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Chemicals Coffee Time Monthly, December 2024

Posted09/02/2025
Updated09/02/2025
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Dear Reader,

I hope you’ve had an excellent Christmas break and are back at your desk suitably refreshed. In the run up to the holidays, there was still lot going on, so let’s dive straight in.

EU-CLP font size changes may be blocked in NI under Windsor Framework

Did you know that there was a thing called the “Stormont Brake” built into the Windsor Framework? No, me neither.

Apparently, this is where adopting an EU rule is considered to be detrimental to Northern Ireland, and it can be dropped with the agreement of the UK and EU. It hasn’t been invoked, up until yesterday, when two Unionist parties have invoked it over the new label and font sizes brought in under the EU-CLP legislative act!

Reuters picked up on this, and their article states:

“Under the February 2023 Windsor Framework agreement, London was given the ability to stop the application of amendments to EU law in Northern Ireland if requested by a third of lawmakers from at least two parties in Belfast’s regional assembly.

The Democratic Unionist Party and Ulster Unionist Party said on Thursday they would trigger the so-called “Stormont Brake” in relation to EU rules on the packaging and labelling of chemicals.

The changes that the DUP said would introduce new minimum font sizes and rules around spacing would not be required for similar products in the rest of the United Kingdom.”With trade flows in chemicals between Great Britain and Northern Ireland worth in the region of 1 billion pounds ($1.25 billion) annually, the impact of this divergence would be significant,” DUP leader Gavin Robinson said in a statement.“

Full article here: https://www.reuters.com/world/uk/northern-ireland-unionists-trigger-stormont-brake-first-time-2024-12-19/

I have absolutely no idea (a) whether this will go through the process of getting agreement and be enforced, and (b) how this would work in practice. Would NI-labelled chemicals using the current label rules be permitted into the EU, or only in NI and GB? Watch this space!

Many thanks to the ever-vigilant Aaron McLoughlin for spotting this on 19th December and sharing it on LinkedIn.

Stormont Brake – more details

Following on from the above news, we researched this in more detail.

It takes a lot to surprise Alison Potts at this point. But her initial quote when she read about this situation was “It’s absolutely wild – they’d have to trigger it for all the linked legislation coming in – detergents, pesticides etc… everything that refers back to the label!”

She’s had some time to read the associated documentation, and has decided to go back to the 2012 Oxford English dictionary ‘Word of the Year’, and label the situation an ‘Omnishambles’. Please enjoy the somewhat simplified summary that Ali has provided below:

  • The Northern Ireland Protocol (Later Modified by the Windsor Framework), included in Annex 2 a list of EU regulations that would continue to apply in Northern Ireland
  • It includes all our old favourites – REACH, CLP, POPs, PIC, Biocides, Pesticides, Med Devices, Food Contact, WEEE, RoHS, EcoDesign for Sustainable Products, Cosmetics, General Product Safety, Detergents (They’re all in there!)
  • The Northern Ireland Assembly (Stormont) can require the Windsor Framework Democratic Scrutiny Committee to assess the impact of new and replacement EU acts that are enforceable in Northern Ireland, and seek to prevent its application if it would have significant impact to the everyday life of communities in Northern Ireland. (The so called ‘Stormont Brake’)
  • The Scrutiny Committee report is out, the final decision has not been made.

What we’ve learned so far has thrown up some interesting information:

  • The CLP changes were introduced in 2 steps (the delegated act, and the legislative act). Delegated acts skip the initial scrutiny committees and are rubber stamped, meaning that it was already in law before concerns were retrospectively raised.
  • No accurate assessments of the cost of divergence are being undertaken. No assessment of the CLP legislative/delegated act was done by the UK government because it didn’t apply to GB and the EU initial assessments should (theoretically) include the entire Island of Ireland. [This applies to all post Brexit legislation!]
  • The minister gathering evidence for the enquiry asked the HSE if they could have access to comments from the GB CLP feedback related to divergence issues/costs etc… and was refused. No summary or contributions were provided, because consent wasn’t explicitly given by the participants.
  • The minister responsible is still the “Minister for Social Mobility, Youth and Progression”!
  • The departments responsible for CLP in Northern Ireland are jointly the “Department for Economy”, “Department of Justice” and “Department of Health” – but not “The Department for Agriculture, Environment & Rural Affairs”!

The feedback/evidence gathering appears to have been by invitation only. As a result there were only 2 comments:

  • A brief generic comment from CIA stating that divergence in general was bad
  • A discarded comment from UK fuels associated that was determined to be unspecific to the CLP legislative or delegated act.

As a result, the Inquiry was unable to reach a decision as to whether the CLP legislative and delegated acts have a Significant impact to the everyday life of communities in Northern Ireland.

The piece of information missing from all the documentation is that CLP is one piece of the 40 Regulations that make up the Chemical Framework. All of the forthcoming updates (Detergents, Cosmetics, etc…) specifically refer to CLP. If Stormont block (and diverge) from one, then it will be the start of disentangling from all of them.

Given that the scrutiny committee were unable to reach a conclusion, it is not guaranteed that the Stormont brake will be applied. But we really hope they can iron out the issues in the scrutiny procedure before the next chemical legislative update comes through.

If you want to delve into the multitude of available information we have the following links available:

Many thanks to two of our regular readers who have been sending news articles and links about the Stormont Brake.

Hearing from the HSE, DEFRA and the UK

UK Persistent Organic Pollutants (POPs) update

The UK POPS update is actually out but it seems that it hasn’t been signed off by the Secretary of State for the Environment yet

  • First tabled 8th October in draft form in House of Commons (HoC)
  • Has been approved in HoC and House of Lords on 4th December
  • And is now waiting to be published as UK law

This will bring into law the following substances as POPs:

  • Dechlorane Plus
  • Methoxychlor
  • UV-238

The document is going to become a Statutory Instrument once it is officially published, and is currently called “Persistent Organic Pollutants Amendment Regulation, 2024”. You can download the draft text (which is unlikely to change) here: https://www.legislation.gov.uk/ukdsi/2024/9780348264005 .

Hat tip to Ali for her research skills!

Keeping an Eye on ECHA and the EU

EUDR information system goes live

Dr Binny Todd emailed to let us know that RSPO have highlighted that the new EUDR information system is up and running, see https://green-business.ec.europa.eu/deforestation-regulation-implementation/deforestation-due-diligence-registry_en

“To access the LIVE Server of the Information System, please click on the following link: https://eudr.webcloud.ec.europa.eu/tracesnt/ Please take note that submitting Due Diligence Statements in the LIVE server is to cover only such products that are to be placed on the market or exported after the entry into application. Due Diligence Statements submitted in the LIVE server have legal value and their content can be subject to checks by Competent Authorities.”

Many thanks to Binny and the RSPO for keeping us up to date. The “legal value” statement is quite scary, and so is the fact that this system is so complicated that it needs a separate training version!

EU Detergents Regs

Jay Dawick of Innospec writes:

In case you hadn’t seen it, CESIO have a position paper on the revision to the EU DetRegs: https://www.cesio.eu/index.php/information-centre/document-library/position-papers/18-240429-cesio-position-on-commission-detergents-proposal-final/file

To further elaborate on some of the points raised in the position paper, CESIO has also recently developed factsheets on biodegradability of surfactants in detergents and surfactant vs detergent: https://www.cesio.eu/index.php/information-centre/document-library/factsheets/24-biodegradability-of-surfactants-in-detergents/file and https://www.cesio.eu/index.php/information-centre/document-library/factsheets/23-factsheet-surfactant-vs-detergents/file

Many thanks to Jay for this useful update.

ICYMI – PCN and distributors

A reminder that the implementation of the CLP Legislative update (Regulation EU 2024/2865) brought with it an expanded definition of ‘Submitter’ for Poison Centre Notifications.

EU based entities who are ‘importers, downstream users and/or distributors’ and place product on the market in an EU or EEA country (or Northern Ireland) are responsible for the Poison Centre Notification. Distributors are specifically named now, see https://poisoncentres.echa.europa.eu/-/clp-revision-defines-new-role-for-distributors-in-poison-centre-notifications?

Given that the transition period for PCNs under the legacy systems ends on December 31st 2024 and all mixture products with Health and Physical hazards need to be notified via the ECHA portal by January 1st 2025, we thought it was a good time to remind readers.

Around the World

Chemical snippets

Process safety corner

Recent incidents:

The latest Trish and Traci podcast is on the 40th anniversary of Bhopal: https://www.chemicalprocessing.com/process-safety-w-trish-traci/podcast/55248282/podcast-butterflies-of-bhopal-lessons-written-in-blood (transcript included) . This edition includes special guest Rahmin Abhari, whose graphic novel “Butterflies of Bhopal” is also well worth a read: https://www.linkedin.com/pulse/butterflies-bhopal-ramin-abhari-p-e–htawc/ .

And an interesting read on drivers being distracted: https://www.linkedin.com/posts/globalhsemanager_cars-are-filled-with-ever-more-distractions-activity-7270236688872869889-M6R-?utm_source=share&utm_medium=member_desktop . Being ancient, I really dislike very new cars which require you to look at screens eg for satnav or other reasons. (I still keep a paper road atlas in my car, and take A to Z maps if going somewhere new, and yes, I do stop the car to look at them).

Infographic of the Month

Some tips on productivity: https://www.linkedin.com/posts/colby-kultgen_work-smarter-not-harder-these-20-sentences-activity-7265346973942063104-OdWf

The Weekend Watch

An absolutely fascinating snippet (from a podcast) about bee behaviour and why focussing 100% on known resources doesn’t make sense for the hive (or for any organisation, I would think): https://www.linkedin.com/posts/sean-brady-11a95427_organisations-typically-strive-to-make-themselves-activity-7265127513784217600-b2GA

The Weekend Recipe

Ali and her friends got together for their ‘friends Christmas’ and someone contributed a delicious sticky toffee pudding that they’d done as gluten free and dairy free. It turned out to be a Mary Berry recipe that is incredibly tolerant of substitutions, so we’ve included it below!

Ingredients:

  • 100g (3 1/2 oz) butter or dairy free spread
  • 175g (6 oz) light muscovado sugar
  • 2 large eggs
  • 225g (8 oz) self raising flour or gluten free self raising flour
  • 1 tsp baking powder
  • 1 tsp bicarbonate of soda
  • 3 tbsp black treacle
  • 275ml (9 1/2 fl oz) milk or dairy free alternative

For the sauce:

  • 100g (3 1/2 oz) butter or dairy free spread
  • 125g (4 1/2 oz) light muscovado sugar
  • 1 tbsp black treacle
  • 300ml (10 fl oz) pouring cream or plant based cream
  • 1tsp vanilla extract

Method:

Preheat the oven to 180c / 160c fan / gas mark 4. Grease a wide shallow oven proof dish (needs to be large enough for 1.7L or 3 pints of mixture).

Use electric whisk (preferably) to mix together butter, sugar, eggs, flour, baking powder, bicarb and treacle – for about 30 seconds, or until well combined. Then gradually add the milk and whisk until smooth.

Pour mixture into dish and bake for 35-40 minutes until well risen and springy in the centre.

To make the sauce, put all the ingredients into a saucepan and stir over a low heat until the butter has melted and all the sugar has dissolved. Bring to a slow boil whilst stirring for one minute before removing from the heat. Then pour sauce over the pudding in the baking dish.

Serve with cream, ice cream or custard (or dairy free alternative of your choice).

Note – The sauce can be made a couple of days ahead and stored in the fridge if you are short of time.

Reasons to be Cheerful

We have been on a classic film sequence in December, featuring the international star Owlkitty:

And Phil Rowley suggested this Christmas classic from Penelope Keith, “not another partridge in a pear tree”: https://www.youtube.com/watch?v=DD34J0uO5QU

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.

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

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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