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Chemicals Coffee Time Monthly, June 2024

Posted06/08/2024
Updated06/08/2024
Byghsclassif1stg

Dear Reader,

I hope this newsletter finds you safe and well. June has been a strange month here in the UK, with many normal political events suspended due to the General Election.

Leaving politics on one side, BADGP is running the UK’s first ever Dangerous Goods Awareness Day on Thursday 11th July. They have produced a series of posters for Toolbox Talks for industry to use, which you can find here (I’m sure they will be useful for anyone handling Dangerous Goods, not just here in the UK): https://dgawarenessday.com/

Hearing from the HSE, DEFRA and the UK

A Labour victory – but what about chemical regulations?

We have just heard the news that Labour is now in power in the UK. It will be interesting to see whether they make any moves to re-join the EU, as this would affect UK chemical regulations significantly.

My colleague Alison Potts points out that, even if the UK wanted to re-join the EU, UK regulations have now diverged so much that we would not be considered ready for Accession. Being older and more cynical, I think that “where there’s a (political) will, there’s a way”, and if the EU thought it was in their interests to readmit the UK, it would be pushed through quickly.

And if re-accession is not possible, it will still be interesting to see whether the Starmer government alters the current approach of reviewing every EU decision, or whether there is a move to a Switzerland-style recognition of most EU chemical regulations.

It’s basically more uncertainty and yet another “watch this space” moment!

UK-REACH consultation is extended

The REACH ATRm consultation has been extended until 25th July 2024. Thanks to the Chemical Business Association for spotting and sharing this news. You can find the consultation here: https://consult.defra.gov.uk/reach-policy/atrm-consultation/ .

Mandatory Classification List update

Good news from the HSE. You may remember the “oops moment” a few months ago when some bright spark reading the regulatory small print discovered that the Harmonised Classifications in the 14th and 15th ATP hadn’t been brought into UK law?

This mistake has now been resolved by the Secretary of State signing them into law as official Mandatory Classifications here in GB.

The full up to date list can be downloaded here: https://www.hse.gov.uk/chemical-classification/classification/harmonised-classification-self-classification.htm

In practical terms, everyone was using these anyway, but it’s good to get it confirmed officially.

Don’t forget that there are now significant differences between the EU Harmonised Classifications (https://echa.europa.eu/information-on-chemicals/annex-vi-to-clp) and the GB Mandatory Classifications, so you need to check both lists if classifying for GB and the EU/NI.

MCL Technical Reports updated

During June, the HSE added a further 7 more Agency Mandatory Classification opinions . These are:

  • 2,3-epoxypropyl o-tolyl ether, 2210-79-9
  • 2-methyl-2H-isothiazol-3-one hydrochloride; 2-methyl-2,3- dihydro-1,2- thiazol-3-one hydrochloride, 26172-54-3
  • Methyl oct-2-ynoate, 111-12-6
  • Dinotefuran (ISO); 1-methyl-2-nitro-3-(tetrahydro-3-furylmethyl)guanidine, 165252-70-0
  • Proquinazid (ISO); 6-iodo-2-propoxy-3-propylquinazolin-4(3H)-one, 189278-12-4
  • 3-iodo-2-propynyl butylcarbamate; 3-iodoprop-2-yn-1-yl butylcarbamate, 55406-53-6
  • Captan (ISO);1,2,3,6-tetrahydro-N- (trichloromethylthio)phthalimide, 133-06-2

Regular readers will be aware that the GB-MCL process requires sign-off by the Secretary of State, see https://www.hse.gov.uk/chemical-classification/gb-mcl-list.htm, and given that we will have a new Secretary of State very soon, it’s unlikely that these will be adopted officially any time soon.

Keeping an Eye on ECHA and the EU

Distance and online selling under EU-CLP

More details from the CLP legislative act keep coming to light. This week’s “fascinating fact”, or perhaps that should be “something to worry about”, are the changes to distance selling rules.

ECHA’s current guidance, given in Q&A 273 at https://echa.europa.eu/support/qas states that:

CLP requires that where a member of the general public can purchase a mixture without first seeing the label, and where that mixture is classified as hazardous or contains a hazardous substance as referred to in CLP Article 25(6), then the advertisement for that mixture must mention the type or types of hazard as indicated on the label.

The type of hazard is best specified by providing the relevant hazard statements, including the supplemental hazard statements as referred to in CLP Article 25(6). It is also recommended that the hazard pictograms and signal word are mentioned, where appropriate, to alert the reader to a potential hazard.

For sales to the general public, it is not sufficient nor relevant to refer to a safety data sheet containing this information.

And don’t forget that Q&A 1235 confirms that internet sales and webshops constitute an advertisement.

Note that these Q&As are still relevant for GB, as the HSE Helpdesk refer to them.

However, the new CLP Legislative Act alters Article 48 which now states that the information in Article 17 should be made available – and Article 17 includes ALL of the label information.

In other words, you need to have a photograph of the label or all of the label information available to the potential buyer before they commit to purchasing your product.

Of course, this new requirement will have a phase-in period; and technically won’t apply to GB – but it will apply to NI and the EU, and if your website allows people to purchase or order CLP-liable products, it would be sensible to ensure you are compliant with the EU rules as well.

EU-SVHC news

Regular correspondent Phil Rowley has been in touch with more news:

ECHA reports that it has received an intention to propose the substance below as an SVHC / ‘candidate list’ substance :- O,O,O-triphenyl phosphorothioate, CAS no 597-82-0, EC no 209-909-9. The file in the Registry of SVHC intentions is here: https://echa.europa.eu/registry-of-svhc-intentions/-/dislist/details/0b0236e18a4bb583 , closing date 1st August 2024 . The reason for SVHC status being proposed is that it is PBT (Persistent, Bioaccumulative, Toxic). Phil notes “Of course, this won’t directly affect the UK, but if you use the substance it would be wise to keep an eye on developments”.

Many thanks to Phil, and as a side note, this substance been on the CoRAP list since 2016 https://echa.europa.eu/information-on-chemicals/evaluation/community-rolling-action-plan/corap-table/-/dislist/details/0b0236e1807ed8ae .

And a couple of weeks later, Phil added: ECHA have just added a single SVHC to their Candidate List, https://echa.europa.eu/-/echa-adds-one-hazardous-chemical-to-the-candidate-list .

This is Bis(α,α-dimethylbenzyl) peroxide, EC no 201-279-3, CAS no 80-43-3.

They have also added 2 new intentions to the SVHC list:

New intentions have been received for:

  • tris(4-nonylphenyl, branched) phosphite (EC 701-028-2, CAS -); and
  • 6-[(C10-C13)-alkyl-(branched, unsaturated)-2,5-dioxopyrrolidin-1-yl]hexanoic acid (EC 701-118-1, CAS 2156592-54-8).

Many thanks to Phil for keeping us all up to date.

Note that the UK has not introduced any new SVHCs since Brexit, apart from a couple of ones which had been agreed prior to Exit Day (hat-tip to Peter Douben of REACH Wise for reminding us of this).

Around the World

Australia (AICIS)

Readers may be aware that the Australian Industrial Chemical Rules (which include Classification, SDS and Labelling requirements) were updated last year.

Regulators ran a post-implementation feedback programme to identify any issues with the new legislation and have recently published some minor updates and guidance based on that feedback.

You can read more about those changes (which are in effect) here: https://www.industrialchemicals.gov.au/response-feedback-proposed-changes-aicis-categorisation-reporting-record-keeping-requirements

Switzerland

It is often assumed that Switzerland subscribes to EU CLP and EU REACH. The reality is a little more complicated, they actually transpose the EU regulations into their own Swiss Regulatory Framework (the ChemA and ChemO) with occasional changes. This results in an implementation delay.

Switzerland have just announced the revision of Annex 2 of the ChemO to include the 21st ATP, the amendment to include the new EU hazard classes as per the CLP delegated act, and the inclusion of 7 new SVHCs into their Appendix 3 Candidate List.

These changes are expected to be adopted on August 2 2024. (https://eping.wto.org/en/Search/Index?viewData=%20G/TBT/N/CHE/287)

Egypt

Egyptian Standard (ES) 6910/2024 – Labelling of Detergents and Cleaning Products, has come into force. It replaces the previous standard (ES) 692/2015.

Annoyingly, Egypt is a country that wants you to pay for a copy of the regulation (https://www.eos.org.eg/ar/standard/9442) but I can tell you that the Egyptian regulator believes that the standard is equivalent to the EU Detergent Regulation (648/2004) and includes the EU Ecolabel criteria (EU 2017/1218). I am unable to verify that for you.

Chemical snippets

Infographic of the Month

A wonderful infographic on the power of a good question (created by Tanmay Vora) https://www.linkedin.com/posts/catherine-mcdonald-b6157210a_powerfulquestions-leaderascoach-leadershipdevelopment-activity-7208021486962393088-EezR .

This particularly resonates with me, as questions are the foundation of the Chemical Regulations Self Help Group, in fact one of our sayings is “there’s no such thing as a silly question”: https://www.chemselfhelp.co.uk/ .

The Weekend Read

Two excellent reads this month on chemophobia and how to combat it:

The Weekend Recipe

It has been so chilly recently that I ended up making an apple crumble, and realised that it would be a good recipe to let you have again. Of course, this should mean that we get a spell of very warm weather instead :)!

Apple crumble

Core and peel some apples, this can be dessert ones like Cox’s Orange Pippin, or cooking apples, or even a mix of the two. You will want to add some sugar to sweeten the fruit (yes, even if you’re using dessert apples). Top tip – if you gently stew the apples for a few minutes, you’ll be able to taste the mixture and adjust the sugar to your liking. If you are using cinnamon (and why not, in an apple-only crumble?), add a sprinkle at this stage and don’t overdo it.

Basic crumble recipe: 3,2,1 (by weight) ; 3 parts flour, 2 parts white sugar, 1 part butter. One of the few recipes I have from my Mother, I suspect another wartime economy one. If you want a slightly richer mix, try 3,2,2 so you double the weight of butter. Other people use 2,1,1.

Method: Weigh the flour and sugar into a large bowl, and stir together (I use my trusty balloon whisk for this). Cut the cold butter into chunks (or even grate it into the flour and sugar) and “rub in”, that is reduce the butter pieces by either rubbing between your thumb and forefingers on both hands, or rubbing between the palms of your hands. When the mixture is like fine breadcrumbs, you’re done.

Then assemble your crumble. Take a favourite dish, and fill it with fruit to leave room for the crumble to come up to the top of the dish. There is some debate in our house about the perfect ratio of crumble to fruit. I was brought up to think that you need a fairly deep layer of fruit, with enough crumble to cover the fruit fully (about a half-inch to an inch depth). Mike is firmly of the opinion that it should be 50:50 fruit to crumble, so that’s what we do. No doubt your family will have their own preference!

Bake in a moderate oven, Gas mark 3 or 4 for around half to 3/4 of an hour, until the crumble is cooked through and the fruit is bubbling and hot (depending on the size of container, and whether you want your crumble brown or just golden etc). If you want a recipe with proper quantities and timings, this one is good: https://www.bbcgoodfood.com/user/896076/recipe/quick-crumble-mix.

Serve hot with cream, or custard, or ice cream.

More tips – you can make crumble with most fruits, or a mix of fruits. Stone fruits (plums etc) or apples or pears are traditional – using soft fruits alone, like brambles or raspberries tends to make a puree which doesn’t hold the crumble weight very well, and it sinks. It’s better to have some of the firmer fruits with them. If you are using apples, you could use brown or white sugar, as they have a more robust flavour, but if you’re using more delicately flavoured fruit, then white sugar is essential to avoid overpowering it.

Reasons to be Cheerful

I’m still in a Monty Python mood, so here goes:

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, or even our weekly email one : https://chemicalscoffeetime.co.uk/. (This new 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

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