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Chemicals Coffee Time, 30th August 2024

Posted30/08/2024
Updated29/08/2024
Byghsclassif1stg

Dear Friend,

Happy Friday!

I finally made the time to get out on Warley Moor yesterday afternoon, dodging the (non-forecast) showers to walk Islay our cocker spaniel through the flowering heather. It was a bit windy, so you could only get that magical heather scent when the wind dropped, but there really is nothing like it. Trying to get a spaniel to keep still long enough to take a photograph was also a bit of a challenge!

I hope you had a lovely Bank Holiday on Monday, if you were able to take the time off. Despite the shorter working week, it’s another busy edition of this week’s newsletter, so let’s get stuck in.

Titanium Dioxide news

Well, its been a while since we updated you on the Titanium Dioxide scandal, and a couple of things have cropped up last week that regulatory nerds (like me) might be interested in.

Firstly, Alison Hill of Lomon Billions writes:

I wanted to share some important information regarding the classification of TiO2 supplied by TDMA members. In case I haven’t sent this previously, here are the details:

  • Testing Programme: TDMA conducted a testing programme to measure the content of particles with an aerodynamic diameter ≤ 10 μm, which is one of the criteria for classification under the CLP Regulation.
  • Methods Used: In the absence of an officially designated method, several grades of TiO2 were tested using internationally recognised test methods for dustiness. These methods have shown minimal variability and are suitable for this application.
  • Results: The data consistently indicates that the vast majority of TiO2 grades do not meet the criteria for classification. Consequently, most bags of TiO2 will not require the warning labels noted in Annex VI of CLP.

For more detailed information, please refer to the attached document: ​2021-04-21-TDMA1140j-TiO2-Classification-methods.pdf​

If any readers have any questions or need further clarification, please go to your supplier, who can provide justification and test certification.

Many thanks to Alison for this detailed information.

Secondly, ​Dave Schoneker ​, a staunch defender of Titanium Dioxide, writes on LinkedIn:

Great News!! The UK Committee on Toxicity (COT) has concluded, after significant review of all the data, that TiO2 (E171) when used in food has NO SAFETY CONCERNS!!! See the report at the link below. I’m really glad to see them align their opinion with the opinions of the rest of the worldwide regulatory community outside of Europe. This is clearly what the science shows. The FSA will be publishing a final report by September 30, 2024.

The report summary itself is here: ​https://cot.food.gov.uk/node/11291​ .

Keeping an Eye on ECHA and the EU

Poison Centre Notification and the new EU hazard classes

A ​timely reminder​ from ​Mark Pfister​ of Opesus that we should update our existing Poison Centre Notifications with information on the new EU hazard classes (endocrine disruptors for human health and environment; PBT/vPvB, and PMT/vPvM), regardless of whether the substances are classified for these new hazards or not.

This is even though only Endocrine Disruptors for Human Health trigger the requirements to notify for Poison Centre Notification in the first place…

No wonder the PCN portal has been running slowly!

More on the new EU hazards

As mentioned by the HSE in the email I shared last week – because the EU have placed their new hazards into Schedule 1 of CLP, they are to be treated the same as the GHS hazards, and sit with them, not in the supplemental portion of the label like all the other EUH statements.

France and CoRAP

Please clear a small space for Ali’s soapbox – she needs somewhere to stand and ‘Keeping and Eye on ECHA and the EU’ seems like a pretty good place to start.

A couple of weeks ago, ECHA announced that France had published a conclusion on a CoRAP substance. The substance is ‘Tris(4-nonylphenyl, branched) phosphite’, and I don’t think anyone here will be particularly surprised to find that it’s being put forward as an SVHC.

To be honest, I got halfway through the substance name and I was fairly confident in my conclusion – without any fancy modelling software.

So why am I writing about it? Because it’s been on the CORAP list for 11 years. ELEVEN.

What the heck France?!! Seriously? You’re dragging Titanium Dioxide and Carbon Black through court cases and appeals when you’ve got easy pickings like this on the to-do list.

And even after 11 years, I still don’t think they’re addressing this substance correctly. The argument is it breaks down into Nonyl Phenol (NP). Their entire substance evaluation report hinges on proving the presence of the breakdown product. And that breakdown product is already known to be hazardous enough that it has its own REACH Restriction.

In which case, why take action on this single substance? Why wouldn’t you just shoot for a modification of the NP restriction to cover substances known to breakdown in the environment to NP? Surely that would future proof the regulation and cut out things like 11 year CoRAP assessments and 3 year ATP waits.

Sensible, proportionate, effective legislation. Not Decades of Red Tape.

REACH Appeals

Many thanks to Steven Brennan of Foresight Chemical Policy Monitoring who caught this one! (Well worth following on LinkedIn!)

On August 13th the board of appeal published their Decision on a dispute between ECHA and a REACH Registrant (BASF). The decision can be found here ​https://echa.europa.eu/about-us/who-we-are/board-of-appeal/decisions​

To summarise – The registrant had initially submitted a 100-1000 tonne registration. The initial dossier check had resulted in a request for more test data. And the registrant then reduced their tonnage band.

ECHA refused to accept this, continued to demand the higher tonnage data, and accused the registrant of reducing the tonnage only to avoid the testing.

Conclusion – The registrant was able to show commercial basis for reduction in tonnage. And the appeal court ruled they were only subject to the requirements of the lower tonnage dossier.

Ali’s two cents…. BASF were lucky and ECHA made the wrong argument!

This was a joint submission, so if ECHA had instead argued that the testing was warranted because the total tonnage of all registrants would still be in the higher band, then they’d have won the argument. I don’t like it, but we’ve seen this alternative argument repeatedly: Registrants can be expected to provide test data from a higher annex if the total tonnage of the joint registrants exceeds the individuals tonnage band.

If you haven’t checked your tonnage bands lately then it’s something that we’d recommend. Particularly as new testing for PMT and Endocrine Disruption is starting to be considered. Your EU tonnages may be quite different to your original figures now that the GB numbers have been removed. Moving registration bands is easier to do before testing is commissioned and paid for, and before dossier checks are underway.

Around the world

More Latin America news from Melissa Owen: ​https://www.linkedin.com/pulse/chile-reach-single-use-plastics-brazils-ecological-pact-melissa-owen-hca5c/​

Chemical snippets

Process safety corner

Recent incidents:

Did you know that Canada has introduced a Process Safety Management standard? It’s discussed in this month’s Trish and Traci podcast? at ​https://www.chemicalprocessing.com/process-safety-w-trish-traci/article/55134091/podcast-worlds-first-process-safety-management-standard​

An article on people’s approaches to risk with age, (although the author doesn’t seem to have heard of Risk Compensation Theory, which states that we have an individual level of risk we are comfortable with, and will adjust our approach to suit our own level): ​https://www.linkedin.com/pulse/exceptions-really-can-make-mess-rule-mark-townend-plvce​

Some thoughts on energy efficiency from Tom Baxter: ​https://www.linkedin.com/posts/tom-baxter-a141a1b_net-zero-uk-energy-efficiency-energy-efficiency-activity-7234103612287643649-QPsb​

How are your Permits to Work?

A checklist to make sure they’re working as intended from the Center for Chemical Process Safety, courtesy of Sarah Eck: ​https://www.linkedin.com/posts/engineereck_excerpt-field-review-of-permits-ccps-ugcPost-7234006623826952193-_Lhk​ . The full document is here: ​https://www.aiche.org/sites/default/files/html/ccps/3379576/V2/FieldReviewofPermits-CCPS-SWP.html​ .

Jobs update (UK stats from LinkedIn)

Regulatory affairs, 1,766 jobs; Health and Safety, 1,380 jobs (but search on manager, specialist, officer etc as well, as the LinkedIn algorithm is still playing up).

Events

The Autumn meeting of the Chemical Regulations Self Help Group is nearly upon us, it’s at our usual venue of Halifax Bradley Hall Golf CLub on Tuesday 17th September. Members should have received their invites by now. Details of the group at ​https://www.chemselfhelp.co.uk/​.

And we’re about to restart the training phase of CLP Mastery, our combination training course and membership, on Wednesday 11th September, more information here: ​https://clpmastery.com/​ for people who want to dive deep into classification, labelling, packaging, SDSs and chemical product stewardship.

If you or a colleague want a more basic introduction to CLP and SDSs, perhaps so you understand the principles in the software you’re using, we are looking to run our new online course in a few weeks time, as last week’s version went very well, and our first trainees have really helped with sorting out what needs to be focussed on, thanks to everyone who attended.

If you are interested in either type of training, please reply to this email with any questions you have.

Infographic of the week

An excellent summary of productivity techniques: ​11 time management tools infographic.pdf​ . More details here: ​https://www.linkedin.com/posts/christianpoensgen_increase-your-daily-output-by-40-small-activity-7234535192487432192-rcff​

The Weekend Read

Well, August has turned out to be “Andrea Love month” when it comes to the Weekend Read. She has produced an excellent series of articles which are truly worth reading. The next one I’m sharing is about how the IARC operates: ​https://immunologic.substack.com/p/what-does-carcinogenic-really-mean​ .

The Weekend Recipe

On my most recent trip to Scotland, I was in Linlithgow DIY, a good old-fashioned iron-mongers and DIY family business, when I spotted a dumpling cloth, complete with recipe printed on it, by a company called Studio 66a. So I thought you might like it (you don’t really need a special cloth, just a tightly woven clean tea towel). This quantity makes a large clootie dumpling.

Ingredients

  • 1 lb self-raising flour
  • 1 lb raisins
  • 1/2 lb suet
  • 3 teaspoons mixed spice
  • 1/2 lb granulated sugar
  • 3 tablespoons treacle (meaning black treacle – in Scotland, golden treacle is golden syrup, a fact which confused me very much when I tried to make treacle tart as a teenager!)
  • 1/2 teaspoon salt
  • milk to mix

Method

Place all dry goods in a large bowl and stir through to combine evenly. Add sufficient milk to form a stiff dough. Prepare your cloot (cloth) by dipping it in boiling water, then remove into anther large bowl and dredge with flour. Spoon the dough into the prepared cloth and tie tightly, but leave room for the dough to swell up.

Place a plate in the bottom of a large pan, add in the tied-up clootie dumpling, and pour in how water to cover. Simmer for “a good 3 hours”. Turn out very gently onto a hot serving dish and dry out in the oven for 10 minutes. Serve with custard, or cream, or ice cream.

This should keep well, and you can cut off slices and fry them in butter. (Remind me again, why is Scotland the heart attack capital of the world?)

Enjoy!

Reasons to be Cheerful

Concluding our “summer of sport” Reasons to be Cheerful, funny football moments ​https://www.youtube.com/watch?v=zqxV0ken2jg​

Many thanks for reading this newsletter, and many thanks to everyone who has contributed to it this week. As usual, if you have anything you’d like to share, please email me and I’ll do my best to include it in the next newsletter.

I hope you have a good day today, and a lovely weekend with your family and friends. Take care, stay safe and I hope to be able to write to you next week.

Kind regards,

Janet

Janet Greenwood

TT Environmental Ltd

01422 24 22 22 07900 21 21 26 ​janet@ttenvironmental.co.uk​ ​www.ttenvironmental.co.uk​

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