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Chemicals Coffee Time, 16th February 2024

Dear Friend,

Happy Friday! We’re now in Lent, and I hope you managed to have pancakes on Tuesday, keeping the tradition going. We had actually run out of eggs, see the Weekend Recipe below, so missed out on the date itself.

Mike and I were surprised and saddened to hear that Steve Wright of Radio 2 had passed away unexpectedly on Monday at the relatively young age of 69. His BBC shows were the soundtrack to many people’s lives, ours included, and there is a lovely appreciation of him by Paul Gambaccini here: .

In some ways, for our generation, it’s another “day the music died” . “And I knew if I had my chance, that I could make those people dance, and maybe they’d be happy for a while“. You certainly made many people happy, Steve. May you rest in peace, and rise in glory.

Breaking news – ECHA website is down all this weekend, see

“Due to maintenance activities, our websites and most of the IT tools will be unavailable from Friday 16 February 2024 starting at 17:00 (3pm UK time) to Monday 19 February 2024 until 09:00 (7am UK time).”

Hearing from the HSE and the UK

Biocides news

Another week, another withdrawn biocide from the UK marketplace… this time it’s Acrylaldehyde (Acrolein) (CAS 107-02-8 EC 203-453-4) in product type 12, slimicides. However, the HSE are still accepting information on this product/use combination.

More details here:

UK Chemical Industry challenges

The latest Chemical Industries Association business survey of UK chemical companies highlights three main challenges: weakening demand, labour cost increases and skill shortages, see .

Of course, skill shortages are likely to lead to higher wages, with skilled people becoming more in demand, so you could consider them to be a single problem. Energy costs were highlighted as another issue, and I was surprised that supply chain problems weren’t on this list as well.

The good news is that there is a general feeling within the survey group that “the worst is over” for the current difficult trading conditions.

UK-REACH reports

The HSE has just published the UK-REACH report for 2022-23 and the Work Programme for 2023- 24, see .

Keeping an Eye on ECHA and the EU

Hexyl salicylate update – James Dawick of Innospec writes: Just a quick reaction to the (UK’s) hexyl salicylate proposal as skin sensitiser cat 1 and repro cat 2, the SCCS issued a draft safety opinion on use of the substance in cosmetics in Nov last year:

Many thanks to James for the update.

EU CLP Legislative act delay – some unexpected consequences

I recently learned (hat tip to Ali!) that there are two important EU items which are dependent on the CLP Legislative Act being passed.

Firstly, she thinks that the EU’s Classification and Labelling Inventory transfer onto the new ECHA Chem website will need to wait until the Legislative Act has gone through.

Secondly, the EU’s Safety Data Sheet in Annex II of REACH will need to be updated. This is because although Endocrine Disruptors are written into the EU-SDS, this references them when they were part of REACH, and when they move into CLP the references will have to change. Ali thinks that as Annex II was updated recently, the EU may be reluctant to change it this year. Headache tablets, anyone?

When might the CLP Legislative Act get voted through?

In order for the CLP Legislative Act to come into effect, it needs to be:

  • passed by vote in the European Parliament
  • published officially in the EUR-Lex journal

Ali notes that there are only 12 working days left for the European Parliament to discuss Environment Committee items, and the CLP Act is just 1 out of 7 pieces of legislation which are supposed to be passed.

They’ve already missed the week of the 5th February, so it will either be the week of the 26th February or the week commencing 11th of March. If it hasn’t passed by then, they’ve got one more shot at it, which is week of the 22nd of April. Otherwise they have missed this legislative term because then it’s the elections.

Biocides and Bees guidance published by ECHA

Hat tip to Nick Keeble, who spotted this guidance and has issued an overview here:

Latin America update

The ever-reliable Melissa Owen has recently produced a series of updates on some important changes if you’re selling into this region, including:

If you’re interested in Latin American chemical regulations, then I strongly recommend you follow Melissa on LinkedIn at .

Farewell to Bodyshop?

The well-known retailer The Body Shop, purveyor of cosmetics to British teenagers since the late 1970s, has gone into administration, see .

While the loss of any business is very sad, particularly when so many jobs are at stake, I cannot say that I am shedding any tears for the Roddick family, who received a reported £130 million when the chain was sold to L’Oreal in 2006 for a reported £652 million

I remember reading a quote from Gordon Roddick around that time, perhaps a year or two later (it may have been after Dame Anita Roddick’s death) to the effect that the sale to L’Oreal had always been part of their plan. It sounded cynical at the time, and unfortunately I haven’t been able to track it down (this was before the internet was as all-consuming as it is now).

But you can see from the Guardian article above that they had already sold a large stake in the business, as at least one early investor pocketed £140m, indicating that the investors held more shares than the Roddicks themselves.

Does this mean that their marketing campaigns around animal testing were all part of that plan too? Just a means of differentiating themselves to grow their business to a point where a larger company would take them over?

The impact of The Body Shop’s stance has certainly had a positive effect in encouraging a reduction in animal testing and the adoption of new non-animal test methods (which everyone in the chemical industry welcomes, as nobody likes to see un-necessary animal testing). It could also be argued that without the money from The Body Shop, Gordon Roddick would not have been able to bankroll The Big Issue in its early days

However, it is impossible to ignore the negative effects. The promotion of the idea that all tests on animals are inherently wrong or bad has led to unwarranted tension between the cosmetics industry and the chemical industry over animal tests, for example with Cosmetics bodies trying to claim that ingredients which are only used for cosmetics should be exempt from normal REACH tests required on chemicals with other uses.

(This stance seems positively bonkers to me – if you are deliberately putting chemical products on your body for years, surely the same tests should be required as for other chemicals with less human exposure, as a minimum, and there is an argument that cosmetics ingredients should actually be tested more thoroughly than other chemicals).

The fall-out from this split between cosmetics and the rest of the chemical industry has, in my view, included unfair bad publicity for the chemical industry as a whole over tests which are still mandatory as a way to protect the end users of chemicals, and this type of bad publicity tends to feed public “chemophobia”.

There is also the damage caused by fanatics on the fringes of the animal rights movement, who were greatly encouraged by The Body Shop’s publicity. These people not only threatened and acted out violence against the animal testing houses, they also protested and threatened chemical companies who were legally obliged to test their substances on animals. (I myself was on the receiving end of a protest in 2005, at a client site, and I experienced how scary it is).

This threat of violence caused the chemical industry to increase security long-term, and I think, caused people working in the chemical industry to withdraw from public debate around animal testing for fear of becoming targets. This in turn meant that there were fewer voices to speak up against the “chemophobia” ideas, and in favour of responsible chemical use.

If only The Body Shop’s marketing had been a bit more nuanced than their marketing phrase “against animal testing” back in 1980s. After all, if my memory is correct, they themselves had been prevented from using their original slogan “not tested on animals”, as at the time all cosmetics ingredients had to have been tested on animals, and many companies also tested their cosmetics formulations to ensure that the consumer was protected from any “unknowns” which might arise.

The Body Shop did not test their cosmetics formulations on animals, but had to follow the same rules as everyone else by using approved ingredients which had been tested on animals, under laws dating back to the 1960s, and, in my view even the phrase “against animal testing” while strictly truthful (as it describes their opinion on animal testing), is disingenuous, as they had to use animal-tested ingredients just like every other cosmetics company.

I can’t help thinking that if The Body Shop had marketed their products slightly more clearly, and explained to their customers that although they were against the animal testing of cosmetics products as a whole, all cosmetics ingredients had to be tested on animals by law, then much of this unpleasantness could have been avoided.

Now that really would have been Corporate Social Responsibility in action!

Chemical snippets

Process safety corner

Historic incidents:

The latest Trish and Traci podcast is out now, this time on the topic of inherently safe design: (this has a transcript to scan if you don’t have time to listen to the podcast itself)

I thought you might like a definition from Sean Moran’s Dictionary of Chemical Engineering Practice: Write only documents aka WOD, write only documentation: Documents which must be written and filed somewhere for some reason (usually to do with paying lip service to something), but are never actually read. (You can buy the book here (not an affiliate link:

Jobs update (UK stats from LinkedIn)

Regulatory Affairs, 3,323 jobs; Health and Safety, 2,788 jobs.

If you are looking for a job at the moment, remember these things:

  • there is plenty of work available
  • you are interviewing a potential employer as much as they are interviewing you
  • if you’re between “proper” jobs, then there’s no shame in taking a lower paid job while you’re searching, or volunteering somewhere to get you out of the house
  • you’re playing a percentage game – out of x applications, you may get 1 interview; out of y interviews you may get 1 job offer etc. Every application you make is a step towards your goal, even if you don’t get an interview from it. Every interview is a win, even if you don’t get a job offer. That will come through sooner or later.
  • And finally, remember Churchill’s advice – never give up.

Good luck if you are job-hunting.

Infographic of the week

A breathing zone infographic, and a very interesting comment about right/left handedness and breathing zones, which I was previously unaware of:

The Weekend Read

Dr Carol Treasure of XCellR8 asks an important question – Am I the only female scientist who finds the whole “International Day of Women and Girls in Science” deeply patronising? read her opinion here

(#spoileralert, I agree with her 100% – you can either have excellence, or you can have quotas, and science is all about the search for truth and excellence).

The Weekend Recipe

One of the problems with having been away for a while is that a backlog of perishable foods can build up, e.g. milk (which Mike solves by making rice pudding to store in the freezer), and also eggs. Apart from making cakes to freeze, or freezer omelettes, it crossed my mind that I could use some up by making lemon curd.

Lemon Curd

  • 2 lemons (rind and juice both needed)
  • 3 medium eggs
  • 2 oz butter or margarine
  • 8 oz granulated sugar

If you are making this to eat or use in a cake filling, you may not need to prep your jam jars, but if you are going to keep this, then sterilise a couple of jam jars before you start making the curd. And don’t forget to sterilise your jam funnel (if you have one) – I’m forever forgetting to do that. Jam funnels are wide-necked and shallow, not unlike some powder funnels from the lab. You can find instructions on sterilising jars in the oven here, and in the microwave here (note that I have never tried this method – use at your own risk!).

Anyway, having prepped any jars you want to use, it’s time to make the lemon curd. You need a pan with either a glass bowl or another pan which sits inside it nicely without touching the base – a good couple of inches “free depth” is about right.

Into your cooking vessel, whether glass or a metal pan, grate the rind from your lemons, then squeeze the juice and add it to the vessel. Next weigh in 2 oz butter (or margarine, if using). Crack the eggs into a small bowl, and whisk thoroughly, and set aside. Weigh out 8 oz of sugar and set aside as well.

Take the (lower) pan and fill with about an inch of boiling water, and set on the heat. Place your cooking vessel on tap, making sure that the base doesn’t touch the boiling water below. Allow the butter to melt, then add the well-beaten eggs and the sugar, and stir until all the sugar is melted (you can feel any crystals with your spoon).

Cook slowly over the boiling water, stirring regularly (or all the time, if you’re nervous), until nicely thickened. (Important – keep the boiling water topped up from your kettle, don’t allow the pan to boil try). The mixture tends to become a little more pale as it thickens and the egg cooks slowly. You can test for “done-ness”, by dropping some onto a cold plate, allowing to cool, and observing the texture. You don’t want runny lemon curd!

When its the correct texture for your tastes, pour into the sterilised jars and allow to cool. Don’t forget to use your spatula to get the residue out of the cooking vessel! Cook’s perk – wipe out the last bit of lemon curd goodness with a slice of bread! I tend to store home made lemon curd in the fridge, and this is essential after the jar has been opened.

Findings – if you use double quantities, this recipe may take quite some time (eg an hour) – using single quantities is a lot faster. You can use an extra egg yolk to help the curd thicken more, as per this BBC recipe, but the one I’ve given you is more economical. Mary Berry uses more butter in her recipe, which will also help it set faster: , and with hindsight I should probably have used more butter, as my curd is quite a “soft” set.

If you want to make the lemon curd even more special, when you break your eggs, take a few minutes to remove the white “strings” from the yolks, otherwise they cook into little white strings in the curd.

“Free from” notes – you can use margarine for making lemon curd, although I have never done that, but in theory that would make it a dairy-free recipe, which is also gluten free.

Reasons to be Cheerful

The Two Ronnies – Water Pub –



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 Greenwood

TT Environmental Ltd

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