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Chemicals Coffee Time Monthly, May 2024

Posted06/08/2024
Updated06/08/2024
Byghsclassif1stg

Dear Reader,

I hope you are safe and well. We are enjoying a rare spell of dry sunny weather in the UK, after months of rain, so I predict the headlines about a drought will be arriving in a couple of week’s time :).

An apology – last month’s newsletter had several missing links due to our local electronic black hole, but you can find the full version here: https://chemicalscoffeetime.co.uk/archive-2/chemicals-coffee-time-newsflash-eu-clp-label-formatting-timescales-update-14th-may-2024/. We have triple checked this newsletter to make sure everything is working correctly.

Hearing from the HSE, DEFRA and the UK

UK-REACH proposals

The first big news of the month was the UK REACH Alternative Model, announced by James Dancy at ChemUK 2024 on the 15th May. The full set of documents, along with the consultation itself were published on the 16th May at https://consult.defra.gov.uk/reach-policy/atrm-consultation/ . It only runs until the 11th July, so there’s not a lot of time to respond, given that it is 35 questions with numerous supporting documents.

Alison Potts (who has read the consultation and all of the supporting information) writes: It’s 35 questions, most of which require a long-form response. So prepare before you open the online form (or you’ll get fed up half-way through). You can see all the questions by opening the document called ‘UK REACH Consultation’, plan your responses in word (taking plenty of breaks!) and then copy/paste them into the online form.

Ali has also produced a detailed discussion on the consultation which you may find helpful: https://chemicalscoffeetime.co.uk/archive-2/alison-potts-comments-on-uk-reach-consultation-2024/

Of course, the second big news in May might make this consultation seem a bit pointless

UK General Election called for 4th July 2024

Much to everyone’s surprise apart from a few insiders in Government, the current UK Prime Minister announced a General Election on the 22nd May.

The predictions of who will win range from the Conservatives clinging on by their fingernails, probably in some kind of coalition; through a Labour landslide; to a situation where there is no clear winner. If my family and friends are typical, the “None of the Above” party would sweep the country!

It’s unclear what a change in government would mean for the UK chemical industry (and its suppliers and customers overseas).

On the one hand, Labour have said they would seek re-entry to the EU. But would this be possible in a Coalition government? Would the EU want the UK back? Are the UK’s laws now harmonised enough to permit quick and easy re-entry?

On the last point, there has been so much divergence between the EU and UK in the last few years, for example different SDSs, the new CLP changes, divergence on both sides between Harmonised and Mandatory Classifications, differences in Restrictions and Authorisations, different Biocidal Actives and Products, etc, that it might take longer than anyone realises to re-align the situation. And that’s before we consider REACH re-registration.

So it’s probably sensible to assume “business as usual” for the time being, and complete the UK-REACH consultation accordingly (although I might be tempted to wait until after the election results are known to finalise things, in case that changes anything).

ChemUK 2024 was a great success

We had a wonderful time at ChemUK, many thanks again to the organisers Ian Stone and his amazing team at UK Industry Events Ltd , and thanks also to all participants, whether stage moderators, IT boffins, exhibitors, speakers and attendees.

I’m looking forward to ChemUK 2025 on 21st and 22nd May 2025 already!

The Chemical Regulations Self Help Group stand was buzzing with members and new contacts who were interested in the work of the group, so much so that Ali and I weren’t able to attend the talks we had hoped to, despite sterling support from members who allowed us time for some short breaks. The good news is that the slides and recordings will be issued to all attendees soon.

In the meantime, I made voiceover recordings of the slides Ali and I had prepared, which you can find on YouTube:

Feel free to share and use these as you see fit, as both these videos are available publicly. As usual, if you have any questions on either topic, please email or DM me.

Keeping an Eye on ECHA and the EU

EU-CLP Legislative Act discussions

Chemicals Coffee Time has seen some lively debate over the interpretation of the deadlines for some labelling changes. and we issued a newsflash about this on the 14th May, see https://chemicalscoffeetime.co.uk/archive-2/chemicals-coffee-time-newsflash-eu-clp-label-formatting-timescales-update-14th-may-2024/ . Many thanks to Kathryn Tearle of British Coatings Federation for spotting this discrepancy.

It seems that a typographical error may be to blame, which should be resolved in the final official version of the Act. Unfortunately, as the legal/linguistic versions of EU Acts need to be signed off by the European Parliament, this may not occur until Parliament reopens in the autumn, and the whole process may mean it is November until publication occurs, or even as late as January 2024.

In the meantime, in an attempt to work out exactly what is going on, Ali has spent several days producing a completely unofficial consolidated version of CLP, based on adding the Legislative Act to the current Consolidated Version of 1st December 2023, which already has the Delegated Act annexes included, but omitting Annex VI for reasons of space.

If you would like a copy of this, please email or DM me, as there is a small admin charge.

Deforestation and forest degradation

Yet another EU “under the radar” regulation, which we learned about at ChemUK, is EU/2023/1115, “on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation”. This comes into effect on the 31st December this year and will impact heavily on palm oils and similar plant oils all through their supply chains, and it also includes cattle, as these are often grazed in former forest areas.

The full list of commodities affected is “cattle, cocoa, coffee, oil palm, rubber, soya and wood“, further details here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1115

Siloxanes restriction

The EU-REACH restrictions for the siloxanes D4, D5 and D6 have been published in the European Journal, see https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202401328. These restrictions will also apply to cosmetics, hat tip Hans Ingels https://www.linkedin.com/posts/hans-ingels-07136658_choose-the-experimental-features-you-want-activity-7197115700702834688-nut5

New EU hazard classes podcast

If you need more information on the new EU-CLP hazard classes, ECHA are recommending their “Safer Chemicals” podcast on this topic: https://smartlink.ausha.co/scpodcast/clp-review-and-new-hazard-classes? .

Webinar on the extension of the proposed chromium restriction (replacing its Authorisation)

ECHA are hosting a webinar on 06/06/2024 | 11:00 – 13:00 , Helsinki time; 9am- 11am UK time on the extension to the planned chromium restriction, explaining what the substances and uses are which are being included, and what information they’d like from industry, see https://echa.europa.eu/-/chromium-vi-substance-restriction-preparation-what-you-need-to-know-about-the-second-call-for-evidence?

Around the World

USA’s Hazcom finally updated

Something which seems to have slipped under the radar is that the USA’s version of GHS has finally, finally, been updated to GHS Revision 7, only 3 or 4 years later than expected (it may be even longer than that).

Many thanks to our friends at Lisam who spotted this news, they have a summary here: https://www.linkedin.com/posts/lisam-systems_update-to-the-hcs-osha-hazard-communication-activity-7200769954000838658-rHNN/

Regulatory nerds will be aware that GHS rev 7 is the version that the EU and therefore GB are on as well, but of course the USA don’t adopt certain hazards like acute and chronic aquatic toxicity, and there are likely to be many other subtle differences between the regimes.

Phil Rowley reminds me that the USA also have their own non-GHS hazards including asphyxiant gases and combustible dusts, although the latter have been included in GHS Revision 8, Annex 11 (although this guidance, not full adoption as a hazard class). As usual, “the devil is in the detail”.

Proposed IARC carcinogens

A list of the latest carcinogens (another way of seeing into the future for Regulatory Affairs) https://www.linkedin.com/posts/aaron-mcloughlin-1a86281_iarc-activity-7186807501449834498-aq8k

Lab safety attitudes and how it can affect production in start-ups

One of the (many) bees in my bonnet is lab safety, as in my experience, chemists working in the lab are the worst about dealing with safety, whether recognising hazards, or behaving appropriately (there are a number of reasons for this, which I won’t go into here).

It’s good to see an excellent article from Simone Bottinelli on this topic, see https://www.linkedin.com/posts/simone-bottinelli-7077b9ab_ramp-occupationalsafety-processsafety-activity-7197908566010146816-G_9X .

The way in which we lab scientists treat hazards differently to people in production can be particularly obvious when dealing with start-up companies spinning out of academia, where lab scientists may be involved in manufacturing for the first time, and not have much exposure to, or practical experience in COSHH, process safety etc.

So it was great to catch up with John Hibbs of Argus Consulting who has worked with the British Chemicals Association BCA) to set up a programme to help academic spinouts and startups get to grips with the health, safety, environmental and regulatory requirements of the modern UK chemical industry.

BCA (formerly BACS) is a UK based trade association representing the chemical supply chain, with 120+ members from base chemicals to retail, from global corporation to SME and sole trader. It has a unique structure with broad central hub supporting multiple industry/ technology-specific sector groups.

Their university spinout and startup sector group acts as a bridge between academic and industrial operations.

Group members receive full information flow from BCA and access to the support and networking provided by the association. These include – regulatory and business environment updates, a “helpdesk” function, the same access to existing BCA sector groups and meetings as other BCA members, discounted attendance at BCA training courses and seminars and facilitation and support from the BCA secretariat team.

Membership is open to defined entities operating within, or originating from, an academic institution. The “business” would be the member, so everyone directly associated with the venture has access.

Subscriptions for membership of BCA for qualifying businesses are at a significant discount, after which they can continue to be BCA members at normal rates. Businesses qualify for this subscription for a maximum of two calendar years, including the year in which they are elected, where the part year of membership is classed as the first year of the maximum two years.

If you are interested complete the Membership enquiry form on the BCA website at Membership enquiry form | BCA (bcaorg.com) or email enquiries@bcaorg.com.

If you are in academia and thinking about setting up a spinout or startup company, or working with, or know, any eligible businesses who could benefit from support from BCA and their members, I strongly recommend you check out this service.

Infographic of the Month

An excellent infographic from Lyle Burgoon on 7 tips for assessing science (and a link to his blog post on the same topic): https://www.linkedin.com/posts/lyleburgoon_toxictuesday-activity-7198706648155123713-OiEX .

The Weekend Watch

It’s really easy to forget what the UK has achieved in terms of science, so I was really interested in this view from New Zealand: What have the British ever done for us (scientifically speaking?) : https://www.youtube.com/watch?v=DcZQS4LBugk

The Weekend Recipe

I’m always on the look out for lactose free and gluten free recipes, so I was delighted to come across a vegan and gluten-free version of Florentine biscuits, and found one here: https://projectveganbaking.com/vegan-florentines/.

Ingredients

  • 2 oz flaked almonds
  • 2 oz candied peel (orange or lemon)
  • 2 oz chopped nuts (I use a mix of pistachio and hazelnut)
  • 1 oz dried fruit (cranberries, sultanas or raisins)
  • 1 oz stem ginger, finely chopped
  • 1 1/2 oz icing sugar
  • 2 oz maple syrup
  • 2 tbsp water
  • 1 tsp cornflour
  • 3 1/2 oz dark chocolate (optional for any choco-phobes)

Method:

Set your oven to Gas Mark 4. Line one or two large baking trays with baking paper.

Prep your nuts (eg chop if required), and mix with the dried fruit, stem ginger and candied peel in a bowl. Then sprinkle in the icing sugar, and mix well to coat the fruit and nuts in it.

Slake the cornflour in the water (that is stir it in and make sure all the lumps are gone), and stir it into to the maple syrup in a large pan. Heat the maple syrup and cornflour mix, stirring as you go, until it either reaches 95oC (if you have a sugar thermometer), or until the mixture thickens slightly and/or you see plenty of bubbles.

Take the pan off the heat, and carefully pour the contents over the fruit and nut mix, and stir so it’s evenly distributed. Then place tablespoonfuls on the tray(s), and flatten into a round shape (they will melt slightly and increase in size in the oven). 6 biscuits per tray is recommended. Bake for around 11 to 12 minutes until you see browning on the edges (you may have to turn the tray round part way through cooking if your oven has a large heat gradient). Cool on a wire rack. When cool, dip the bases in the melted chocolate (if you are using it), and if you’re feeling traditional, don’t forget to make a wavy pattern in the chocolate with a fork. Leave to set.

Findings: This is really just a mix of nuts and dried fruit in a toffee base, so more like a sweetmeat than a biscuit. It is very sweet, and needs the tang from the ginger and peel to counteract this. I cut down the amount of icing sugar, but that made the liquid around the solids a bit too fluid, so do use the full amount (it won’t make the florentines any sweeter to use that extra sugar, as it will just form a bit more toffee in the oven).

The florentines don’t spread as much as the dairy version, so flatten them out before baking. They are very fragile while warm, and need to be peeled off the baking paper very carefully if they are still cooling. As they were so sweet, I didn’t bother coating them in chocolate, although a dark, bitter chocolate (eg Lindt 85% cocoa) might counteract some of the sweetness.

Overall, this recipe does work, and is tasty, but it is quite a fragile “biscuit” and I might be more inclined to use a more traditional florentine recipe and use gluten free flour and margarine to make lactose free and gluten free florentines in the future, as this would make a less sweet biscuit.

Reasons to be Cheerful

We’re still on a Monty Python theme:

Shameless plug of the month: This is for an excellent charity, the Community Heartbeat Trust, who provide defibrillators at public venues around the UK. Neil Hollis of BASF is raising funds again for them by participating in British Coatings Federation‘s annual charity bike ride: https://www.linkedin.com/posts/neil-hollis_neils-fundraiser-for-the-community-heartbeat-activity-7192134436476321792-PjzV. You can donate directly here: https://www.justgiving.com/page/neil-hollis.

Many thanks for reading this LinkedIn newsletter, and many thanks to everyone who has contributed, through sending in links, queries, comments etc. If you have anything you’d like to share, please email me or send a DM, and I’ll do my best to include it in the next Chemicals Coffee Time Monthly.

It would be great if you’d like to subscribe to this newsletter, or even our weekly email one : https://chemicalscoffeetime.co.uk/. (This new website includes the email archive, with both open-access and subscriber-only content).

Look forward to chatting to you in late June or early July.

Kind regards,

Janet

Janet Greenwood, TT Environmental Ltd

PS We’re happy for you to use this content in your own social media or newsletters, as long as you credit Chemicals Coffee Time. Please note that this newsletter highlights issues which may be of interest to your business, but is not intended as specific advice. We always recommend that you should do your own research. If you need consultancy help, please book a Quick Consultancy Call here: (https://chemicalscoffeetime.co.uk/quick-consultancy-calls/), or Quick Consultancy Email here: https://chemicalscoffeetime.co.uk/quick-consultancy-emails/

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