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Chemicals Coffee Time Monthly, February 2026

Posted
Updated
ByEmma

Dear Reader,

February may be the shortest month of the year, but it was pretty busy on the regulatory front in both the UK and EU. There was a lot of fuss about PFAS, so we’ll concentrate on that first.

PFAS news

DEFRA PFAS action plan for the UK

On Tuesday 3rd February, DEFRA published a new PFAS action pan, see https://www.gov.uk/government/publications/pfas-plan/pfas-plan-building-a-safer-future-together .

Steven Brennan of Foresight has compiled an excellent summary of the DEFRA report here: https://www.linkedin.com/posts/dr-steven-brennan_pfas-plan-building-a-safer-future-together-activity-7424385600356679680-vzNe, which I urge you to read in full.

H If you are not already a subscriber to Steven’s weekly newsletter, you can sign up here: https://www.useforesight.io/newsletter

Proposed PFAS EQSs

ICYMI (or in case we didn’t report it), DEFRA are proposing nanogram level Environmental Quality Standards here; https://www.gov.uk/government/publications/developing-thresholds-for-managing-pfas-in-the-water-environment/developing-thresholds-for-managing-pfas-in-the-water-environment-summary

  • 0.4 ng/L for PFOA
  • 0.2 ng/L for PFHxS
  • 0.3 ng/L for PFNA
  • 0.015 ng/L for PFOS

These figures are generally below the reporting threshold for lab tests! Interesting times.

PFAS in fire-fighting foam

Reminder – even if you don’t use PFAS in your products, they may still be present in your fire fighting materials. If you have any stocks of AR-AFFF (alcohol resistant aqueous film forming foam) on site, please check to make sure they are still legal to use.

These two new pieces of legislation are:

  • The Persistent Organic Pollutants (Amendment) Regulations 2025 (UK SI 2025/296)
  • The Persistent Organic Pollutants (Amendment) (No. 2) Regulations 2025 (UK SI 2025/297)

There is a good summary of the changes here: https://www.sgs.com/en/news/2025/04/safeguards-05125-uk-amends-legislation-on-pop-chemicals-for-great-britain (and don’t forget that DEFRA are committed to bringing in more PFAS POPs which may also be present in fire fighting foam).

You don’t want to find yourself in a situation where the fire fighting foam is used, but you accidentally end up causing PFAS pollution. I hear on the grapevine that at least one site which had an accidental release of firewater contaminated with foam is to be prosecuted because of the POPs content.

The limits on fire fighting foam which were introduced last year are:

  • In fire-fighting foam mixtures— (a) sum of the concentrations of PFOA and its salts: 0.025 mg/kg; (b) sum of the concentrations of PFOA-related compounds: 1 mg/kg. (There may be other relevant limits for your products or ancillary chemicals, please read the full legislation yourself to check).

Please check your stocks of fire-fighting foam if you have not already done so, and if you work for or are a member of a trade body, please ask them to circulate an urgent reminder.

AFFF foam SDS update

A reminder from Tony McLaughlin that SDSs for AFFF foam should be updated with new disposal information, see https://www.linkedin.com/posts/tony-mclaughlin-a2a948183_the-safety-data-sheets-sds-for-afff-foam-activity-7432399254058418176-Hk4e

Alternatives to PFAS for AR-AFFF

There is some guidance on alternatives here: https://firechiefglobal.com/what-are-the-alternatives-to-pfas-foam/ and if you have any information on specific brands which you’d like to share with other readers, then please do let me know.

Where might PFAS be hiding in your business?

As well as fire fighting foam, our friends at HIBISCUS PLC – Chemical Labels | SDS Software | DGSA Training have produced an infographic and explainer here: https://hibiscus-plc.co.uk/what-businesses-should-be-preparing-for-with-the-pfas-regulatory-update/

PFAS destruction methods

The UK government carried out an investigation into PFAS destruction methods last year, seehttps://www.gov.uk/government/publications/rapid-evidence-assessment-of-pfas-incineration-and-alternative-remediation-methods

It seems that the Veolia facilities in Ellesmere Port are currently able to do full PFAS destruction according to the requirements in the document, see https://www.veolia.co.uk/services/waste-management/hazardous-waste-treatment/pfas-hub. Tradebe’s Fawley incinerator is also able to meet these standards: https://www.tradebe.com/environmental-services/markets/uk/ .

Hearing from the HSE, DEFRA and the UK

GB-CLP changes presented to Parliament

Nicola Kaye of BASF writes on LinkedIn:

The draft amendment to GB CLP, GB BPR and GB PIC has been laid before parliament. Whilst it is not yet law, if approved GB CLP will be amended to delete the GB notification database, and replacing articles 37 and 37A with a new process to speed up adoption of new Mandatory Classification and Labelling, allowing a “fast track” process for substances classified by other jurisdictions, for example the EU. GB BPR will be amended to delay active substance renewal dates until 31 July 2031 for a number of substances, as well as amendments to data protection periods and article 55 derogations.

https://www.legislation.gov.uk/ukdsi/2026/9780348279672/contents

Many thanks to Nicola for sharing this with us. Remember that this is a draft regulation and may be altered before its final publication.

Our friends at Steptoe LLP have spotted something interesting about this draft, and discuss it in an article for the ENDS Report, which they have linked to from this article here: https://www.steptoe.com/en/news-publications/ends-report-quotes-steptoe-attorneys-on-health-and-safety-executives-hses-chemicals-reform-plans.html (the report itself is behind an email wall).

You may remember the furore about the proposals to use information from other jurisdictions for hazard classification etc, with some people claiming that it was going to lower standards? It always looked like the intention was to track the EU more closely, and the link above states:

“The piece highlights HSE’s plan to use the EU as the only trusted jurisdiction for recognition of foreign approvals and signals that some changes will require a future chemicals bill.”

Many thanks to the Steptoe team for this important insight, and Mick Wragg for spotting it.

Response of HSE to chemical regulations consultation

The HSE Chemicals Legislative Reform Consultation Response was published in February and prompted some discussion among our readers.

Briefly their suggestions are (my notes in brackets):

  • make the Mandatory Classification List more smooth (good idea in theory, let’s see how it works in practice)
  • give up on the idea of a UK Classification and Labelling database (we’ve never had it published, it generally duplicates ECHA’s information, and even at ECHA, the notified C&L entries are of limited value anyway due to errors and the inability to view the notifying company, although ECHA will publish this information at some stage)
  • move Technical Notes from legislation to the HSE website (this is what already happens with the Mandatory Classification List, the Restriction List etc for GB, and it is efficient – should be an improvement)
  • ability to amend CLP via secondary legislation (this will depend on what is being amended and whether industry can comment, in theory makes life easier for the regulators, but don’t forget the people who are regulated)

Keeping an Eye on ECHA and the EU

Proposed updates to Annex XVII of EU-REACH

Mick Wragg writes

I have come across a proposed amendment to REACH Annex XVII Restriction concerning Entries 28-30, which relate to the sale of products containing CMRs to general public (two documents below).

In particular I note that the proposal introduces a need to consider additivity when determining whether a product containing two or more CMRs could be sold to the general public.

There was some discussion in the newsletter about when additivity might be applicable, and this is a developing issue.

EU-REACH test methods regulation update is here

ICYMI – as discussed back in September 2025, the REACH test methods regulation was finally published in early January, see https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02008R0440-20260108.

Unfortunately it only seems to be currently available in html (webpage) format, but I hope that a pdf version in each EU language will be produced soon.

Ethanol approved for EU Biocide use

Steve Marks of Airedale Chemicals writes – you’ve probably spotted this or been sent it already….. https://echa.europa.eu/-/echa-s-biocides-committee-supports-approval-of-ethanol-in-disinfectants

Interesting that the “Committee did not take a position on whether ethanol should be considered a carcinogenic or reprotoxic substance.”

In fact, the quote continues – “As a result, no new hazard classification has been proposed. (my bold)

According to the BPC, the following factors prevented a clear hazard conclusion:

  • The applicant’s dossier, although considered complete, lacks data on dermal exposure, a key route of exposure for biocidal products. The available inhalation data has not been performed in accordance with the standard guidelines.
  • Most of the evidence relating to the carcinogenic and reproductive properties of ethanol is from voluntary oral consumption of alcoholic beverages, which the Committee did not consider an appropriate basis for decisions in the context of these biocidal uses.
  • New studies on more relevant exposure routes are underway, and the BPC believes these must be considered before determining carcinogenic or reprotoxic properties. However, waiting for these studies to become available could significantly delay the approval process.”

There are several interesting points in how this is being handled – firstly it seems BPC have listened to industry when we complained that using voluntary oral consumption was not a sound basis for classification; secondly that the dossier itself was lacking dermal toxicity data and appropriate inhalation data, so more tests have been required; and thirdly that the BPC did not want to allow the ethanol approval to laps, obviously they recognise its important as a biocide.

I think we should probably treat this as an interim approval, pending more test data – but it’s still very good news.

Chemical snippets

Process Safety Corner

Recent incidents

Insights

Events

ChemUK 2026

Visitor registration for ChemUK 2026 is now open! You can sign up for a free ticket here:https://register.visitcloud.com/survey/10m32vv2wydrd.

I’m particularly looking forward to the REACH panel discussions on Day 1, jointly chaired by Elaine McGavin and Neil Hollis, see https://www.linkedin.com/posts/chemuk2026-ukreach-chemicalregulation-share-7427666708787798016-ZY43.

And, of course, the Chemical Regulations Self Help Group will be on Stand H160!

Infographic of the Month

It was quite chilly, in February, so we shared this infographic on the chemistry of deicers and antifreeze https://cen.acs.org/articles/93/i2/Periodic-Graphics-Deicers-Antifreeze.html

The Weekend Watch/ Read

An important article from the HSE on commissioning your LEV system correctly. https://www.hse.gov.uk/lev/commissioning.htm. This also has useful links to guidance on LEVs.

At least two of our clients have found that it is possible for an LEV to be so efficient that it actually removes product from the surface of a liquid. This can be due to quite subtle, e.g. when the manway is open for a short time, or there is a seemingly small and insignificant leak somewhere, so watch out for changes to product quality/ amounts of raw material used, as it can be leaving through the LEV.

This is a triple whammy in terms of costs, as you are paying for raw material you don’t use, loss of production time, and you may also be paying to dispose of the wastes collected in a filter or scrubber.

The Weekend Recipe

As Valentine’s Day falls in February, I thought a nice chocolate cake would be a good recipe to give you, either to share with your loved one, or if you just need a bit of cheering up. (Cake freezes very well, so you don’t need to eat it all at once!).

And, as a traditional home baker, I am very fond of the BeRo recipes, so I was thrilled to come across a Milk Chocolate Cake recipe recently which was a new one I’d not come across before. It’s particularly tempting, as I’ve not been able to eat milk chocolate because of this lactose intolerance, and dark chocolate can be quite bitter.

Although the recipe does include evaporated milk, Mike was able to make some lactose-free evaporated milk for me using this recipe, https://www.biggerbolderbaking.com/evaporated-milk-recipe/, simply using homogenised lactose free milk as the starting point. However, it did take him about 45 minutes to do, and you need to stir most or all of the time, so it’s not for the faint-hearted. (There’s also a home made condensed milk recipe from the same site: https://www.biggerbolderbaking.com/how-to-make-condensed-milk/).

Cake Ingredients

  • 7 ounces (200g) self raising flour
  • 7 ounces (200g) caster sugar
  • 1/4 teaspoon salt
  • 2 ounces (50g) cocoa powder
  • 4 ounces (115g) soft margarine or 4 ounces (115g) softened butter
  • 2 eggs, beaten with
  • 5 tablespoons evaporated milk
  • 5 additional tablespoons evaporated milk mixed with 1 teaspoon vanilla extract

Icing ingredients

  • 3 ounces (80g) butter
  • 4 tablespoons cocoa powder
  • 8 ounces (225g) sieved icing sugar
  • 3 tablespoons hot evaporated milk or 3 tablespoons hot full-fat milk
  • 1 teaspoon vanilla extract

Cake method

Set your oven to Gas Mark 4 (180C/350F) and grease and line the base of a 6 inch or 7 inch cake tin with a solid base (the original recipe firmly states not to use a loose-bottomed tin, otherwise the mixture may run out, which sounds like the voice of experience). (In theory, you could make this in two sandwich tins, but you’d need to add more liquid to make a looser batter).

Sieve the flour, sugar, salt and cocoa together into a large bowl (use a balloon whisk to distribute the cocoa evenly). Rub in the margarine or butter. Stir the beaten eggs and evaporated milk mixture into the dry goods, then add the additional evaporated milk with the vanilla extract. Beat well until light and fluffy and well mixed.

Then pour carefully into the pre-prepared tin, and bake in the pre-heated oven for 25 to 35 minutes, or “until well risen” (use the toothpick/ skewer test to make sure it’s cooked through). Allow to cool slightly before turning the cake out onto a wire rack and allow to cool completely before icing and decorating the cake.

Icing method

Melt the butter and blend in the cocoa powder, sieved icing sugar, hot milk and vanilla extract. Beat until smooth and thick. Split the cake in two, and put icing on top of both layers before sandwiching them back together again.

Findings – you do need to mix the cake batter well to make sure all of the cocoa powder has been absorbed. The cake top came out nice and glossy, and keep your cake fairly high in the oven (it took longer to bake as I had it too low to start with). The flavour of the cake and icing was very more-ish, not as dark as dark chocolate but still a nice strong chocolatey taste. Definitely worth trying this recipe.

Reasons to be Cheerful

In February the funny videos were from the Scottish sitcom “Still Game”, about pensioners growing old disgracefully:

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 March or early April.

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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