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Chemicals Coffee Time Monthly, February 2024

Dear Reader,

I hope this newsletter finds you safe and well, and the days are getting lighter after what seems to have been a very long, dark, wet winter.

Brian Bilston, a humorous modern British poet, sums up January well:

Thirty days hath September, April, June and November.

Unless a leap year is its fate ,February hath twenty-eight.

All the rest hath three days more,

Excepting January,which hath six thousand,one hundred and eighty-four.

It is a Leap Year, so February has been slightly longer than normal, but it still seems to whizz past in comparison to January, and it’s also been busy on the regulatory front.

EU News

Approximate date for EU-CLP Legislative Act vote scheduled

Let’s start with the good-ish news that the EU Parliament’s Environment Committee have finally declared a ‘foreseen date’ (i.e. target) of April 22nd 2024 for the final Parliamentary Vote. The rapporteur will still have to ensure that the paperwork is filed before the deadline and they will have to cross their fingers that there is space in the agenda.

The week commencing April 22nd is the final voting session before the EU elections. We’ll be waiting for the publication of the session agenda (due approximately April 17th) to see if they made it or if the whole thing will be back to the drawing board until autumn.

As we always advise, do not make any changes based on what may be in the Act, wait until the draft legislation is published, as you never know when a sneaky amendment or alteration might come in.

It seems to me that the entire chemical and chemical-using industry in the EU (and UK) is collectively holding its breath about what the new labelling provisions will be.

But it’s not just the contents of the Act which are important. I recently learned (hat tip to my colleague Ali, Alison Potts) 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 REACH Annex II was updated recently, the EU may be reluctant to change it this year.

Headache tablets, anyone?

Advice from CEFIC to EU-REACH registrants on dealing with ECHA’s Assessment of Regulatory Needs documents

As first step in reviewing some chemical substances, ECHA is providing people with Assessment of Regulatory Needs documents. This is often an early warning before requests for further testing (usually expensive animal tests, at that).

Phil Rowley (retired, but open to a little consultancy) writes: this may be of interest although we’re no longer in the EU – the company I worked for has maintained two of its EU REACH registrations via an ‘OR’ – so I’ve just copied this to them for information: https://static.ducc.eu/media/file/2024-01/2024-01-08%20Recommendations%20on%20ARN.pdf . Many thanks to Phil for keeping us up to date with issues and pieces of advice which we might otherwise miss.

ECHA proposes 5 chemicals for Authorisation

Phil has also spotted that the ECHA machine grinds on relentlessly, with a further 5 chemicals being proposed for Authorisation, which are:

  • Melamine;
  • Bis(2-ethylhexyl) tetrabromophthalate covering any of the individual isomers and/or combinations thereof (TBPH);
  • S-(tricyclo[ 2,6]deca-3-en-8(or 9)-yl) O-(isopropyl or isobutyl or 2-ethylhexyl) O-(isopropyl or isobutyl or 2-ethylhexyl) phosphorodithioate;
  • Diphenyl(2,4,6-trimethylbenzoyl)phosphine oxide; and
  • Barium diboron tetraoxide.

Full details here: https://echa.europa.eu/-/echa-consults-on-recommending-five-substances-for-reach-authorisation .

ECHA fees to be altered

Steven Brennan of Compliance and Sustainability Ltd has an interesting article on ECHA’s fees being uprated in line with inflation, although SME fees may not be fully affected: https://www.useforesight.io/news/echa-fees-to-be-updated-in-line-with-inflation

Well, someone’s got to pay for all the work they’re carrying out!

New version of IUCLID6 released

These changes were adopted in mid-February for IUCLID Cloud, but if you’re still on the server version or using it direct on your laptop, you’ll need to run the updates: https://iuclid6.echa.europa.eu/view-article/-/journal_content/title/iuclid-service-release-v7.12.4

UK News

Two new Technical opinions from the HSE

As part of the GB-CLP Mandatory Classification process, the Health and Safety Executive (HSE) issue Technical Opinions on what they think new MCs should be. These are then signed off by the Secretary of State before coming into legal effect, as per the process here: https://www.hse.gov.uk/chemical-classification/gb-mcl-list.htm

The latest to reports are for

As usual, do not use the Technical Report classifications, you should wait until they are brought into the MC list itself.

Ali comments (somewhat tongue-in-cheek) that these reports are bound to be a bit controversial, as Hexyl Salicylate is classified as Sensitizing (Skin Sens. 1; H317) and Reprotoxic (Repr. 2; H361d) , which will upset IFRA and their fragrance members; and Glyphosate is not classified as carcinogenic, upsetting some of the NGOs! I should point out that Glyphosate will be classified for eye effects (Eye Dam. 1; H318) and chronic aquatic toxicity (Aquatic Chronic 2; H411).

James Dawick of INNOSPEC LIMITED (UK) 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: https://health.ec.europa.eu/publications/hexyl-salicylate-casec-no-6259-76-3228-408-6_en . Many thanks to James for the update.

GB Biocidal Active Substance Expiry Dates Postponed

Active substance expiry dates for all biocidal active substance/product type combinations which were due to expire between 1 January 2024 – 31 December 2026, have been postponed until 31 January 2027. See the announcement email here: https://content.govdelivery.com/accounts/UKHSE/bulletins/38b5095, and further details here: https://www.hse.gov.uk/biocides/expiry-postponements.htm.

Ali writes: First things first – This is great news for anyone worried about the imminent loss of biocidal active substances from the GB Market (and to reiterate – everyone should have been worried about that!)

If you want to supply a new Biocidal Product then you still need to apply in the usual way, but for anyone supplying treated articles, such as products where the biocidal active is just an in-can preservative, this will be a lifeline.

However, my enthusiasm for this news is tempered. This is not a staggered postponement. All the expirations (110) have been moved to the same date (January 31st 2027), which is just 3 months after the 1st REACH deadline. Will the regulator really have the ability to handle the amount of approvals which will all be due on the same date?

And it’s not just the regulator, the labs will all be booked up, and the companies themselves will now have to prepare mulitiple complex BPR dossiers for the same renewal dates.

In the meantime, does the regulator have sufficient data on the biocidal actives they’ve just extended? Were these substances originally rubber stamped on the basis of Union authorisation or mutual recognition? In which case the UK regulator may not hold the full dossier.

And if the concern is that we were about to lose a number of key biocidal actives from the GB market, is there some initiative or campaign to identify and encourage the support of these substances through the BPR. Or are we literally just postponing the whole problem until January 2027 with zero solutions.

I absolutely understand that the agency needs to firefight the immediate problem of losing these substances from the GB market. But without a long term plan, we’re just kicking the can down the road.

Around the World

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 https://www.linkedin.com/in/melissa-owen/ .

Process Safety Corner

Another excellent graphic novel from Ramin Abhari, P.E. on a PPB contamination incident in Michigan in 1974: https://www.linkedin.com/pulse/mix-up-michigan-back-story-ramin-abhari-p-e-/.

The latest “Trish and Traci” podcast from Trish Kerin is out now, this time on the topic of inherently safe design: https://www.chemicalprocessing.com/process-safety-w-trish-traci/article/33036866/master-inherently-safer-design-principles (this has a transcript to scan if you don’t have time to listen to the podcast itself)

I recently came across the concept of Security Theatre, things done to make us feel safe which don’t necessarily actually make us safer: https://www.linkedin.com/posts/globalhsemanager_security-theatre-describes-measures-that-activity-7162253409490833408-nEOQ

For those of us who are (ahem) more experienced, we know that there are usually trade-offs between health/safety/environment, (as Ali mentions in her article on flame retardants), and here is another classic one: Safety versus Environment – refrigerants https://www.linkedin.com/posts/engineereck_nfpa-flammable-refrigerants-hazard-assessment-ugcPost-7162492836460814336-Vigf

This type of trade-off is why I don’t believe in the utopia of ECHA about “health safety and environment all working together”, as if you can somehow engineer chemicals which can manage to be healthy, safe, environmentally friendly and actually do the job they’re supposed to (an example of this type of ECHA thinking is here: https://www.linkedin.com/posts/european-chemicals-agency_joining-forces-for-humans-animals-environment-activity-7163814703993999360-51El).

Infographic of the Month

Continuing our mini-series of productivity infographics, another excellent summary from Victoria Repa: https://www.linkedin.com/posts/victoria-repa-115a1987_how-to-100-turn-your-goals-into-reality-activity-7146485025448931328-DV_5/

The Weekend Watch

Probably one of the most important Weekend Watch/Read items I’ve ever posted, from Gareth Lock – Compliance provides the illusion of safety in diving: https://www.youtube.com/watch?v=VNhmxz2_adc .

This is very applicable to the chemical industry. Are we creating competent members of staff, who can adapt and react appropriately in changing circumstances, or box-tickers who can only work off a procedure?

The Weekend Recipe

As we’re firmly in Lent, I thought we should try some vegan recipes, in case any of our lovely readers have given up dairy produce or meat. One of our main go-to vegan (and free-from) recipes is Chickpea Curry, (hat tip to my former husband Tony Murfin , whose recipe I still use), which I sometimes add cauliflower to, but I fancied making a non-tomato curry for a change, and came across a recipe on BBC food to try out.

The ingredients are so similar to my normal Chickpea Curry that I thought it would be fun to make the two recipes side-by-side, and have a taste test (just as well Mike likes Chickpea Curry, although we often serve it with sausages for some meat protein 🙂 ).

Cauliflower and Chickpea Curry – Coconut and tomato versions

Basic ingredients (if making 2 lots of curry, double these quantities except the spices which can stay the same unless you like a strong curry)

  • 1 tbsp sunflower or vegetable oil
  • 1 small onion, sliced
  • 1 clove of garlic, crushed or finely chopped
  • A thumb-sized piece of fresh ginger, grated
  • 1 tbsp curry powder (I use medium), or curry paste (if you have some handy)
  • 1 small cauliflower, cut into florets, stalk sliced
  • 400g tin chickpeas

Coconut chickpea and cauliflower curry only

  • 2 tsp ground turmeric (optional)
  • 1 400g tin coconut milk
  • 1 lemon, cut into wedges (to serve, optional)

Tomato chickpea and cauliflower curry only

  • 1 400 g tin of chopped tomatoes
  • tomato puree
  • tomato ketchup

Method: Heat the oil up in the pan you’re making the curry in (saves washing up – purists would fry the onions and spices off separately in a frying pan). Fry the sliced or chopped onion in the vegetable oil for 5 minutes until brown. Add the garlic and ginger and stir for 1 minute (not too long, we don’t want the garlic to get too brown and bitter, or catch on the base of the pan). Add the curry powder or curry paste, and fry for another minute or two to cook the spices (if using turmeric for the coconut curry, add at this stage too). Add in the tinned chickpeas, drained (reserve the liquid) and stir round to coat in the curry powder.

Next, add the specific liquid ingredients for the style of curry – for coconut, add the coconut milk and the drained chickpea water; for tomato, add the tin of chopped tomatoes. Finally add the cauliflower pieces (florets – you can use the chopped stalks as well, although I’d add them first and cook them for 5 to 10 minutes before adding the florets, which tend to cook more quickly),. Don’t forget to add some salt at this stage.

Cook over a low heat for about 10 to 20 minutes until the cauliflower is cooked to your liking (chewy or soft). During cooking, you may need to add extra liquid if the sauce is too thick (e.g. the tomato version may need some of the chickpea curry water adding).

When the curry is nearly finished, adjust the texture of the sauce by either adding more liquid; or you can thicken it either with cornflour slaked in water (coconut curry or tomato curry); or by adding about a tablespoon of tomato puree and a teaspoon of tomato ketchup (tomato curry only).

Findings: well, there was quite a difference in flavour between the two batches. Both of them were tasty, although as you might expect, the coconut milk version was more mellow, and the tomato version more tangy. I would use the minimum amount of water to cover the cauliflower (or use the chickpea liquid), as the tomato version was a bit runny and needed quite a bit of tomato puree to thicken up (and a vegetable stock cube for extra flavour).

I must admit that the amount of cauliflower was higher than when I add it to my own chickpea curry recipe (more properly, my ex-husband’s chickpea curry recipe), making it more of a vegetable curry with chickpeas than a chickpea curry with cauliflower. As I’d accidentally used too much ginger, and unfortunately picked up the low-fat coconut milk, I added some powdered coconut milk (a new ingredient I’m trialling – but it does contain casein, so OK if you’re lactose intolerant, but not if you can’t handle any dairy produce), which made it much creamier and upped the coconut flavour nicely.

Overall, both recipes work, and are good and tasty.

Reasons to be Cheerful

I spent quite a bit of time in January in Scotland helping look after my elderly Mother, and that stirred quite a few memories, which was reflected in my choice of “Reasons to be Cheerful”.

When my sister and I were children, we didn’t have a television and instead used to listen to Radio 4, where Kenneth Williams was a regular on panel games, and he also appeared in repeats of earlier comedies like Round the Horne.

Here he is explaining accents: https://www.youtube.com/watch?v=qh29gBLoHVU and appearing as Rambling Syd Rumpo on Parkinsons https://www.youtube.com/watch?v=Dct_VJNLvAk

For the rest of February, I was in a bit of a Two Ronnies mood:

Water Pub – https://www.youtube.com/watch?v=mkwzN-AdIEY .

Swear Box https://www.youtube.com/watch?v=p-TNrSDVGi0

Ice Cream Parlour: https://www.youtube.com/watch?v=kBmKxX22ONs .

Remembering the good times when we were growing up reminded me of a phrase about “the land of lost content“, which turns out from Poem XL from A Shropshire Lad, by A.E. Housman, https://poets.org/poem/shropshire-lad-xl.

Many thanks for reading this LinkedIn newsletter, and many thanks to everyone who has contributed. 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 newsletter.

It would be great if you’d like to subscribe to this newsletter, or even our weekly email one https://www.ghsclassificationcourses.com/home/news... (which includes access to the email archive).

Look forward to chatting to you in late March or early April.

Kind regards,


Janet Greenwood, TT Environmental Ltd

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