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Chemicals Coffee Time Monthly, July 2024

Posted06/08/2024
Updated06/08/2024
Byghsclassif1stg

Dear Reader,

I hope this finds you safe and well and you’ve been able to enjoy some of the warmer weather we’ve finally had.

There was a General Election in early July in the UK, in case you missed it.

Alison Potts writes: there are two things that are enjoyable about general elections – dogs at polling stations, and the glare of Larry the Downing Street Cat observing the new tenants moving in. This will be Larry’s sixth Prime Minister – he’s getting quite proficient at pest control.

So I thought we’d look at what we’ve learned about the new regime so far.

New UK government updates

A Labour victory – but what about chemical regulations?

Now that Labour is in power in the UK, it will be interesting to see what happens. David Lammy, the new Foreign Secretary, visited several EU countries immediately after the , and is talking about improving the UK/EU trade deal, and generally seeking a better relationship with the EU, although there is apparently no plan to re-join at the moment.

Ali points out that, even if the UK wanted to re-join the EU, UK regulations are no longer in alignment with the EU and we would not be considered ready for Accession (under the Copenhagen Criteria). Being older and more cynical, I think that “where there’s a (political) will, there’s a way”, and if the EU thought it was in their interests to readmit the UK, it would be pushed through quickly.

And if re-accession is not possible, it will still be interesting to see whether the Starmer government alters the current approach of reviewing every EU decision, or whether there is a move to a Switzerland-style recognition of most EU chemical regulations.

It’s basically more uncertainty and yet another “watch this space” moment!

In the meantime, you may be interested in an excellent article which Neil Hollis of BASF wrote in March about the future of UK Chemical Regulations, which has recently been opened up as “free to view”: https://www.politicshome.com/members/article/regulatory-certainty-key-ingredient-industry-resilience .

Confusion over North Sea drilling Licences

In a unexpected turn of events, the Daily Telegraph announced on the 11th July that the new Energy Secretary has over-ruled his own officials and banned new drilling for oil and gas, both of which are critical feedstocks for the chemical industry, as well as being energy sources.

However, this was denied later the same day by the Department of Energy Security and Net Zero, which is reported to have said “the reports are untrue and no official decision has been made“. See https://uk.news.yahoo.com/ed-miliband-orders-immediate-ban-102141947.html .

It’s difficult to unpick what is going on, as sometimes politicians “float” ideas to see how they’re received, then backtrack them if they are unpopular. An alternative theory would be that someone who opposes the policy leaks it to the press, and when it’s unpopular, it’s reversed. Whatever the reasons, it will be good to get clarity on this, as it really isn’t good for everyone’s blood pressure.

Net Zero confirmed

We have heard in the King’s Speech on the 17th July that the Labour Government intend to pursue Net Zero vigorously. This will no doubt add to the chemical industry’s burden of paperwork, as well as requiring further investment. And all to reduce our emissions, and therefore consumption, of carbon.

One wonders what the late, great, Douglas Adams would have made of it all, as he often uses the term “carbon based life forms” for humans in The Hitch Hikers Guide to the Galaxy. (And for those of you who are too young to know this, the original radio series is better than the books, which in turn are far better than any tv or filmed version).

Or what about the greening of the planet which has occurred in the last 35 years, according to NASA’s satellite imagery? https://www.nasa.gov/technology/carbon-dioxide-fertilization-greening-earth-study-finds/ . This has had significant benefits for everyone, from greening the Sahel, the semi-arid region to the south of the Sahara desert, to an increase in crop yields.

I fear we are in for “interesting times” with this government, and predict even more layers of regulation. No doubt there will be more to come as the details of the Kings Speech are worked through.

Hearing from the HSE, DEFRA and the UK

Another Brexit glitch resolved

Daniel P. of Qiagen writes:

This may be of interest to some readers of the Chemicals Coffee Time newsletter, it’s regarding the status of sodium azide under GB BPR. It has now been updated to align with the status of the EU, apparently a lingering mistake from the BREXIT transition. Sodium azide is now allowed to be used in treated articles across both the EU and UK. It doesn’t seem to have been communicated by the HSE, and seem to have changed some time within the past 7 days.

“With reference to your email of the 16th July.

The entry for sodium azide Product Type 6 was recently changed to correct an error in the spreadsheet – the entry should have been ‘yes’ as regards treated articles, but was mistakenly entered as ‘no’ either when the spreadsheet was created or subsequently.

The reason for the amendment was that sodium azide for PT6 qualified for the BPR Article 94 transitional provisions for treated articles, as the original dossier for authorisation was submitted before the 1st September 2016 under the EU BPR whilst the UK was still part of the EU. This is reflected on the ECHA Article 94 list which shows this substance is allowed in treated articles.

As regards the assessment of sodium azide, we can’t predict exactly when the assessment will be completed, as every assessment is different and can have quite different timescales depending on factors such as whether additional data is identified as being required etc. However, if you sign up for our e-bulletins (if you have not already done so), when the outcome of the assessment is known we will publicise that – i.e. approval or non-approval decision. There may also be earlier details if we need information, for example if we issue a consultation on a substance where it may be a candidate for substitution.”

Many thanks to Daniel for keeping us up to date. One wonders what other Brexit anomalies are lurking in the chemical regulatory thicket?

Update – the HSE’s spreadsheet has now been updated with this information, you can download it from here: https://www.hse.gov.uk/biocides/uk-list-active-substances.htm .

Keeping an Eye on ECHA and the EU

Another Query on the CLP legislative act

A reader asks what the state of play is on this, and I know I’ve mentioned it before, but our friends at HIBISCUS PLC. Chemical Labels | Chemical Labelling / SDS Software who have produced an excellent summary of the new label format, which I thought you’d find useful.

To answer the question briefly, we have the legal-linguistic text in English, but until that goes through the formal translation process, we are a bit stuck. We know there are some errors in the UK version!

Hibiscus’s summary is here, including an excellent example on how the new EU label format will affect labels, although some of the deadlines may be slightly incorrect (one of the points of contention): https://www.hibiscus-plc.co.uk/revisions-to-eu-clp-legislative-act-passes-into-law/ .

However, although the Act may have been passed in the European Parliament, it’s not been officially published yet (in my view, it’s not fully passed into European law), and we are waiting until the translations are passed (including corrections) in the new European Parliament in the autumn. Current timescales November 2024 – January 2025.

In fact, there’s an informative diagram which Fabian Bohnenberger has made on the EU post-election timeline, available at https://fabianbohnenberger.com/2024/06/24/eu-post-election-timeline/ (hat tip Aaron McLoughlin of Fleishman Hillard for sharing this on LinkedIn).

Trifluoroacetic acid (TFA)#1

Chris Hughes writes:

In case you missed it – Trifluoroacetic acid (TFA) has been added to the registry of intentions for harmonised classification and labelling under the EU hashtag#CLP regulation, with a proposal for addition of reproductive toxicity (Repr. 1B, H360Df), persistent, mobile and toxic (PMT, EUH450) and very persistent, very mobile (vPvM, EUH451) hazard classes. TFA is an extremely persistent PFAS compound. It is ubiquitous in the environment, dwarfing concentrations of other PFAS. It is also a dead-end transformation product of many other substances, including fluorinated refrigerant gases (F-gases) and various pharmaceuticals and agrochemicals. What will the knock-on impacts be to the many precursors of TFA if this harmonised classification ultimately goes through? An unprecedented regulatory development with potential far reaching implications…

Many thanks to Chris, who has recently set up his own business, Embark Chemical Consultinghttps://www.linkedin.com/in/chris-hughes-321b45121. He has his own newsletter here: https://www.embarkchemical.com/ . Chris is a high-level eco toxicologist with masses of experience in REACH tests, and a very nice chap as well.

TFA #2 – COSHH implications of TFA proposed classification

Jason Hyde of Oxford Nanopore Technologies, has spotted something interesting about the proposed EU reclassification of Trifluoroacetic acid and its salts as Repr. 1B, H360Df; PMT, EUH450; and vPvM, EUH451.

TFA is widely used in HPLCs, so the reprotox classification would mean that anyone handling HPLC liquids would be potentially exposed to it, and your COSHH assessments would need to be updated to reflect that.

Jason also notes that TBE buffer, which is made from a mixture of Tris/Borate/EDTA and is used in biology labs, also holds a reprotoxic classification (H360FD, H412, as per this Merck SDS https://www.merckmillipore.com/GB/en/product/msds/MDA_CHEM-106177). Your COSHH assessments should already reflect this fact (whether or not you agree with the reprotox classfication of borates, you still need to follow the current classification).

TFA #3

A paper on Trifluoroacetic Acid: Toxicity, Sources, Sinks and Future Prospects https://www.mdpi.com/2071-1050/16/6/2382

Infographic of the Month

I thought you might find this excellent interactive infographic from CircuLaw on the European Green Deal Overview.

It shows the large number of EU regulations which are involved in this mammoth project (aiming for Net Zero by 2050), and you can click through each box to the regulation itself. See https://www.circulaw.nl/European_green_deal.pdf

The Weekend Read

A truly excellent article from Andrea C. Love, Ph.D. on Chemophobia – it’s quite long, but it covers everything we have discussed in the newsletter, and more: https://immunologic.substack.com/p/chemophobia-the-fear-of-chemicals

Process safety corner

Recent incidents:

The latest Trish and Traci podcast covers a serious case of corrosion: https://www.chemicalprocessing.com/process-safety-w-trish-traci/article/55090704/podcast-corroded-pipe-elbow-sparks-explosion-launches-38000-lb-shrapnel

The July ESPC learning sheet is on LPG Bleves: https://epsc.be/epsc_media/Learning+Sheets/2024/24_06+EPSC+Learning+Sheet+_+LPG+Bleve+at+unloading-p-9548.pdf (thanks to Tijs Koerts for the reminder).

An interesting post on the McNamara fallacy (that is decision-making based solely on metrics and ignoring all other factors, such as experience and perception): https://www.linkedin.com/posts/globalhsemanager_one-of-the-better-explanations-of-the-mcnamara-ugcPost-7218504864799039488-gr5q

And a decision making infographic as an antidote to the McNamara fallacy: from Tanmay Vora https://www.linkedin.com/posts/tnvora_visualthinking-criticalthinking-leadership-activity-7216386699394768896-ZdjL

The Weekend Recipe

While I was up in Scotland at the start of July, Mike ended up stuck at home on Sunday (there was an event on at the estate, and he couldn’t do his usual game-keeping rounds). Instead, he decided to do a spot of cooking, and tweaked an online parkin recipe to use up some stem ginger we have in the fridge, to avoid opening a new jar of ground ginger.

Yes, he admitted it was an experiment! (Said with a twinkle in his eye by the man who always complains when I experiment with recipes). Modifying recipes, and using up ingredients creatively – I couldn’t be prouder of him. (And of course I said to him “you can take the man out of the lab (and pilot plant), but you can’t take the lab out of the man“).

The recipe he used is here: https://lovinghomemade.com/2015/02/04/yorkshire-parkin-gingerbread-by-another-name/, although apparently it’s originally from Paul Hollywood of Great British Bake Off fame.

Mike’s experimental parkin

  • 100 g butter
  • 48 g golden syrup
  • 48 g black treacle
  • 1 egg
  • 55 g milk
  • 100 g plain flour
  • 100 g dark brown sugar
  • 100 g rolled oats
  • 1 teaspoon bicarbonate of soda
  • 30 to 40 mls syrup from a jar of stem ginger
  • 1 stem ginger ball, chopped very finely

Method:

  • Set your oven to 170 oC, Gas Mark 5
  • Prepare a square tin by greasing it with butter and lining it with baking paper (at least on the bottom, to help it come out once it’s baked)
  • Melt the butter, golden syrup and black treacle together in a pan over a low heat
  • Chop the stem ginger ball finely and measure out a slug of the syrup for later
  • Beat the egg and milk together in a jug
  • In a large bowl, place the dry ingredients (flour, sugar, oats, bicarbonate of soda), and mix together. Add the chopped stem ginger and mix again
  • Pour the butter mix and eggy mix into the dry ingredients, add the ginger syrup, and mix together thoroughly
  • pour into the tin and bake for around 40 minutes until dropped in the centre, and pulled away at the edges

Findings:

The parkin had risen well, was a lovely colour, and Mike had taken it out of the oven at the right time to make a nice moist cake. Using stem ginger and its syrup still gives a good ginger flavour, but without the “kick” of a fiery aftertaste you get if you used dried ginger. (The original recipe would have used 1 1/2 teaspoons of ground ginger, as Mike halved the ingredients). As I like a strong ginger flavour, if I made this myself I’d probably use a bit more of the stem ginger, but that’s a personal preference.

Reasons to be Cheerful

We’ve had a mixture of Reasons to be Cheerful this month:

And finally, I hope you like our new Chemicals Coffee Time logo, showing at the top of the page. You’ll see it on the new website as well (link below).

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 August or early September.

Kind regards,

Janet

Janet Greenwood, TT Environmental Ltd

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