling what may be discharged.
This is why Norway combines several complementary systems:
HOCNF provides the environmental data
NEMS manages and classifies the environmental data
The Norwegian Environment Agency (Miljødirektoratet) uses this information when assessing applications for discharge permits
Operators use the same information to ensure their offshore activities remain within the conditions of those permits.
Together, these elements create a transparent and consistent framework for protecting the marine environment while enabling offshore operations.
HOCNF: The Environmental Data Behind Every Assessment
Every environmental assessment starts with data. The Harmonised Offshore Chemical Notification Format (HOCNF) was developed by the OSPAR Commission to provide a standardised way of documenting the environmental properties of chemicals intended for offshore use. Rather than allowing suppliers to submit environmental information in different formats, the HOCNF defines exactly what information should be provided and how it should be presented. This allows operators and regulators across the OSPAR region to assess offshore chemicals using a consistent set of environmental criteria, regardless of who manufactures the product.
The HOCNF is normally prepared by the chemical supplier, who has access to the product formulation and technical information. Environmental test data is generated through laboratory testing using recognised international methods, while the supplier compiles the complete HOCNF documentation.
Importantly, an HOCNF is not an approval. It is the environmental data package used by operators and authorities to assess the potential environmental impact of offshore chemicals.
The Difference Between HOCNF and SDS
Why isn’t a Safety Data Sheet (SDS) sufficient? The answer is that the two documents have different purposes.
A Safety Data Sheet is designed to protect people. It provides information about hazards, safe handling, storage, transport, emergency response and occupational health in accordance with regulations such as REACH and CLP.
An HOCNF is designed to protect the marine environment. It provides the environmental information needed to assess the potential impact of offshore chemical discharges, including marine toxicity, biodegradation and bioaccumulation.
Because the two documents are developed under different regulatory frameworks and assess different types of risk, the same chemical may have different classifications in an SDS and an HOCNF. A product that presents relatively low risk to workers may still contain substances that persist in the marine environment or are harmful to aquatic organisms.
For this reason, an SDS alone is not sufficient for chemicals intended for offshore use on the Norwegian Continental Shelf. The HOCNF provides the additional environmental information needed for classification in NEMS and for discharge permit applications to the Norwegian Environment Agency.
The resulting colour category then helps operators determine whether a chemical can be used offshore within the limits and conditions of their discharge permit.
HOCNF and SDS Compared
Safety Data Sheet (SDS)
HOCNF
Protects workers
Protects the marine environment
Required under REACH/CLP
Required for offshore environmental assessment in the OSPAR framework
Human health and physical hazards
Marine toxicity, biodegradation and bioaccumulation
Used across industries
Used for offshore chemicals
NEMS: Turning Environmental Data into Practical Information
Once the HOCNF has been completed, the chemical supplier submits the environmental information to NEMS Chemicals, the industry’s shared database for offshore chemical information on the Norwegian Continental Shelf.
NEMS provides a common source of environmental information for operators and supports the registration, classification and management of offshore chemicals.
Before a chemical is made available to operators, the submitted HOCNF documentation undergoes quality assurance by the NEMS KPD Centre, an independent organisation responsible for verifying that the environmental data has been generated and documented in accordance with the applicable standards. This includes reviewing laboratory documentation and confirming that the required environmental testing has been performed using recognised international methods.
Once the HOCNF has been verified, NEMS calculates the Norwegian environmental colour category according to the criteria defined by the Norwegian Environment Agency. The verified chemical information is then made available to operators through the NEMS database.
Because all chemicals are documented using the same HOCNF format and verified through the same process, operators can compare products using consistent environmental criteria.
NEMS also protects commercially sensitive information. While authorities can access the full chemical composition where required, operators use verified environmental information without necessarily having access to proprietary formulations.
Understanding Norway’s Colour Categories
One of the most recognisable features of the Norwegian system is the environmental colour classification.
Using the environmental information contained in the HOCNF, NEMS automatically calculates the Norwegian environmental colour category according to the criteria defined by the Norwegian Environment Agency.
The colour categories provide a standardised way of communicating a chemical’s inherent environmental hazard and play an important role in environmental assessments, discharge permit applications and offshore chemical management.
The four main categories are:
Green – Chemicals considered to pose the lowest environmental concern
Yellow – Chemicals that are acceptable for offshore use but remain subject to environmental control
Red – Chemicals that should be substituted where reasonably practicable and require stronger justification
Black – Chemicals containing substances subject to the strictest environmental restrictions
A chemical’s colour category is based solely on its inherent environmental properties and does not change according to how much of the chemical is used. However, the planned quantity, intended application and expected discharge remain important factors when the Norwegian Environment Agency assesses the overall environmental impact of offshore activities and determines the conditions of a discharge permit.
Discharge Permits: From Application to Compliance
Unlike some regulatory systems, Norway does not approve offshore chemicals as individual products. Instead, operators apply to the Norwegian Environment Agency for permission to use and discharge chemicals as part of their offshore activities.
Preparing the Application
When assessing an application, the Norwegian Environment Agency considers information including:
the environmental data documented in the HOCNF
the chemical’s registration and classification in NEMS
its environmental colour category
the intended application and expected discharge volumes
substitution assessments where required
the overall environmental impact of the planned activities
The environmental colour category plays an important role during this assessment. It reflects the inherent environmental hazard of the chemical and helps determine how it should be managed within the regulatory framework. Green and yellow chemicals are generally easier to justify, while the use of red chemicals requires stronger justification and active consideration of safer alternatives. Black substances are subject to the strictest restrictions.
Operating Within the Permit
If the planned activities are approved, the Norwegian Environment Agency issues a discharge permit that establishes the conditions under which chemicals may be used and discharged during the operation.
From that point onwards, responsibility shifts to the operator. The operator must ensure that chemical use remains within the conditions of the discharge permit, that substitution requirements are addressed where applicable, and that actual chemical use and discharges are monitored and reported in accordance with regulatory requirements.
This means the discharge permit is not simply an approval issued at the start of an operation. It forms the legal framework for environmental compliance throughout the lifecycle of offshore activities, from planning and chemical selection to operational reporting.
Reporting and Continuous Environmental Management
Operators continue to record chemical consumption throughout offshore operations and calculate actual discharges based on how each chemical is used. This information forms the basis of mandatory environmental reporting and demonstrates compliance with the conditions of the discharge permit.
The same environmental information that supported the original assessment therefore continues to support environmental management throughout the chemical’s operational lifecycle, enabling both operators and authorities to verify that actual chemical use and discharges remain within the conditions of the discharge permit.
The Framework at a Glance
Framework component
Role
OSPAR
Defines the international framework for offshore environmental management.
HOCNF
Provides standardised environmental data for offshore chemicals.
NEMS Chemicals
Registers, manages and classifies offshore chemical information.
Environmental colour categories
Indicate the inherent environmental hazard of offshore chemicals.
Norwegian Environment Agency
Assesses discharge permit applications and regulates offshore discharges.
Operators
Ensure chemicals are managed and used in accordance with discharge permit conditions.
Environmental reporting
Documents actual chemical use and discharges throughout offshore operations.
Although each component has a distinct role, they all support the same objective: protecting the marine environment while enabling safe offshore operations.
Rather than viewing HOCNF, NEMS, colour categories and discharge permits as separate requirements, it is more helpful to see them as interconnected parts of Norway’s offshore chemical management framework. Together, they provide a consistent approach to assessing, permitting, managing and reporting offshore chemical use on the Norwegian Continental Shelf.
Where does ChemCenter fit? ChemCenter helps operators integrate environmental information into their wider chemical management processes, supporting operator approval workflows, risk assessments, substitution, operational documentation and traceability throughout the chemical lifecycle. It complements the Norwegian offshore chemical management framework rather than replacing the specialised environmental assessments performed through HOCNF and NEMS or the discharge permit process administered by the Norwegian Environment Agency.
Chemical substitution is becoming a central priority for companies that handle hazardous substances. Traditionally, finding safer alternatives has required significant manual effort. AI is changing this entirely. In this article, we explain in what way.
Challenges in Traditional Chemical Substitution
Finding safer alternatives (substitution) is essential for reducing health risks, improving environmental performance and meeting global regulatory expectations. Substitution is increasingly expected by regulators, customers and investors across Europe, the Middle East, North America and Asia-Pacific.
Despite its importance, substitution is traditionally difficult.
Many organisations must manually compare hazard classifications, performance characteristics, regulatory requirements and supply chain constraints. As a result, substitution processes are often slow, fragmented and prone to human error. This can delay safer chemical adoption and make it harder for companies to meet growing ESG expectations.
How AI Can Affect Chemical Substitution
AI introduces a more intelligent, data-driven approach to chemical substitution. Instead of relying on manual comparisons, scattered data and expert judgement alone, AI can analyse large volumes of chemical information in seconds and highlight safer, compliant and operationally suitable alternatives. It brings structure, consistency and predictive capability to a process that has traditionally been slow and uncertain.
Faster Identification of Safer Alternatives
Instead of searching manually, AI can instantly analyse extensive chemical datasets and SDS records and suggest alternatives that offer reduced hazards, similar performance and better regulatory outcomes. This speeds up decision-making by helping organisations respond quickly to regulatory changes.
Automated Hazard and Risk Assessment
AI can help interpret complex data, classify hazards and estimate risk scores automatically. This removes inconsistency caused by manual interpretation and ensures every substance is evaluated within a standard, reliable framework. AI can also help flag chemicals with missing or outdated data, ensuring assessments remain accurate.
Compliance Assurance Across Global Regulations
With operations often spanning multiple countries, compliance demands may vary. AI continuously tracks regulatory updates across regions and automatically checks whether a substance or its alternative is compliant. This protects organisations from unintentional non-compliance and helps maintain a proactive approach to international chemical safety expectations.
Enhanced Sustainability and ESG Performance
AI can help organisations assess environmental impacts by comparing biodegradability, ecotoxicity, emissions and lifecycle considerations. As a result, it can help with ESG reporting and strengthen the organisation’s environmental profile across global markets.
Important: Although AI provides valuable insights, it is not fully reliable on its own. All AI-generated recommendations should be reviewed and validated by qualified experts to ensure accuracy, safety and regulatory compliance.
AI is transforming chemical substitution by simplifying complex processes, speeding up evaluations and enabling safer, more sustainable decisions. For organisations looking to reduce risk and meet global regulatory and ESG expectations, AI-powered chemical systems may be the way to go forward. By integrating AI into their systems, companies can modernise operations, improve safety and be prepared for future regulatory requirements.
In the oil and gas industry, chemical risk assessment is essential for safe and reliable operations. Drilling, production, processing and maintenance all involve chemicals that can pose significant health, environmental and operational risks if not properly controlled. Establishing a clear and consistent approach to assessing these risks helps companies prevent incidents, protect workers and maintain compliance across diverse global sites and regulatory frameworks.
What Is a Risk Assessment?
A risk assessment is a systematic process used to identify potential hazards, evaluate the likelihood and severity of harm and determine the measures needed to control those risks. In the context of chemical safety and broader risk management, this involves understanding the hazardous properties of a substance, analysing how it is used and assessing the potential for worker exposure or accidental release.
Many organisations also use a risk assessment matrix to visualise the relationship between likelihood and consequence. This helps classify risks into categories such as low, medium or high and supports consistent decision-making across departments, sites and regions.
A risk assessment answers three key questions:
What could go wrong?
How likely is it to happen?
What are the consequences?
Why Chemical Risk Assessment Matters
In high-risk environments, for example during surface treatment, well intervention or maintenance activities, inadequate control may lead to acute health effects, chronic exposure problems or severe incidents including fires and explosions.
A comprehensive risk assessment enables organisations to understand these hazards and put effective controls in place. For companies operating internationally, it also helps ensure alignment with regulatory frameworks such as:
Equivalent rules across the Middle East and Asia-Pacific
Most jurisdictions require employers to document chemical risk assessments in writing. While specific rules differ between countries, the principle is the same. Employers must identify hazardous substances, assess potential exposure and record how risks are controlled. Clear and consistent documentation supports internal communication, provides evidence of compliance during audits and forms the foundation for safe operating procedures.
Chemical Risk Assessment Step by Step
1. Maintain an accurate chemical inventory
An up-to-date chemical inventory with the latest safety data sheets (SDS) is the starting point. Ensure that the SDS complies with globally recognised formats such as GHS and contains reliable information about hazards and safe handling.
2. Identify the inherent hazards
Review SDS data to understand the chemical’s classification, health risks, environmental impacts and physical hazards such as flammability or reactivity.
3. Assess exposure
Evaluate how the substance is used, the quantities handled, possible exposure routes, the work environment, ventilation, existing control measures and the frequency and duration of tasks.
4. Determine the level of risk
Combine the hazard and exposure findings to estimate the overall risk and prioritise necessary actions.
5. Implement and improve control measures
Based on the risk outcome, establish suitable measures. These may include engineering controls, process changes, improved ventilation, automation, safer alternatives, or appropriate personal protective equipment. Ensure these measures are reflected in work instructions, toolbox talks, checklists and training routines.
6. Document, monitor and review
Record the entire process and revisit the assessment when new chemicals are introduced, processes change or equipment is modified. Regular reviews help ensure continuous compliance and improvement.
Digital Tools for Risk Assessments
Digital chemical management tools can make it significantly easier to organise chemical inventories, access SDS documents, streamline risk assessments and maintain proper documentation. For organisations operating across multiple regions, digital systems help standardise processes and ensure compliance with varied regulatory requirements. Integrated features such as automated updates, version control and embedded risk management workflows further strengthen the consistency and quality of assessments.
A robust chemical risk assessment helps companies manage hazardous substances safely, maintain compliance and reduce the likelihood of costly incidents. With structured controls, regular reviews and the support of digital tools, organisations can strengthen their risk management practices and ensure safer, more reliable operations.
Working with hazardous substances in high-risk work operations can pose significant health threats, and employers should be aware of the potential consequences of chemical exposure. An exposure register is a critical tool for companies wanting to protect their employees, support compliance with legislation and industry standards, and ensure full traceability of chemical and environmental exposure.
What Is a Chemical Exposure Register?
An exposure register is a structured record that documents an employee’s potential or confirmed exposure to hazardous substances or harmful processes in the workplace. This includes day-to-day operational exposure as well as accidental events such as leaks, spills, equipment failures, overexposure incidents or unexpected contact with dangerous materials.
Why Exposure Tracking Matters
Chronic illnesses linked to occupational exposure may not appear until many years after the event, making proper documentation essential. An exposure register serves several key purposes:
Supports long-term health monitoring and medical follow-up
Provides evidence in the event of occupational illness or compensation claims
Helps employers conduct accurate risk assessments and refine safety measures
Improves transparency and accountability within high-risk working environments
Ensures compliance with global health and safety legislation
While specific legal requirements vary by region, most regulatory frameworks such as EU REACH, UK COSHH, OSHA in the United States and various international occupational health standards require employers to track exposures to high-risk substances and keep detailed historical records.
What an Exposure Register Should Contain
While the exact requirements vary by country, an effective exposure register generally contains:
The employee’s identity and job role
The substance or process involved
Date, location and duration of the exposure
Whether the exposure was routine, accidental or incidental
Concentration levels or estimated exposure where available
Actions taken such as medical evaluation or corrective measures
Relevant safety documentation such as safety data sheet (SDS) references, monitoring results or incident reports
Organisations should only collect exposure data that is relevant, accurate and necessary, in alignment with privacy laws.
Documentation and Storage Requirements
Exposure records should be stored safely and, in some cases, for an extended period depending on the jurisdiction and nature of the hazard. Some countries even require records to be retained for the lifetime of the employee if the substance is known to cause long-latency health effects.
Long-term storage requirements should include secure retention and data protection compliance. The exposure register should only be available to authorised personnel such as health professionals, regulatory authorities, and safety representatives. Additionally, employees should be able to access their own records if needed.
Common Challenges with Exposure Registers
Some common challenges include:
Limited reporting and awareness: Many incidents are not reported because employees underestimate the seriousness of the exposure or because reporting procedures are unclear. Insufficient training or limited awareness of long-term health risks often contributes to this.
Long-term data management: Maintaining records for decades requires robust digital infrastructure and data governance. Many organisations struggle with system changes, data migration and compliance with modern privacy regulations.
By documenting exposure events accurately, storing records securely and addressing common reporting challenges, organisations can strengthen their chemical safety practices. With the support of modern digital chemical management systems such as ChemCenter, companies can simplify the registration process, improve compliance and ensure safer, more resilient operations.
Diisocyanates are essential in everyday work operations across offshore and onshore industries, but they demand strict safety and compliance control. With tighter regulations such as REACH, knowing where these chemicals are used and by whom is crucial. Chemical management systems give supervisors the oversight needed for safer, compliant operations.
What Are Diisocyanates?
Isocyanates is a collective term for a group of chemical substances used as components in polyurethane products. Diisocyanates are a specific type of isocyanate that contain two reactive isocyanate groups.
In both offshore and onshore environments, a variety of products contain diisocyanates, many of which are used daily.
Examples of products containing diisocyanates:
Adhesives
Elastomeric materials
Flooring and surface coatings
Insulation foams
Protective coatings and paints
Sealants
Why Diisocyanates Require Careful Handling
Diisocyanates are highly reactive substances that can pose significant health risks, even at low concentration, if not handled properly.
Short-term (acute) exposure may cause:
Irritation of the eyes, nose throat and skin
Coughing, wheezing, or tightness in the chest
Headache, nausea, and general discomfort after inhalation of vapours or aerosols
Long-term (chronic) exposure may cause:
Respiratory sensitisation
Skin sensitisation
Chronic respiratory issues
Permanent asthma
Handling products containing diisocyanates therefore requires strict control measures. Work should always take place in well-ventilated areas or under local exhaust ventilation. Suitable personal protective equipment (PPE) must be worn whenever there is a risk of contact or inhalation. To reduce risk further, workers should receive instruction in safe work practices and emergency procedures, and all chemical containers should be clearly labelled with hazard information.
Examples of exposure scenarios:
Spray application of polyurethane coatings, paints or foams
Mixing or transferring polyurethane components during maintenance or repair work
Cutting, sanding, or grinding cured polyurethane materials
Welding, hot cutting, or heating surfaces coated with polyurethane, where residual isocyanates may be released
Cleaning of application equipment or containers contaminated with uncured materials
A thorough risk assessment should identify all potential exposures and define suitable preventative measures before starting any work activity.
Regulatory Compliance
The use of diisocyanates is strictly regulated due to their potential health risks. Several international frameworks set requirements for safe handling, labelling, and worker protection.
REACH (EU)
Under the EU REACH Regulation, restrictions on diisocyanates entered into force in August 2023. Anyone handling products containing more than 0.1% diisocyanates must complete specific training in safe use. Employers are responsible for documenting compliance, ensuring proper labelling, and maintaining access to up-to-date safety data sheets (SDS).
Other Global Standards
Similar principles apply under other regulations worldwide, including:
GHS (Globally Harmonised System): Defines hazard classification and labelling standards
CLP Regulation (EU/EEA): Aligns classification, labelling, and packaging requirements with GHS principles
OSHA Standards (USA): Require exposure control, ventilation, PPE, and worker training
Digital Tools for Chemical Management
To determine whether a product contains diisocyanates, always refer to the product’s SDS in the company’s chemical inventory. The SDS provides detailed information about the product’s composition, hazards, and the measures required for safe handling.
Many companies now use digital tools to maintain oversight and control of their chemical activities. This can provide several key benefits:
Real-time inventory tracking: Know exactly which chemicals are in use, where they are stored, and in what quantities across multiple sites
Automated SDS management: Ensure safety data sheets are always updated and accessible to all personnel, both online and offline
Compatibility checks: Identify and prevent unsafe storage combinations before incidents occur
Multilingual labelling and documentation: Improve clarity and compliance, especially in international operations
Simplified reporting and audits: Generate accurate compliance reports quickly for internal reviews or regulatory inspections
Enhanced visibility between offshore and onshore operations: Share live data across locations
Reduced administrative workload: Minimise manual updates and paperwork, allowing staff to focus on critical safety and operational tasks
Diisocyanates are vital to many offshore and onshore operations, but their safe use depends on strict control, clear documentation, and regulatory compliance. As requirements under REACH and other global frameworks tighten, digital chemical management systems provide an efficient way to maintain oversight, reduce risk, and simplify compliance.
