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Chemicals Coffee Time Monthly, June 2025

Posted17/07/2025
Updated17/07/2025
ByEmma

Dear Reader,

June was another busy month for chemical regulations, but to keep us cheerful there’s news of a Lego periodic table, and an AI “you couldn’t make it up” moment.

Hearing from the HSE, DEFRA and the UK

Survey on chemical regulations changes

The HSE have announced a major survey on UK chemical legislation, which is open until 18 August 2025, 11:59pm.

The survey covers these areas

  • GB Biocidal Products Regulation (GB BPR)
  • GB Classification, Labelling and Packaging of substances and mixtures (GB CLP)
  • the export and import of hazardous chemicals – GB Prior Informed Consent (GB PIC)

If you are affected by any or all of these pieces of legislation, now is the time to have your say! https://consultations.hse.gov.uk/hse/chemicals-legislative-reform-proposals/ .

And if you’re unsure about how to respond to this survey, Steptoe LLP are running a webinar discussion tomorrow (9th June 2025) with Darren Abrahams, Tom Gillett and Zanda Romata which may help you clarify your position. See https://www.steptoe.com/en/events/effective-advocacy-on-proposed-reform-to-clp-biocides-and-pic-in-the-uk.html .

UK interim approach to PMT for PFAS

Huge thanks to Steven Brennan of Foresight.io, who spotted that the UK Government have published this interim approach https://www.gov.uk/government/publications/interim-position-statement-on-the-approach-to-pmt-concept-to-support-uk-reach-risk-management-of-pfas/interim-approach-to-the-pmt-concept-to-support-uk-reach-risk-management-of-pfas .

It looks like PMT (and vPvM) will be considered under UK-REACH to start with, and PFAS is being used as a test case for this. I think that these new hazards will be rolled out to all registered substances in time. GB appears to be taking a “non threshold approach” to PFAS, at least to start with, which may lead to divergence from EU-REACH.

The situation with GB-CLP is interesting, as the HSE have been quite firm about stating that they will only consider the new hazard classes if they are implemented by GHS, and not just because they are in EU-CLP. This approach appears to be confirmed by this statement “The UK will continue to participate in UN GHS discussions on proposed new hazard issues (which includes PMT as the EU has implemented this into EU CLP as new hazard classes). If criteria are defined within UN GHS, the UK will still have to consider implementation in GB CLP.“.

It is very encouraging that the UK’s statement recognises that there are gaps in the understanding of PMT/vPvM substances, and it proposes further research in three areas:

  • a new method to define the inherent mobility of any substance accounting for both intrinsic substance and extrinsic environmental properties
  • a screening tool to aid prioritisation at registration that accounts for hazard and different exposure scenarios.
  • and a monitoring programme to target persistent and mobile substances

It will be interesting to see how all of this is implemented in practice.

Keeping an Eye on ECHA and the EU

23rd ATP to CLP published

Good news – the 23rd ATP to EU-CLP has finally been published as COMMISSION DELEGATED REGULATION (EU) 2025/1222 on the 20th June , and you can download it here: https://eur-lex.europa.eu/eli/reg_del/2025/1222/oj/eng

Many thanks to Yannick Gama of Kodak, Laura Coward of Lubrizol, Breda Kosi (retired) and others for sending this link through. As I always say, “better to hear twice than not at all”.

Laura notes that there are 22 new entries and 10 updated entries. The official timeline for adoption of the new classifications is:

  • This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union (that is 10th July 2025). It shall apply from 1 February 2027.

Still more Harmonised Classification proposals

When will this end? a recent ECHA newsletter noted that an intention has been submitted for:

  • Silver chloride (provisional chemical name) (EC 232-033-3, CAS 7783-90-6).

Four proposals have been submitted for:

  • diclofop-methyl (ISO); methyl 2-(4-(2,4-dichlorophenoxy)phenoxy)propionate; methyl (RS)-2-[4-(2,4-dichlorophenoxy)phenoxy]propionate* (EC 257-141-8, CAS 51338-27-3);
  • 2-ethylhexyl 10-ethyl-4,4-dimethyl-7-oxo-8-oxa-3,5-dithia-4-stannatetradecanoate* (EC 260-829-0, CAS 57583-35-4);
  • [1α(S*),3α]-(α)-cyano-(3-phenoxyphenyl)methyl3-(2,2-dichlor-oethenyl)-2,2-dichlorovinyl)-2,2-dimethyl-cyclopropanecarboxylate αCypermethrin) (provisional chemical name) (EC – , CAS 67375-30-8); and
  • Sodium fluoride* (EC 231-667-8, CAS 7681-49-4).

Another CLH proposal for a fragrance component

Adam Batting,of Contract Candles and Diffusers writes: France has proposed an Opinion Development for 1,3,4,6,7,8-hexahydro-4,6,6,7,8,8-hexamethylindeno[5,6-c]pyran CAS 1222-05-5. Sometimes called Galaxolide or HHCB. The proposal is to classify this product as a Reprotoxic 1B (H360Df)

This is a very popular fragrance ingredient and would have a large impact on a wide range of industries that use fragrances.

Understandably, the comments have come straight away from the lead registrant, other interested parties in the fragrance industry and even a couple of member states claiming Reprotoxic 2 may be more appropriate.

This will be an interesting one to watch as recently the RAC does have a tendency to go for the higher classification which could be very impactful people using this chemical.

Many thanks to Adam for sending this information through, very serious news for anyone using fragrances in their products.

Three more substances added to EU Candidate (SVHC) list, and more in the pipeline

ECHA have just announced that they’ve added three more substances to the Candidate list under EU-REACH, see https://echa.europa.eu/-/echa-adds-three-hazardous-chemicals-to-the-candidate-list

  • 1,1,1,3,5,5,5-heptamethyl-3-[(trimethylsilyl)oxy]trisiloxane, CAS no 17928-28-8
  • Decamethyltetrasiloxane, CAS no 141-62-8
  • Reactive Brown 51

And Phil Rowley one of our regular correspondents, has spotted that the Member State Committee meeting includes news of more SVHC proposals, see https://echa.europa.eu/-/echa-member-state-committee-june-meeting-highlights

ECHA writes: ” In its June meeting, ECHA’s Member State Committee (MSC) agreed to identify two new substances of very high concern, SVHC. ECHA will add them to the Candidate List later in June:

  • Decamethyltetrasiloxane (L4); (EC 205-491-7); and
  • 1,1,1,3,5,5,5-heptamethyl-3- [(trimethylsilyl)oxy]trisiloxane (M3T); (EC 241-867-7)

In addition, one substance will be added to the Candidate List in June without the committee’s involvement:

  • Tetra(sodium/potassium)-7-[(E)-{2- acetamido-4-[(E)-(4-{[4-chlor-6-({2-[(4-f luor-6-{[4-(vinylsulf onyl)phenyl]amino}- 1,3,5-triazin-2-yl)amino]propyl}amino)-1,3,5- triazin-2-yl]amino}-5-sulf onato-1-naphthyl)diazenyl]-5- methoxyphenyl}diazenyl]-1,3,6-naphthalin; (EC 466-490-7)”

Simplification of CLP

There was a feedback meeting on the 16th May which DG-GROW for CLP, called “REALITY CHECK WORKSHOP ON THE POSSIBLE SIMPLIFICATION OF CHEMICALS LEGISLATION – CLP (CLASSIFICATION, LABELLING AND PACKAGING OF SUBSTANCES AND MIXTURES)”.

The 3 page minutes document is an absolute zinger – basically “industry says this is unworkable”, and it is recommended these proposals are either scrapped or have much longer phase in periods: AOB_CLP_Meeting minutes – CLP Reality Check Workshop.pdf

AISE have also reported on this meeting to their members, see pages 21 to 25 https://aise.eu/app/uploads/2025-05-22-AISE-members-info-session_slides.pdf

You may have already seen the ChemicalWatch news item that the CLP labelling rules may be rolled back, see https://product.enhesa.com/1543779/european-commission-to-reverse-clp-requirements-in-major-shake-up – apparently the announcement is due today, 8th July.

Watch this space!

Chemical snippets

Process safety corner

Recent incidents:

Insights:

Reminder – safety isn’t just about psychology

A very important reminder from Chris Brookes-Mann in a comment on this LinkedIn post: https://www.linkedin.com/posts/dr-clare-dallat-10b41940_workhealthandsafety-activity-7335478459835551746-3Wc7

“When every problem is a treated like a cognitive/social psychological problem, then everything in that article is absolutely valid. But without being too meta about it, systems theory tells us that systems are mere constructs.

If, say, some hitherto unknown chemical reaction involving exotic substances causes a reactor vessel to rupture, we could study the sociotechnical system, and look at first and second stories and bounded rationality, and consider why it made sense for all concerned to progress the process development to the stage it was at when the runaway reaction occurred.

Or we could study the process system and conclude that that combination of reagents, in those quantities, in that size/form factor of vessel, being operated at that temperature and/or pressure, and with those heating/cooling arrangements is unsafe. Which would be more helpful to us to find a better way of doing what we want to do?”

BADGP National Dangerous Goods Awareness Day, 10th July

The 2nd National Dangerous Goods Awareness Day will culminate in a free to all webinar on Thursday 10th July 2025 at 1300hrs on DGSAs and DG competent persons – what the legal requirement is and what they do within a company. Each day from the 1st July will see the provision of a dangerous goods poster for your workplace each day with an option to use the poster as a ‘Toolbox Talk’.

More details here: https://badgp.org/event-5815699

Another periodic table for our collection – in Lego!

If you subscribe to the RSC Chemistry World newsletter, you may have already seen this, but I couldn’t resist it – a Spanish scientist has made a spiral periodic table in Lego and is publicising this to try and get an official version made! https://www.chemistryworld.com/news/campaign-launched-to-get-lego-periodic-table-playset-out-there/4021543.article

You can even vote on the Lego website to encourage them to adopt it: https://ideas.lego.com/projects/8b77f7bc-026c-4865-908b-9af273a18205 (luckily there are around 400 days left to vote, but it’s best to vote now before you forget). Note that you will need to create an account on the Lego website, if you don’t already have one.

AI news – Automated Idiocy

Peter Watts of Bibra Toxicology posted this on Linkedin:

If you ask Google “Is the swimming pool on the Titanic still full?”, Google AI replies:

“AI Overview. No, the swimming pool on the Titanic is not currently filled with water. The pool is likely empty due to several factors, including the pool’s base cracking as the ship sank and the crew’s focus on passenger evacuation. Additionally, the immense water pressure at the Titanic’s depth would crush any voids within the ship, including the pool.

Here’s a more detailed explanation:

  • Cracked Pool Base: As the ship sank, the structure of the Titanic was severely damaged, and the pool’s base is likely to have cracked, allowing the water to escape.
  • Evacuation Priority: The crew was primarily focused on the safety of passengers and evacuating them, not on maintaining the pool’s water level.
  • Water Pressure: At the Titanic’s depth of 12,500 feet (3,800 meters), the water pressure is immense, which would likely crush any empty spaces within the ship, including the pool.”

Truly, you couldn’t make this up!

Infographic of the Month

Dust explosion infographic: https://www.linkedin.com/posts/chris-cloney_combustibledust-explosionsafety-processsafety-ugcPost-7336789460631638017-LjXt

The Weekend Watch/ Read

Nomenclature for risk assessment book – free download from IchemE – an oldie but goldie – https://www.icheme.org/media/28093/nomenclature-for-hazard-and-risk-assessment.pdf (only 51 pages)

The Weekend Recipe

My neighbour, Janet R, has a really easy recipe for bran loaf from her Mother (who’s still going strong in her early 90s), which I thought you might like:

Bran loaf

Place all of these in a large bowl and soak overnight

  • 2 cups all bran
  • 2 cups sultanas
  • 2 cups sugar
  • just under 1 pint of milk

The next day, set your oven to gas mark 2 (150 C) and line and grease a loaf tin.

To the bowl of soaked ingredients, add

  • 2 1/2 cups self-raising flour and stir until mixed thoroughly, then pour into the tin

Bake for around 1 1/4 hours until done (a skewer comes out clean when placed in the middle of the loaf). Cool in the tin for around 10 minutes, then turn out of the tin and cool on a rack as usual.

Reasons to be Cheerful

It’s amazing what you can stumble across on Youtube, and I came across one of the famous Smash adverts with the Martians the other day, so I thought some old funny adverts might be nice to share.

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).

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

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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