Chemicals Coffee Time, 21st October 2022

Dear Friend,

Happy Friday!

Well, what a week it’s been in UK politics – again!  As Alan McGuinness of Sky News posted on Twitter on Wednesday, “My son has lived through four chancellors, three home secretaries, two prime ministers and two monarchs. He’s four months old.​”  With an additional comment yesterday – “Soon to be three prime ministers“.  (Unless Boris Johnson gets re-elected:…​).​

For SciFi fans (and, let’s face it, nerds like me tend to fall into this category), this is starting to resemble the President of the Galaxy position in The HitchHiker’s Guide to the Galaxy book series, where Zaphod Beeblebrox realised that the job of President was to distract people from whoever was running things in the background.

Leaving politics aside, we’ve had quite a bit of rain, so the reservoirs are starting to refill, and with a bit of luck they will soon be back at normal capacity. Welcome news after quite a dry late summer and autumn, although it does mean we’re going through doggie towels very fast.  Meggie (our old dog) has decided that she’s going to play-fight the towel, as if she was a puppy!  Any tips on how to persuade a very stubborn 12 year old cocker spaniel to stop mock-biting and dancing around, and encourage her to co-operate with being dried, would be very welcome.

Don’t panic about the new EU SDS format

There’s a lot of concern (and marketing!) about the new EU SDS format which comes into effect on 1st January 2023, but it’s a more nuanced situation than many people realise.

For example, if you’re only selling into mainland GB, this new format SDS won’t apply to your products; and did you know that even if you create an EU format SDS with a GB address for contractual reasons, that’s not compliant with EU law? To answer these questions, and more, we’ve created a new factsheet which summarises the current situation to the best of our knowledge: Don’t Panic About – The New EU SDS Format, 19-10-2022.pdf.

You can also download it on “open access” (no email or sign-up required) from here:… . This page also includes links to the main documents referred to in the factsheet, in case anyone has problems accessing them from the pdf (many thanks to Peter Godfrey of CEA Research Associates for pointing this out – it can be a firewall issue).

Feel free to share this factsheet and/or link with anyone working with chemicals who may find it useful.  It was also published on LinkedIn (without the cover pages) on Wednesday….

This is the first in a series of factsheets about chemical regulatory “hot topics”, and, as usual, all feedback is very welcome.

In a classic example of “great minds think alike”, Colin Pratt of Dangerous Goods Services also produced a LinkedIn article on the same topic later on the day I published the factsheet on LinkedIn, with a bit more detail on SDS content, which you can find here:…

Hearing from the HSE

The ongoing MCL/HCL issues continues to cause concern, as discussed in last week’s email (see…​).

Colin also writes:  In Fridays post you included the following


acetamiprid (ISO);
135410-20-7 Acute Tox.3, H301, from Acute Tox. 4, H302*, and Chronic Aquatic 1, H410, increased from Chronic Aquatic 3, H412. (New hazards Repr. 2, H361d, and Acute Aquatic 1, H400).

[End quote]

So to extract the relevant bit (from my side at least) the Environmental Hazard has increased from Chronic Aquatic 3 (H412) to Chronic Aquatic 1 (H410) – NOTE I’m just reviewing this one end point in isolation!

By ADR (2021) this will now become an “Environmentally hazardous substance for transport” so UN 3082 (Liquid) or UN 3077 (solid).

So again this one end-point (viewed in isolation) will cause issues – if a UK haulier uses the MCL, then its not hazardous to transport, if he uses the HC it is (for this end point). Not the same legal dilemma of course – but still a conflict of interests.

ADR Quote)

Substances shall be classified as “environmentally hazardous substances (aquatic environment)”, if they satisfy the criteria for Acute 1, Chronic 1 or Chronic 2, according to Table These criteria describe in detail the classification categories. They are diagrammatically summarized in Table

(End quote)

I believe that said table lists the CLP / GHS values , such that ADR and GHS are “aligned” and the higher GHS hazards result in transport classifications ( the lower don’t).

Many thanks to Colin for spotting another problem with diverging too far from EU hazard classifications.

Can you help? UK REACH extension deadlines decision

Kerry Allan O’Sullivan of Haltermann Carless writes – I was wondering if you would be able to put something into you weekly round up regarding the lack of information and time taken to decide on UK REACH deadline extensions. We are currently trying to organise our budget for the coming year and have faced this uncertainty with many questions and varied scenarios regarding a best case and worst case. Just thinking most companies are in a similar boat.

A quick check on the public consultation on the extension to these deadlines at… shows that there is a maximum 12 week timetable for the outcome of the consultation to be published, which takes us to 1st December 2022. Of course, that isn’t necessarily the decision on whether the deadlines will be extended. (And given the current political turmoil, is the UK Government actually able to take this kind of decision?).

Do any of our newsletter readers in the larger chemical companies or consultancies, or legal experts, have any information on this? because it’s not a trivial issue for many businesses, both inside and outside the UK, or more properly, Great Britain.

Keeping an eye on ECHA

Alison writes:

There’s an appeal for a REACH dossier. ECHA want more testing to be carried out, the registrants think it isn’t warranted.

I think ECHA are looking for Endocrine disruptors…

The existing STOT (Oral) show mechanistic effects -> minor changes to the thyroid, slight hormonal changes etc… but no adverse toxicological outcomes meaning no classification. And the existing Repro test was also negative.

ECHA want generational repro testing. Presumably to see if the mechanistic effects accumulate in later generations and would result in classification, but the existing legislation doesn’t warrant it – hence the appeal.

The registrants are pointing out that the developmental neurotoxicity tests that ECHA also wants aren’t fully valid.

Could be an interesting outcome.

Food Contact Materials Webinar

Andrew Bourne from WSP writes: This is a free webinar WSP are running on Food Contact Materials (FCM). There has been a lot of developments in this area over the last year (German Ink Ordinance) and even in the last month or so (EFSA proposals) so we though this might be a good time to do a round up of the global regulations and what this means for international supply chains.

The webinar will be presented in plain English to make it accessible to everyone.

WSP are intending to run a series of these webinars which look very useful, we’ll keep you up to date with them.

Titanium dioxide news

A literature review on the genotoxicity of Titanium Dioxide was published on 11th October which discusses all of the test results available publicly, see… . The authors conclude that in the reliable studies, the genotoxic damage was the same as seen under physiological stress, and that the evidence to date does not support a direct DNA-damaging mechanism for TiO2 in either the nano or micro form. (To nobody’s surprise, except perhaps the regulators!).  And there’s a follow up post this week from Dave Shoneker:… .

However, I would still like to know whether or not asbestos (or silicates with similar cancer-inducing properties) can be found naturally in Titanium Dioxide, as this is potentially a route for lung or other cancers to be unwittingly caused, as we learned recently from the Talc situation, see….

Having said that, even if there is a small amount of asbestos in TiO2 (and we don’t know yet), workers with it are usually protected from breathing in the dusts under occupational health legislation; and it is mainly found in liquids in consumer form, so exposure via inhalation would be significantly lower than someone liberally using talcum powder on their body and on babies bottoms.

Product safety news

The problems with contaminated cough syrup which killed children in the Gambia (that we reported last week) may be more widespread than previously feared – Indonesia has taken a rather extreme step of banning the sale of all liquid medicines for children (both on and off prescription) while they investigate a rise in deaths there, see….

Ali comments: Indian Health Authorities shut down all production at Maiden Pharmaceutical last week, after finding violations “across its manufacturing and testing activities”. But that may cause its own problems as they are a major manufacturer and India provides 45% of all generic medicines to Africa.

Jobs update (UK stats from LinkedIn)

Regulatory affairs 658 jobs and Health and safety 54,301 jobs, an increase (of 1!) in regulatory affairs, and a decrease in Health and Safety jobs. This does not give the full picture on Regulatory Affairs, where there is still a lot of behind-the-scenes recruitment going on via head-hunters and personal contact.  If you are looking for work, check out your preferred companies’ pages on LinkedIn and their websites, and consider sending your CV with a covering letter even if no jobs are advertised.  This tactic works more often that recruiters like to admit.

Handling work stress from emails

As we all seem to be extremely busy at the moment (possibly as we come up to the October school holidays?), it’s easy to get stressed out by the tiniest details.  Not to mention the stress from all of the political uncertainty.

I came across an email from a rather unthinking fellow small business owner on Tuesday, who will literally send an email in the middle of the night with the following explanation: “I am fortunate enough to have the luxury of working flexibly which is why I’ll sometimes email you at very odd hours. This suits me but it might not suit you, so please only respond to me during your own working hours and at a time convenient to you 🙂 “.

My response (having deleted my original reply which may have included the terms “sociopath“, “bragging about being in charge of your own hours to people who aren’t” and “extremely rude“) :

While I think the explainer is a good idea, I think it’s much, much better to stack up out of hours emails and send during working hours. I describe it as an “email curfew”.

Having been on the receiving end of multiple OOH emails from another consultant during a joint project while I was working away from home to help look after my ailing father, and literally sleeping on my sister’s sofa, pings at 8, 9 and 10 pm simply added to my stress levels. (The other consultant was working around her small children at the time, but I had to put my foot down about when the emails were sent, as it was affecting my health adversely). So please do consider your recipients.

I recently found that Outlook has some kind of feature where you can send weekend emails at 8am on Monday – it worked once, then disappeared into the ether, so I accidentally sent an email over the weekend – ooops! But I do my best to stick to an email curfew.

Comments on LI etc are different, there are some fascinating discussions over the weekend. But emails? Definitely on curfew. I also try to do this with both emails and teams chats my remote working team, for similar reasons.

Your email sent out of hours could be the thing that tips someone over the edge.”

Feel free to pinch the idea of an email curfew, for both sending and receiving, as it really does help cut stress levels.

And dealing with stress generally

An excellent set of tips from Howard Quinlivan on LinkedIn at… .

In my experience, the “macho” mindset (which these days can come women trying to compete with men, just as much as men themselves) can lead to people taking poor decisions on their own safety or health (which is fine, that’s down to them) or on other people’s safety or health (which is far more worrying).

Process Safety Corner

Recent incidents

Historic incidents: the CSB have published their investigation into a 2021 liquid nitrogen fatality:…

The need to dig deeper to the “second stories” during incident investigation…

I was too busy to get to Hazards 22 which took place in Harrogate this week, but hope to post some interesting items from the event in next week’s newsletter.

The Weekend Read and Watch

A fascinating article on growing moulds and searching for new chemicals they create:…

And an excellent little video on how the stomach works:…

The Weekend Recipe

Autumn – season of mists and mellow fruitfulness, and delicious puddings too!  This week we have Ali’s Boozy Bread and Butter Pudding, which is also lactose free, and can easily be adapted to be gluten free.  Ali writes:

Use the alcoholic spirit of your choice for this one! It’s designed for a rum or brandy, but works well with Vegan Bailey’s and I’ve also had success with certain flavours of Gin.


  • 7-8 Slices white bread
  • Enough ‘Butter’ to cover the bread
  • 150 mls alcohol
  • 4-5 tbsp raisins/currants/dried peel
  • 350 mls lacto free milk
  • 250 mls Arla lacto free cream
  • 1 tsp vanilla
  • 140 g Sugar
  • 3 eggs
  • 3 tsp apricot jam to glaze
  • Icing sugar to dust


  • Soak the fruit in the alcohol. Preheat the oven to 170⁰C (150⁰C Fan).
  • ‘Butter’ the bread with your lacto free alternative. Cut the slices diagonally and arrange into an oven proof dish.
  • Pour the milk and cream into a saucepan, add the vanilla and bring to a gentle boil while stirring.
  • Whisk the eggs and sugar together. Add the egg mixture slowly to the saucepan of hot milk/cream and whisk together until smooth.
  • Sprinkle the fruit over the bread with any remaining alcohol that the fruit has not absorbed.
  • Pour the milk mixture evenly over the bread.
  • Place the dish in a larger roasting tray. Pour water halfway up the tray (Bain marie) – and bake in the oven for 45 minutes until golden brown.
  • Warm the apricot jam and brush over the bread pudding. Dust with icing sugar and serve.

In my house we make this with gluten free bread (an easy substitution). And the recipe takes well to adaptations – you could switch for brioche loaf, use cranberries or any preferred dried fruit, and consider a marmalade or jam glaze.

If you have no dietary requirements in your house, then swap the liquids for 300ml double cream and 300ml whole milk for a richer custard base

Reasons to be Cheerful

Adam Batting of Contract Chemicals writes: Hopefully this will make you smile, an old bit of Australian satire very much in the Bird and Fortune mould about an oil tanker spill Clarke and Dawe – The Front Fell Off – YouTube .

And did you know what the new Queen Consort put in the “girls in pearls” picture when she guest-edited Country Life magazine this summer? Now that’s a countrywoman, and a dog lover, with a sense of humour!…

There are almost too many memes about Liz Truss and the political situation, but here are a few favourites:

consensus /kənˈsɛnsəs/noun

nounconsensusplural nounconsensuses

    1. a general agreement. “there is a growing consensus that the current regime has failed”

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.  When we may, or may not, have a new Prime Minister, or a previous Prime Minister back again – who knows!

Kind regards,


Janet Greenwood

TT Environmental Ltd

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