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Chemicals Coffee Time, 24th November 2023

Dear Friend,

Happy Friday! I hope you and your family and friends are safe and well, and you’ve been avoiding this wild weather. It’s been very windy with us for the past couple of days, even though there hasn’t been a named storm – typical late autumn/ early winter weather.

We seem to have been very busy at work in the last few months, and that means sometimes we don’t read everything as closely as we could.

An apology and update on the proposed EU CLP label font size situation

If you are signed up to our monthly LinkedIn newsletter, you will be aware that I sent out a newsflash about the EU-CLP amended label font proposals yesterday afternoon.

Briefly, back in our 29th September issue of Chemicals Coffee Time, we published some information about the minimum font size amendments as being in mm, when in fact they referred to the x-height in mm. That subtle difference between text height and x-height really matters.

I’m very sorry for any confusion, and would like to explain what the difference means. We’ve done some analysis on Helvetica font, at 20 point and at the x-height in mm equivalent (3mm), and discovered that there is only a slight reduction when the x-height is used compared to the point size (approximately 1/7th – but please do your own research).

It does feel like we have had the wool pulled over our eyes, as what seemed to be a significant reduction turns out to be nothing of the sort.

Of course, as I write this, the EU-CLP legislative act is in trilogue, we don’t know yet whether the amended proposals will go through, or the original proposals will end up being brought back in, or some other proposal will be adopted without further parliamentary discussion.

What this all means is that we should have been lobbying the trade associations to sort the mess out from late September onwards.

But there’s still time – please lobby your trade associations to attend the trilogue committee meetings (if possible) and to lobby MEPs who sit on them to, ideally, remove the minimum font sizes altogether.

Otherwise I’m afraid that we’re in for a rough couple of years attempting to cope with labelling restrictions which do nothing for people’s safety, but which cause a great deal of wasted time, effort and expense. The parallels with the minimum pictogram issues we had when CLP was introduced are too strong to ignore, and if you remember, those were resolved in the 2nd ATP to CLP.

You can read the full article on LinkedIn here: https://www.linkedin.com/pulse/newsflash-clp-label-font-size-problems-continue-janet-greenwood-7ml7e/

Many thanks to Tracey Hemingway-Wright of Hibiscus who flagged up this issue on Wednesday, and who has discussed it further with us as we’ve worked through the implications.

Hearing from the HSE and the UK

The HSE sent out an excellent email this week on looking after your metalworking fluids (for people using them) – how to make sure they are in good condition to protect your workers’ health. Usually, I’d just link to the online version of the newsletter, but for some reason there wasn’t a link available, so I’ve pdf’d it and it’s here in case you missed it: HSE ebulletin – metalworking inspections, looking after your metalworking fluid.pdf.

Breaking news – the Ends Report claims that the Environment Agency is going to go through a reorganisation, see https://www.linkedin.com/posts/the-ends-report_breaking-worst-changes-ever-done-environment-activity-7133441455439650816-ugae . They cite a ‘far narrower sector based approach’ to regulation in a major reorganisation of its work. Whether this is accurate or not, how it will work, and whether the other environment agencies in the UK (SEPA, NIEA and Environment Wales) are considering a similar approach remains to be seen.

Keeping an Eye on ECHA and the EU

The European Court have dismissed an appeal this week which sought to claim that “the information requirements of the REACH Regulation only apply to a substance, used exclusively as a cosmetic ingredient, when they do not concern testing to establish effects on human health“. https://www.linkedin.com/posts/hans-ingels-07136658_interesting-judgements-of-the-general-court-activity-7133078774253809664-W6_b?

ECHA have published research on BPR compliance, and found that “18 % of checked products were non-compliant with fundamental requirements that affect their safe use. Most of them either lacked a product authorisation or included non-allowed active substances.”

As you would expect, these products were withdrawn from the market, and in some cases there were prosecutions. A further 19% of products had minor issues, giving a total of 37% non-compliant BPR labels. More details here: https://echa.europa.eu/-/one-in-three-checked-biocidal-products-found-to-be-non-compliant

Understanding the USA

Another three Prop 65 additions from California on 17th November 2023: https://oehha.ca.gov/proposition-65/crnr/chemicals-listed-effective-november-17-2023-known-state-california-cause-cancer :

  • Coal-Tar Pitch,
  • Fluoro-Edenite Fibrous Amphibole, and
  • Silicon Carbide Whiskers

Many thanks to Phil Rowley and Tom Jonaitis for sharing via LinkedIn.

Chemical snippets

Proper re-use and recycling

I don’t know how you feel about disposing of your old IT hardware like servers, laptops and even smartphones, (personally I’m paranoid about loss of data) but there are now specialist companies who will clean your devices, and they can even do it on your site so you can witness it.

I’ve recently come across a company in Cheshire who offer this as a service, and who have a sister company who can then refurbish the laptops etc with new hard drives and re-sell your equipment to new users. As you would expect, the destruction of data storage is carried out to externally validated standards.

This seems like a win/win/win for everyone – people get safe disposal/ cheap refurbished clean devices/ and it saves materials which would otherwise have to be recycled or simply end up in landfill. (It’s also handy to know about reputable refurbished equipment if you don’t mind using second-hand devices!).

The safe disposal company is MBH Global, https://www.mbhglobal.co.uk/about ; and the refurbished equipment seller is Tec-It-Out, https://tec-it-out.co.uk/pages/about-us . I’ve not used either company’s services yet, but thought that it might be of interest to some of our readers.

(Stats for nerds: 1 laptop being recycled prevents the equivalent of 258kg CO2 emissions. Which is the equivalent to a heavy goods vehicle travelling 304km or 16 tons of freighted goods being transported 1000km. MBH Global currently process in excess of 2000 laptops per month).

I’m sure we’re going to see a lot more re-use companies springing up in the future. I’ve been lucky enough to have a traditional milk delivery service, in reusable glass bottles, for most of my adult life, and look forward to the return of lemonade and beer bottles with a deposit!

Process safety corner

The latest Trish and Traci podcast covers the La Mede Refinery tragedy in 1992, where 6 people died, many were injured, and corrosion was a key part in the incident: https://www.chemicalprocessing.com/process-safety-w-trish-traci/article/33015350/la-mede-refinery-tragedy-unveils-critical-corrosion-lessons

A video and good explanation of decomposition of polyethylene in an LDPE plant: https://www.linkedin.com/posts/ugcPost-7132743827974414337-R2j3

And a rather scary video of a cooling tower fire: https://www.linkedin.com/posts/tijs-koerts-0a67636_coolingtower-fireincident-fire-activity-7133390077258289152-pzXE .

An example of a fairly simple Bow Tie diagram on falls from height https://www.linkedin.com/posts/dh04tch_renewables-processsafety-bowties-activity-7133100068491911168-TQqo .

The latest Process Safety Beacon discusses what happens when agitation/ mixing stops unexpectedly: https://www.linkedin.com/posts/engineereck_ccps-safety-beacon-agitator-stopped-ugcPost-7133064453339680768-itNd

Jobs update (UK stats from LinkedIn)

Regulatory affairs: 3,567 jobs; Health and Safety, 2,990 jobs. If you are looking for work, now is an excellent time to apply for jobs to start in the New Year.


The University of Leeds are running their Industrial Air Pollution Monitoring course again in March 2024, enrolment is now open: https://www.linkedin.com/posts/cpd-conference-and-events-unit-university-of-leeds_industrial-air-pollution-monitoring-activity-7132299076707979264-OtSn

Infographic of the week

A somewhat cynical infographic this week about meetings! Infographic on work and meetings from Irina Blok.pdf

The Weekend Read

An excellent post on some essential uses of PFAS https://www.linkedin.com/posts/pascal-michaux-09a8b0_reach-pfas-fluoropolymers-activity-7130977866942406656-VDgb

The Weekend Recipe

If you follow the old Book of Common Prayer for the Church of England, you may have seen that the Collect for this Sunday, the last one before Advent, is “Stir up, we beseech thee, O Lord, the wills of thy faithful people; that they, plenteously bringing forth the fruit of good works, may of thee be plenteously rewarded; through Jesus Christ our Lord. Amen.”

It’s even called “Stir Up Sunday” in some parts, and is traditionally the time to make your Christmas Puddings, ready for Christmas Day itself. The theory is that this maturing gives Christmas pudding flavour time to develop. There is basically a choice – the traditional steaming method (literally taking hours!) – or a microwaveable version. As I’m having a busy time at the moment, guess which one I’ll be using :).

This recipe is from the Microwave Technologies Association, https://www.microwaveassociation.org.uk/recipes/recipe.php?id=105, and I can confirm it actually works.

Important note – you may need to adjust the cooking time depending on the wattage of your microwave. Do the cooking in bursts and check for “done-ness” like you would a cake (ie stab with a skewer or toothpick, which should come out clean when the pudding is cooked).


  • 50g butter
  • 50g plain flour
  • 1 teaspoon mixed spice
  • 75g fresh breadcrumbs (white or brown – but brown is better)
  • 100g soft dark sugar
  • 150g sultanas
  • 75g raisins
  • 50g dates
  • 50g cherries
  • 125g currants
  • 25g coarsely chopped lemon peel
  • 2 eggs
  • 2 tablespoons black treacle
  • 1 tablespoons golden syrup
  • 50ml orange juice or sherry


Important – do NOT put any money or charms in a pudding you’re going to microwave. For that, you need a traditional steamed pudding as per my recipe from 20th November 2020, which you can find in the Chemicals Coffee Time archive at www.ghsclassificationcourses.com (you’ll need to be logged in to access it).

Use metric measures only, and use the exact amounts (otherwise you may get the cooking time wrong). Sieve all the dry ingredients together in a large mixing bowl. Stir well to distribute spices. Stir in remaining ingredients (and remember to have a wish after the first stir)! Lightly grease a half litre (1 pint) pudding basin and fill with the mixture.

Cover with loosely fitting cling wrap. Set in the centre of the microwave oven and cook on medium high (700 watts) for 10 minutes. Leave to stand for 10 minutes after cooking. Sprinkle top with brandy, ignite and serve. This pudding develops a lovely flavour on standing for a couple of weeks.

To heat on Christmas day, turn pudding out of basin and place on an ovenproof plate. Use the basin as a lid and heat through for 2 – 3 minutes on medium high power. Transfer to the table, pour over a little warmed brandy, ignite and enjoy!

Findings – I made this last year about this time, and found that it swelled up a bitn the middle, but it cooked fine. I added a little brandy, like you would with a Christmas cake, and kept it until Christmas Day (wrapped in its baking dish clingfilm in a cool dark place) before reheating for a minute or two on the day itself. You could use whatever dried fruit you like, you’re not forced to use exactly these types of fruit or amounts, although I have noticed that putting some prunes or dates into the mix, cut slightly larger than the raisins, gives a nice texture to the pudding. We missed out the peel, I only had a small lemon so just grated that in, rather than as much as the recipe suggests, and it was absolutely fine.

Reasons to be Cheerful

As we’ve mentioned Christmas, I thought you might like Christmas Day with Doctors Who:


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

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

www.ghsclassificationcourses.com www.chemselfhelp.co.uk

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