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Chemicals Coffee Time Monthly, November 2024

Posted09/02/2025
Updated09/02/2025
Byghsclassif1stg

Dear Reader,

I hope this finds you safe and well. The big news in November was the much-delayed publication of the EU-CLP Legislative Act, so let’s dive straight into that.

Keeping an Eye on ECHA and the EU

CLP Legislative Act published at last

The EU-CLP legislative act was finally officially published on the 20th November 2024 as “Regulation (EU) 2024/2865 of the European Parliament and of the Council of 23 October 2024 amending Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (Text with EEA relevance)”, see https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202402865 . It will enter into Force on Monday 9th December.

Many thanks to Breda Kosi for spotting this.

These dates are usually important because of the transition deadlines, and in the drafts we saw references to 18 months and 24 months deadlines “from the date of publication”. However, Article 2 of the Legislative Act (page 24) give definitive dates, and these are 30th June/ 1st July 2026; and 31st December 2026/ 1st January 2027. (that is slightly longer than 18 months and 2 years respectively).

So far, so good – but the way that Article 2 has been written is unpicking the bits which apply to what deadline will take some time – the EU really don’t make it easy for us, do they! As usual, we will keep you up to date once we have worked out what is going on.

Alison Potts writes – the legislative act brings the workability changes for the new EU classifications of endocrine disruptors, PBT, PMT (etc…), such as adding them to labels, bridging, PCN and other articles of CLP. It also introduces voluntary digital labelling and measures for labelling refillable packages.

However the thing that has caused the most consternation are the changes to label formatting – Text and background colour, and font and line spacing. Alongside the increased scope for foldout labels and the regulation of their layout and content.

I am sure your inboxes will be overwhelmed with webinars, guidance and training on these new requirements over the next 12-18 months. But for now, I will simply advise you to search for ‘1.2.1.4’ of the legislative act and read that section for yourself. (Janet notes- page 25/26 of the Act).

Guidance on new EU-CLP hazard classes published

Guidance for the new EU CLP Hazards (Endocrine Disruptors to Health and Environment, PBT/vPvB, and PMT/vPvM) has finally been published and is available on the ECHA website! https://echa.europa.eu/guidance-documents/guidance-on-clphttps://echa.europa.eu/guidance-documents/guidance-on-clp

Ali comments- I’m pleasantly surprised by the guidance. They’d already made it clear that (for endocrine disruption) it was going to be heavily based on the previously EFSA guidance which is pretty dry and uninspiring stuff. However the new documentation is actually much clearer to read and a vast improvement on the EFSA text.

Note that this guidance only covers the updates to CLP which were made last year, on the classification methods for the new hazard classes. Official guidance for the labelling format changes is likely to take some time to be published.

A new EU-only SVHC

Triphenyl phosphate has been identifed as an SVHC in the EU (but not in GB at the time of wrting). ECHA announced its publication on 7th November: https://echa.europa.eu/-/echa-adds-one-hazardous-chemical-to-the-candidate-list-1

PFAS

Martyn Shenton of Blue Frog Scientific writes:

Just in case you have not seen the latest PFAS update from ECHA: https://echa.europa.eu/-/echa-and-five-european-countries-issue-progress-update-on-pfas-restriction (summary) and https://echa.europa.eu/documents/10162/67348133/pfas_status_update_report_en.pdf/fc30b694-cfb1-e9ed-7897-d9f3e4ef9ab7?t=1732088416751 (3-page document).

A few key points:

  • It is noted that “restriction options other than a ban” are being considered. This is a significant change from the original proposal of a full ban or a ban with time limited derogations.
  • New uses not originally identified by the dossier submitters continue to be identified following the consultation with examples including sealing applications, technical textiles, printing applications and other medical applications.
  • The importance of fluoropolymers, their use and life cycle are being given special attention due to their high interest from stakeholders.
  • The aim of the restriction proposal to minimise PFAS emissions remains.

Thanks very much to Martyn for this excellent summary.

Divergence – unintended Harmonised / Mandatory Classification Index number issues

Just before she left TT Environmental, Grace (our graduate/ graphics expert) spotted an interesting discrepancy on the Index Numbers for Cinnamaldehyde, CAS no 104-55-2.

The 21st ATP to CLP has an index number 606-155-00-6 for the EU/NI; and the GB MCL 5th edition has an index number 605-155-00-6.

When Grace queried this with the HSE Helpdesk, they explained that:

The 606 number is assigned to ketones and derivatives, whereas cinnamaldehyde, as an aldehyde, should have been assigned number 605. This means the EU index number is erroneous.

Upon transposing this to the GB MCL list, the number was corrected to 605; however, the check digit has not been amended to account for this. Therefore, the GB index number is also erroneous.

We plan to address this error in a future update of the list.

Presumably ECHA are also aware of their error and will update the Harmonised Classification List in due course.

At the moment, if you are using the HC Index number for the EU/NI and or the MC Index number for GB on your SDSs, I think the best thing you can do is use the number as published in the appropriate jurisdiction, but be aware that this should change in both jurisdictions to the correct number at some point in the future, when it will be the same in both EU/NI and GB.

If you were to use the GB number with the correct checksum digit, (if you know how to create that), the danger is that it isn’t currently published anywhere, so people can’t look it up in either the Harmonised or Mandatory Classification Lists.

Many thanks to Grace for her diligence, and we will, of course, keep an eye on this for you and let you know as soon as this is corrected.

Hearing from the HSE, DEFRA and the UK

PFAS bill proposed for UK

Liberal Democrat MP Munira Wilson is bringing in a PFAS in water bill which would introduce statutory limits, see https://www.linkedin.com/posts/rachel-salvidge-21371831_breaking-mp-munira-wilson-has-just-introduced-activity-7259559379056619522-5eBD .

The comments under this post are also worth reading, as some people are highlighting PFAS in sewage sludge (which is then used as a fertiliser on farmland). “Interesting times” ahead for this whole situation (and that’s before we consider the “sewage strike” which angry farmers are considering doing in response to the inheritance tax raid, see https://www.msn.com/en-gb/money/other/furious-farmers-plot-to-stage-sewage-strike-over-rachel-reeves-s-inheritance-tax-raid/ar-AA1txgGN ).

Animal test guidance

The HSE have published guidance on minimising animal tests under UK-REACH, see https://www.hse.gov.uk/reach/animal-testing/index.htm?

New batch of MCL technical reports published

You may have seen an HSE email about this in late November – briefly these are Agency opinions on what the hazard classifications should be, but they will not necessarily be signed into UK law. The updated list can be downloaded from here: https://www.hse.gov.uk/chemical-classification/classification/publication-template.htm?

A proposal on COMAH and the environment

Last month’s LinkedIn newsletter was so full that I had to move this article to November :).

Regular readers will be aware of my commitment to making chemicals in as safe a way as possible, so that people can benefit from our products now and in the future, so I hope what I am about to write is taken in the right spirit, and not as special pleading from someone who doesn’t care about safety, health or the environment.

In the past year, I have had quite a few discussions with sites which might go into the COMAH regulations on the grounds of environmental hazards.

Anyone dealing with COMAH liability will be aware that the Lower Tier thresholds for E1 products (H400 or H410 classification under CLP) is only 100 tonnes, and Upper Tier is 200 tonnes. The thresholds for E2 products (H411) are Lower Tier 200 tonnes, and Upper Tier 500 tonnes, and of course you need to aggregate the E1 and E2 quantities on your site as well.

The reasons why companies are finding themselves hovering around COMAH liability for environment are interesting:

  • changes in hazard classification, e.g. M factors on biocidal active substances making many more substances (and their mixtures) classified as H400 and/or H410
  • the ongoing supply chain crisis, which means companies either need to either hold more raw materials, or have to store finished products until they can be transported off-site

The entire chemical industry landscape has changed quite a bit since the COMAH 2005 regulations, which reduced the thresholds from their original levels in the COMAH 1999 regulations.

The alterations were:

  • E1 (equivalent) Lower Tier reduced from 200 tonnes to 100 tonnes, and Upper Tier from 500 tonnes to 200 tonnes
  • E2 (equivalent) Lower Tier reduced from 500 tonnes to 200 tonnes, and Upper Tier from 2,000 tonnes to 500 tonnes

Is there any scope to return to the 1999 thresholds? as it would keep sites which were environment-only out of COMAH. It does seem a bit unfair that sites where a “traditional” major accident (fire/ explosion/ thermal runaway/ poisoning) can’t be initiated by the inventory should be responsible for taking sites into COMAH, when their risks are generally based around (non-fire/ non-explosion) loss of containment.

A quick scan of the eMARS database in the EC, which lists all reportable Major Accidents and MATTEs (Major Accidents To The Environment), shows that most incidents are not caused by environmental-classified-only materials, although these may be released as a result. Perhaps a tweak to GB COMAH might resolve this anomaly, and help businesses keep operating – maybe even consider a category of “environment-only” sites who could be overseen by the EA?

Again, I hope these suggestions are taken the right way, as it is an attempt to balance the needs of industry (who are important in helping society as a whole) while still providing a high degree of safety on those sites for workers, neighbours, and the environment.

Around the World

Brazil

Melissa Owen , doyenne of Latin American Regulatory Affairs, has just announced that Brazil REACH has entered law there, see https://www.linkedin.com/posts/melissa-owen_reach-latinamerica-chemicals-activity-7262882793242669057-ks82/ .

She has produced an English language translation which you can purchase here for $59 USD: https://ambientelegalacademy.teachable.com/p/brazil-reach-law-15-022-english-translation-708823 (looks like value for money, and no, I’m not on commission!)

Ukraine

In case you missed it – Ukraine’s version of CLP was adopted on the15th November, see https://www.reachlaw.fi/ukraine-clp-regulation-enters-into-force-today/ (many thanks to Nicola Kaye for highlighting this).

Ukraine also has their own version of REACH, and the REACHLaw blog https://www.reachlaw.fi/blog/ has some useful webinars and articles on this.

Infographic of the Month

A fabulous 3-D coloured model of a cell https://gaelmcgill.artstation.com/projects/Pm0JL1 (expanded so it makes more sense – probably much more tightly packed in real life). As someone on LInkedIN commented – it makes one realise how much we don’t know.

And a bonus Infographic – If a lemon was a chemical product: https://jameskennedymonash.wordpress.com/wp-content/uploads/2014/08/ingredients-of-a-lemon-english.jpg

The Weekend Watch

A video on quality and systems – essential viewing if you are interested in safety and systems – a great many pieces of wisdom: https://www.linkedin.com/posts/alexnesbitt_these-10-minutes-with-russ-ackoff-are-simply-ugcPost-7256044405285892097-VLAX

Book recommendation

Chris Packham of Enviroderm (not to be confused by the better known TV “personality”) has written the book on skin care and occupational health. It doesn’t seem to be available from anywhere else except direct from his website, and is a snip at £45, distilling his decades of experience in this vitally important field of work. It’s a bit of reading for me in the evenings at the moment, and full of great practical advice, I thoroughly recommend it. (As usual, I’m not on commission).

https://www.enviroderm.co.uk/guide-book

(Good news – Chris’s daughter Helen also works for Enviroderm, so the company’s expertise will be available to industry for many years to come).

The Weekend Recipe

Talk about a scandal on the Great British Bake-Off! Their so-called Parkin recipe, one of the Technical Challenges in the recent UK series, where everyone is given a basic recipe to make from the same ingredients) has horrified every northern baker in the country.

While it is just about acceptable to have a vegan version, the parkin was iced! This is completely outrageous. Icing has not place on parkin. To make matters worse, there are rumours that the recipe used didn’t even have oatmeal or rolled oats in it! Oats are the very essence of parkin.

Time to dig out the recipe I use which makes a nicely sticky parkin, and once it’s cooled, don’t forget to wrap it in greaseproof paper for several days to mature properly before eating).

Yorkshire Parkin (from Yorkshire Televisions’ Farmhouse Kitchen recipe, book 1)

Ingredients

  • 9 oz flour (plain)
  • 7 oz granulated sugar
  • 3 1/2 oz porridge oats
  • 2 heaped teaspoons powdered ginger
  • 3 oz soft margarine (I use butter, of course!)
  • 2 oz lard (or you can use butter instead, but it won’t be as traditional)
  • 7 oz golden syrup
  • 3 oz black treacle
  • A slightly rounded teaspoon bicarbonate of soda
  • A few drops (about 1 dessert spoon vinegar)
  • 1/4 pint milk

Method

Heat your oven to Gas Mark 4 first, and grease and line a large roasting tin or traybake tin (I use one of my 9″ by 12″ traybake tins). Mix the flour, sugar, oats and ginger together in a large bowl and make a well in the centre. Melt the margarine or butter and the lard together in a pan, and add the golden syrup and treacle. Heat gently together, do not allow to boil. Pour the mixture into the dry ingredients in the bowl. Drop the bicarbonate of soda into the centre, sprinkle the vinegar on the soda, and “watch it fizz” as the original recipe says. Put the milk into the syrup pan, warm it a little to get all the syrup out and pour into the bowl. Mix everything together thoroughly to make a batter, and pour into the tin. Bake in the middle of the oven, or slightly higher, for about an hour. The original recipe suggests checking after 15 to 20 minutes to see if the middle has lifted – if it has, shake it to let it sink again, turn the tin round, and continue cooking. Once baked, cool it in the baking tin, then lift out and cut into quarters. Store 3 days before eating. This keeps very well.

Tips – make sure you mix everything in well, and don’t have pockets of flour left behind. You need to work fast once the reaction starts, to make sure as much carbon dioxide is captured inside the batter rather than all being released to atmosphere, (I wouldn’t let the reaction go to completion before starting to stir everything up), so I’d probably warm the milk in the pan and add that to the bowl before adding the bicarbonate of soda.

It’s been a couple of years since I made this recipe, but it is a good one, and I suspect the lard helps the parkin keep. If you use vegetable margarine and a hard vegetable block like Trex instead of lard, and a nut milk, you can probably make this completely vegan, but I haven’t tried this.

Enjoy!

Reasons to be Cheerful

In November, we went full-on nerd with Don McMillan, engineer and stand-up comedian:

It’s great to have foun someone who is both genuinely funny, and understands that scientists and engineers like graphs and charts!

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 on LinkedIn if you haven’t already, and if you want to get the news early, and much, much more (because we can’t include everything in this monthly round-up), you can sign up to our weekly email newsletter here: https://chemicalscoffeetime.co.uk/. (This website includes the email archive, with both open-access and subscriber-only content).

Chemicals Coffee Time Monthly and Weekly have grown over time to support the chemical industry, and are free to read and free from adverts. If you’d like to support our work, why not treat yourself to one of our new Chemicals Coffee Time mugs? https://chemicalscoffeetime.co.uk/product-range-mug/ .

Look forward to chatting to you in late MMMM or early MMMM.

Kind regards,

Janet

Janet Greenwood, TT Environmental Ltd

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