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Chemicals Coffee Time Monthly, August 2025

Posted02/10/2025
Updated02/10/2025
ByEmma

Dear Reader,

I hope you’ve managed to have a good holiday and are back at work refreshed. August can be a quiet month for regulations, due to the holiday season, but unfortunately we have had some very serious accidents.

Hearing from the HSE, DEFRA and the UK

Technical UK-REACH reports published

The HSE have just published their first batch of these reports, which can be found here: https://www.hse.gov.uk/reach/rmoa.htm

Another batch of HSE MCL opinions published

As you probably know, this is a step in the process before they are signed off by the Secretary of State, but it gives us an early warning on what the new or updated GB Mandatory Classifications are likely to be. You can download them as an excel file from https://www.hse.gov.uk/chemical-classification/classification/publication-template.htm

These substances are:

  • 3,5-dimethylpyrazole, 67-51-6
  • ulexite (CaNaH12(BO3)5 × 2H2O) [1] ulexite (CaNaH12(BO3)5 × 2H2O), calcined [2], 1319-33-1 [1] 92908-33-3 [2]
  • colemanite (CaH(BO2)3 × 2H2O) [1] boron calcium oxide (B6Ca2O11), hydrate (1:5) [2] colemanite, calcined [3], 1318-33-8 [1] 854267-07-5 [2] 92908-12-8 [3]
  • tincalconite (B4Na2O7 × 5H2O), 12045-88-4
  • Thermally treated garlic juice, 8008-99-9
  • [ethane-1,2-diylbis[nitrilobis(methylene)]]tetrakisphosphonic acid, 1429-50-1
  • [ethylenebis[nitrilobis(methylene)]]tetrakisphosphonic acid, calcium sodium salt, 85480-89-3
  • [ethylenebis[nitrilobis(methylene)]]tetrakisphosphonic acid, potassium salt, 34274-30-1
  • [ethylenebis[nitrilobis(methylene)]]tetrakisphosphonic acid, sodium salt, 22036-77-7
  • 2-pyrrolidone; pyrrolidin-2-one, 616-45-5
  • Rape oil; rape seed oil, 8002-13-9
  • Tebuconazole (ISO); 1-(4-chlorophenyl)-4,4-dimethyl-3-(1,2,4-triazol-1- ylmethyl)pentan-3-ol, 107534-96-3
  • Eugenol; 2-methoxy-4-(prop-2-en-1-yl)phenol , 97-53- 0

PFAS and fire fighting foam consultation

Bill Atkinson of OHES writes – the HSE published its Annex 15 assessment on PFAS and fire fighting foam and proposed restriction report. The consultation on this is now open until 18th February 2026. Link is: https://consultations.hse.gov.uk/crd-reach/pfas-in-firefighting-foam-fff-restriction-proposal/

Martyn Shenton of Blue Frog Scientific also notes: The HSE’s assessment concluded that the use of PFAS in FFF poses significant risks to both the environment and human health (through environmental exposure), and that these risks are not adequately managed under current controls with persistence being a key property of concern.

This initiative follows the recommendation made in the April 2023 Regulatory Management Options Analysis (RMOA). The proposed restriction applies to all PFAS that meet the definition of “any substance containing at least one fully fluorinated methyl (CF₃) or methylene (CF₂) carbon atom without any hydrogen, chlorine, bromine, or iodine atoms attached.” The scope includes production, use, storage, and disposal of PFAS in FFF.

Many thanks to Bill and Martyn for sending this information through.

It is an unusually long consultation, which I think reflects the HSE’s understanding of the benefits of fluorinated compounds in firefighting foam, and the fact that foam is the best method to deal with certain fires e.g. alcohol fires (which actually require a very specific Alcohol Resistant Fire Fighting Foam – AR-FFF). Please do participate in the consultation if this topic affects you.

Keeping an Eye on ECHA and the EU

There wasn’t a lot of new information coming out of ECHA in August because of the holidays, but it gave us a chance to catch up with some things we’d missed earlier.

Borderline cases manuals published

A new guidance document on borderline cases between articles and substances/ mixtures was published in May, and you can find it here: https://echa.europa.eu/documents/10162/17240/borderline_cases_substances_articles_catalogue_en.pdf/ (apologies for missing it earlier).

Many thanks to Freesia Day of Connect4Compliance who has spotted that the new EU Borderline Manual v5.5, which covers cosmetics which overlap with other regulations, was published back in June https://webgate.ec.europa.eu/circabc-ewpp/d/d/workspace/SpacesStore/95fd87e4-5ded-4921-958c-75ff482b3d4c/download .

Charges increasing in the EU

New EU BPR fees announced by ECHA, thanks to Daniela Romano for highlighting this: https://eur-lex.europa.eu/eli/reg_impl/2025/1490/oj/eng .

Steven Brennan continues his excellent work keeping us all up to date. His latest “spot” is that DG-GROW are consulting on increasing REACH fees, but also altering some of them, with a view to encouraging SMEs, see the proposals here: https://ec.europa.eu/transparency/comitology-register/screen/meetings/CMTD%282025%291408/consult?lang=en, and Steven’s views on this https://www.linkedin.com/posts/dr-steven-brennan_comitology-register-activity-7355908639091486721-9JTh

MOCS in EU-CLP coming in 2026

A timely reminder from one of Martyn Shenton’s colleagues at Blue Frog Scientific about what they refer to as MOCS, the More Than One Constituent Substance category which the EU are bringing in, see https://www.bluefrogscientific.com/chemical-regulatory-news-and-views/get-ready-mocs-new-clp-rules-coming-2026.

This concept was brought in via the CLP Legislative Act, https://eur-lex.europa.eu/eli/reg/2024/2865/oj/eng, and involves classifying certain hazards of MOCS based on components as well as test data. It could, in theory, mean divergent hazard classifications for certain substances between EU/NI and GB.

CLP Simplification sting in the tail for labels via Digital Contact?

One of our lovely CLP Mastery trainees has spotted an addition to the CLP simplification proposals, which are available here: https://single-market-economy.ec.europa.eu/publications/simplification-certain-requirements-and-procedures-chemical-products_en.

Are you aware that there is a proposal to remove the supplier telephone number from the CLP label mandatory information, and replace it with something called a “digital contact”?

The digital contact is separate to the digital label, and is defined as “…any up to date and accessible online communication channel through which a supplier can be reached or engaged without the need to register or down or to download an application“.

As far as we can tell, this is not a phone number, but whether it means an email address, or a direct message, or a chat bot or something else is unclear.

If you have any information on the digital contact proposals, please do send them through, as it would be good to share this with our readers.

Titanium dioxide permissible in pharmaceuticals

After the excellent news that the Titanium Dioxide classification as Carc. 2, H351 has been annulled, in a separate decision, the European Medical Agency have finally published their decision to continue the use of Titanium Dioxide in pharmaceuticals, see https://www.ema.europa.eu/en/documents/report/feedback-european-medicine-agency-ema-eu-commission-request-evaluate-feasibility-alternatives-replace-titanium-dioxide-tio2-medicinal-products-its-possible-impact-medicines-availability_en.pdf .

It appears that this report was held back until the Titanium Dioxide judgement had been finalised. There is also a “working document” on this topic here: https://health.ec.europa.eu/latest-updates/commission-staff-working-document-use-titanium-dioxide-medicinal-products-2025-08-06_en

Further details from Dave Shoneker of Black Diamond Regulatory here: https://www.linkedin.com/posts/dave-schoneker-0938133_commission-staff-working-document-on-the-activity-7358971671766081536-g7vp

However, there is no word on Titanium Dioxide’s use in food, where it has been banned since 2022 – https://www.efsa.europa.eu/en/news/titanium-dioxide-e171-no-longer-considered-safe-when-used-food-additive – watch this space to see if/ when this changes.

More CLH proposal updates

Despite the fact that ECHA appeared to be on holiday, we did have some updates made to the CLH proposal list this week (full details here https://echa.europa.eu/registry-of-clh-intentions-until-outcome):

  • 2 new CLH consultations have been announced, for on 3-aminopropyldimethylamine and 3-aminopropyldiethylamine, although they have not appeared on the official list yet at https://echa.europa.eu/harmonised-classification-and-labelling-consultation
  • 1 new proposal for a CLH, for Nerol (important news for fragrance manufacturers/ users
  • 3 CLH proposals have been withdrawn, for Silver zeolite, Silver sodium zirconium hydrogen phosphate, and Silver copper zeolite

Around the World

GHS Rev 11 is finally published!

After the UN’s announcement that GHS Rev 11 had been published, only for us to find out that actually it hadn’t been, either as a paid-for or free pdf, Tatiana Moneró of Lisam Brazil writes: “Better late than never, GHS 11th Rev is available for purchase in shop.un.org https://shop.un.org/books/global-harmon-syst-class-11-26470 “. Many thanks to Tatiana, who also broke the original news over a month ago.

Latin America update

Melissa Owen has produced a couple of excellent infographics on Latin America chemicals regulation:

Chemical snippets

Training course dates for your diary

Just a quick reminder that here at TT Environmental we are running our short course in classification, labelling and SDSs, CLP Fastrak, in September, and the full live CLP Mastery training course in October and November.

  • CLP Fastrak will run on 16th/17th/18th September, with the catch up meeting on 24th September.
  • CLP Mastery live training will run every Wednesday morning from 8th October to 12th November, with the catch up meeting on 19th November. There are also 12 “Ask Us Anything” meetings, running from October 2025 to September 2026, in the afternoon of the 2nd Wednesday of the month.

If you come on the short course, and want to upgrade to full CLP Mastery, you only pay the difference between the fees. There are discounts for two or more people from the same company attending the same course.

More information on CLP Fastrak here: https://docs.google.com/document/d/1F64oDGQwEz8x9_sQDz7g6u9geICfwGeZZ40zYFLMUs8/edit?usp=sharing and CLP Mastery here: https://clpmastery.com/

Please note that enrolment closes on the Friday before the each course starts, as we need to print and send out the Workbooks, and they re-open for self-serve trainees once the course has finished. The closing date this year for CLP Fastrak is Friday 12th September 2025, and for CLP Mastery is Friday 3rd October 2025.

To secure your place(s), please send me an email or direct message with the names and email addresses of the trainees, and which course(s) you want to enrol them in.

Process Safety Corner

Recent incidents:

Insights:

Insights (this month on physical failures leading to incidents):

And some very sound advice on facilitating PHAs in the real world, with notes on what isn’t mentioned in training – https://www.linkedin.com/posts/lucas-bienert_hey-team-my-latest-article-is-available-activity-7358001115063357440-UlGf

A great explanation on Human errors vs human factors from Tom Geraghty https://www.linkedin.com/posts/geraghtytom_human-error-vs-human-factors-on-a-recent-activity-7362919987105144833-zU5O

A brief history of Bow Tie Diagrams: https://www.linkedin.com/posts/davidslater_bow-ties-beginnings-ugcPost-7363480677964570626-54J8

The EC have just published a guide to investigating process safety incidents, see Handbook for Learning Lessons from Chemical Incidents Wood & Allford 2025 (EU).pdf . I have not looked at this yet, and would welcome your comments on it.

And the CSB have just published a third volume of their Chemical Incident reports collating learning about incidents https://www.csb.gov/us-chemical-safety-board-releases-volume-3-of-chemical-incident-reports-incidents-resulted-in-18-billion-dollars-in-property-damage/

Finally, as someone who has serious concerns about Reason’s Swiss Cheese model, I was amused to find that the Swiss are having trouble making holes in their cheese, and are actually having to add particulates to create them, see https://www.linkedin.com/posts/andybrazier_swiss-cheese-hole-mystery-solved-its-all-activity-7366741204119494656-4v4w

Infographic of the Month

As there’s a bit about AI in this newsletter, I thought this infographic from Tanmay Vora “What AI doesn’t do” might be of interest: https://www.linkedin.com/posts/tnvora_sketchnote-facilitation-activity-7346152313553575937-RHSV

The Weekend Watch/ Read

A fascinating read on memory https://www.linkedin.com/posts/pelleguldborghansen_have-you-ever-walked-into-the-kitchen-activity-7363094814575288320-qmRZ

So that’s why I’ve got to retrace your footsteps sometimes to recall what I was thinking about- it’s not just old age :)!

AI – automated idiocy

Chat GPT-5 was released on the 7th August, and Gill Pagliuca of Ricardo has spotted several reports that it’s counting the letter “b” as appearing three times in the word “blueberry”! This chap has actual evidence – https://kieranhealy.org/blog/archives/2025/08/07/blueberry-hill/ .

And something else that you might find amusing – I was chatting to a software chap in California recently who said that most AI is like “mansplaining” at the moment – it’s very confident (if not arrogant), oversimplifies things too much, and is quite convinced that everyone else is wrong!

Podcast

Chris Hughes of Embark Chemicals latest podcast guest is… (ahem)… me! You can find it here: https://www.embarkchemical.com/podcast/janet-greenwood. Thank you very much to Chris for the invite, it was very enjoyable to record.

The Weekend Recipe

It’s been a good year for brambles/ blackberries here, so I thought you might like a jam recipe for them. I usually make them into a jam with apples, so when this experiment worked, I thought you might like it too.

Bramble (blackberry) jam without apples

  • 1 kg brambles, or slightly over
  • 1 kg bag of granulated sugar (jam sugar is not necessary, but use if you like)
  • 1 – 2 tablespoons of lemon juice (a flavour enhancer, and the brambles were quite ripe so I wanted a little more acid)

First prepare your jars, you will need around 5 or 6 modern (ie 12 oz) jam jars for this batch. Sterilise them https://www.bbcgoodfood.com/howto/guide/how-sterilise-jars. If you have a jam funnel, remember to clean and rinse that out, and dry in the oven as well.

Place your brambles, lemon juice and sugar in a large pan over a low heat, and stir until the sugar is dissolved and the juice is running nicely. You may want to bash a few brambles to get the juice flowing early. (Top tip – when you add the sugar to the brambles, the mixture should be no more than halfway up the side of your pan. If it is, either find a larger pan, or make the jam in two batches.)

Once the sugar is dissolved (don’t forget to scrape the sides of the pan into the liquid), fire up the heat and boil until setting point is reached, stirring occasionally. Take the pan off the heat, and leave to cool for around 10 minutes (to stop the fruit floating to the top). Then spoon carefully into your jars using the jam funnel. Either put the lids on straight away, while the jam is still hot; or leave until the jam is cool. Doing anything else tends to result in condensation inside the top of the jar, which you’ll want to avoid.

Once the jars are cool, wipe off any spilt jam from the sides (and if you can avoid spilling jam, you’re a better person than me), and label with the contents and date. If you don’t have enough for a full jar, use that one up immediately.

Findings: this has a more pure bramble flavour than if you make bramble and apple jam, although it does set a bit more “loosely” in my experience. Mike was so taken with the flavour that he used it for his jam sandwich the next day – praise indeed!

Food safety note for our American readers – if you make any preserve, you will probably process it further (“canning”), and the fact that we don’t do it in the UK may freak you out. Feel free to do your own additional preservation methods, which are not used here (I suspect because we are a much cooler climate).

Reasons to be Cheerful

We seem to be losing a lot of important people at the moment, and the Reasons to be Cheerful reflect this.

First, we have Tom Lehrer, so I couldn’t resist the Elements Song, which includes a bonus version based on Aristotle’s view of the world: https://www.youtube.com/watch?v=AcS3NOQnsQM

And when Jim Lovell passed, Dermot O’Leary played a piece by the band Public Service Broadcasting, called “The Other Side”, which is so unusual that I had to stop and listen to it completely. (I didn’t know that Mike was having the same reaction to the piece while listening in his car). It was a reminder of the sheer bravery of the astronauts, and the ingenuity of the team who put them in space.

Fancy a quick quiz? Tracey Hemingway-Wright at Hibiscus has one on Dangerous Goods TLAs (three letter acroynms): https://hibiscus-plc.co.uk/dgr-tlas-how-many-do-you-know/

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 September or early October.

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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