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Chemicals Coffee Time, 25th November 2022

Dear Friend,

Happy Friday! And Happy Thanksgiving for yesterday for our American readers!

Here in the UK, we don’t celebrate Thanksgiving as such, but this Sunday marks the start of Advent, when we prepare for the coming of the Christ Child. Traditionally, it is a time of prayer and preparation for the Christmas feast, sometimes we fast as well, although not necessarily as strictly as during Lent https://www.christianity.com/wiki/holidays/what-is….

For many people, Advent also marks the time to put up their Christmas lights, and if you do, watch out for warning on any extension cables wound round a drum. Pulling too much power through one of these can heat it up so that the copper melts, see
https://www.linkedin.com/posts/ben-bell-6498531a5_… . (Did you know that modern extension cable drums may give two figures of safe power use, one when the cable is coiled, and one when it’s fully extended? news to me, but I am very careful about unrolling extension cables fully, or other electrical cables wound round a central point, for example on my Henry vacuum cleaner).

There is something very deep in the traditions of Northern countries about light and warmth and feasting at Midwinter, and there is evidence of this at Durrington Walls outside Stonehenge about 2,500 BC, that is 4,500 years ago https://www.english-heritage.org.uk/visit/inspire-…

Can you help?

Alan Ritchie of WSP has asked if anyone has had difficulty installing the latest server version of IUCLID6.  WSP have attempted this on two separate servers, and now can’t use it at all.  This issue has also occurred in other businesses, and been flagged up on the ECHA LinkedIn support group for IUCLID users, which you can apply to join here: https://www.linkedin.com/groups/12043483/​  .  The admins in the group simply recommended that the affected user contact their helpdesk, so it does seem to be a tricky problem.

In the meantime, have you or your colleagues come across this problem, and do you have any tips on how to resolve it?  If you are thinking of installing this latest upgrade to the server, you may want to wait and see what happens.

A good day for science – Titanium Dioxide is Innocent!

You may have seen the newsflash on Wednesday, when we found out that the General Court of the European Court of Justice has ruled that the Harmonised Classification of Titanium Dioxide as a carcinogen, which was brought in under the 14th ATP to EU-CLP, is to be annulled.

More details here (open access, no sign in required): https://www.ghsclassificationcourses.com/newsflash…

And thanks to Aaron McLoughlin of Fleishman Hillard who has provided the full decision: https://curia.europa.eu/juris/document/document.js… (a mere 70 minute read….)

Obviously, this ruling only applies to the EU Harmonised Classification, not the GB Mandatory Classification. There are also likely to be consequences for downstream regulations, such as cosmetics and food safety regulations, both in the EU and UK. And as Anna Thomason of Aquaspersions pointed out via email “It’s still on the CAL PROP 65“.

We also need to be careful to understand whether Titanium Dioxide can contain asbestos in any significant concentrations, because, as we learned earlier this year, it is likely that it is asbestos in Talc which has given rise to health problems in people who used it over a long period of time, see https://www.ghsclassificationcourses.com/chemicals… (also open access, no sign in required).  (By the way, asbestos is identified in samples through microscopy, see eg. ALS Global https://www.alsglobal.eu/specialities/asbestos/ana…​).

It’s also a very important ruling for other substances:

  • Alison points out that it’s the first time we have seen a Harmonised Classification overturned in a court of law.
  • And you may remember that some time ago, ECHA said that they would use Titanium Dioxide as the first substance where particle size was effectively carcinogenic, and then roll that classification out to all PSLTs, that is Poorly Soluble Low Toxic materials. They seem to have gone quiet on this proposal recently, perhaps because the court case was in the pipeline, but with a bit of luck this ruling means this proposal won’t be implemented.

School chemistry experiment gone wrong in Australia

Horrifying news of two children hospitalised following an experiment gone wrong: https://www.bbc.co.uk/news/world-australia-6369889…. Apparently, burning material from the experiment was caught up in a gust of wind. It is not clear whether the children were burnt directly through burning materials being blown onto them, or whether their clothes caught fire. (It appears that this is not the first time there have been problems in Australia with this either: https://www.smh.com.au/national/nsw/maybe-it-needs… )

The specific experiment, which I had not heard of before, is called “Carbon Sugar Snake”, and you can see how it is supposed to work here: 

There seem to be a lot of variables which could mean that the experiment is not particularly controllable. There is a detailed description from a company called MEL Science, who provide a good deal of safety information as well: https://melscience.com/GB-en/chemistry/experiments… .

Update – working from home rules have tightened post-Covid

MIchelle Clements of Christeyns writes: I noticed that you mentioned claiming tax relief for working at home. Did you know that the rules for this recently changed and you can no longer claim as easily as you could in Covid? There are only three specific reasons now.

Like most (if not all) tax matters, this is complicated, so I spoke to an advisor, who recommended the following link as a summary: https://www.att.org.uk/home-sweet-home-%E2%80%93-t… . You will see that the “special reasons” for home working ended on 5th April 2022, that is at the end of the last tax year, and we are now left with the previous reasons for home working.

These can be found in detail here: https://www.gov.uk/hmrc-internal-manuals/employmen… and examples are here: https://www.gov.uk/hmrc-internal-manuals/employmen… .

A number of tests are applied to see if home working expenses are tax deductible:

Before a deduction can be permitted for a household expense it must be demonstrated that the expense has been incurred wholly, exclusively and necessarily in the performance of the duties of the employment, see EIM31630 and EIM31660. Those are the statutory conditions imposed by section 336 ITEPA 2003. HMRC accepts that those conditions are met where the following circumstances apply:

 

  • the duties that the employee performs at home are substantive duties of the employment. “Substantive duties” are duties that an employee has to carry out and that represent all or part of the central duties of the employment (see EIM32780)
  • those duties cannot be performed without the use of appropriate facilities
  • no such appropriate facilities are available to the employee on the employer’s premises (or the nature of the job requires the employee to live so far from the employer’s premises that it is unreasonable to expect them to travel to those premises on a daily basis)
  • at no time either before or after the employment contract is drawn up is the employee able to choose between working at the employer’s premises or elsewhere

In the context of last week’s article, which was about helping disabled employees into work, I suggested that it may be a good idea to permit disable employees to work from home. In this case, this might be e.g. your office is not accessible for them to work comfortably, then they may come under the “no such appropriate facilities are available to the employee on the employer’s premises”.

However, whatever the primary reason for home working, note that the last bullet point states that “it must be clear that the employee cannot choose between working on the employer’s premises or elsewhere“, in other words the employer decides that they must work from home, and this must be in their contract of employment. Apparently it is permissible for an employee working from home to visit the office occasionally, but it must not be their official place of work.

It is obviously possible for any employer to permit home working, but claiming tax back on expense payments for home working, or payment of a flat rate for employees’ home working, is only permissible under these strict conditions.

Any employer who wishes to avoid falling foul of these home working tax regulations should take advice on their own individual situation or individual employees’ situations, in my case from the Federation of Small Businesses https://www.fsb.org.uk/.

Update – UK’s “Bonfire of EU Regulations”

Alison writes: OK, so the government had the Regulatory Policy Committee (independently operated by BEIS) look at the EU retained law bill (Jacob Rees Mogg thing). They just published their report on it. And it is hilarious.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1118976/RPC-CO-5223_1_-_IA_f__-_opinion.pdf

They rated it ‘Not fit for Purpose’

“The IA is not fit for purpose. The Department has not sufficiently considered, or sought to quantify, the full impacts of the Bill. In addition, the IA does not include a consideration of the impact on small and micro businesses (SMBs) consistent with Better Regulation”.

“As first submitted, the IA was not fit for purpose as it failed to consider adequately the full impacts of the Bill, in line with RPC primary legislation guidance. In addition, the Department had not included a suitable assessment of the impact on SMBs across the UK economy, or the impact of regulation (and deregulation) upon them or any potential mechanisms to mitigate the impact. In the Department’s revised IA, there has been little attempt to rectify these”

It’s my first introduction to the word ‘counterfactual’. I intend to use it often!

Update – UKCA mark extension

BEIS webinar on UKCA mark extension (many thanks to Nicola Kaye of REACH Law for sending this through): BEIS webinar slides 21 November 2022 – Update on UKCA Implementation.pdf. The draft text The Product Safety and Metrology (Amendment and Transitional Provisions) Regulations 2022 (legislation.gov.uk).

Training and events

There’s a Chemical Watch conference on Tuesday 6th December on UK Chemical Regulations and Policy, see https://events.chemicalwatch.com/542159/uk-chemica… . Our friend Neil Hollis of BASF is speaking (although it means he’s missing the Chemical Regulations Self Help Group Christmas Lunch meeting – we’ll miss him!).

Chemistry corner

New SI units – https://www.chemistryworld.com/news/si-units-get-n… “Metrologists and metric system enthusiasts can rejoice as there’s now official prefixes for extremely large things – ronna and quetta (1027 and 1030) – and for very small stuff – ronto and quecto (10−27 and 10−30).”

Apparently the large numbers are required to describe data quantities.

Service update- UK Cosmetics notification

Freesia Day of Connect4 Compliance writes on LinkedIn https://www.linkedin.com/posts/f-day-2602241bb_com…

This is a message from the Office for Product Safety and Standards (OPSS) for the ‘Submit cosmetic product notifications’ service.

You can now “Copy and Edit” your submitted notifications
The new “Copy and Edit” feature is now live. This will allow users to copy an existing notification and its contents. This copy will then be available in the draft product notification section. From here users will be able to open the copied notification and make any changes they want to, before submitting it as a new product notification.

This could be used to update an existing notification following a formulation or packaging change or, as a method to reuse notifications as templates.

This new feature can be found on the “Notified Product summary page”. Click on the link “Create a draft notification using this notification as a template”, this can be found in the top-right of the page.

No changes have been made to existing draft or submitted notifications.

Hearing from the HSE

More HSE agency opinions on MCLs, and also Technical Reports published https://content.govdelivery.com/accounts/UKHSE/bul… . (The overall sequence of events for bringing in new GB Mandatory Classification limits is the technical reports are published, then the HSE agency opinion, which triggers a timeline for approval and then adoption).

If DEFRA and the HSE decide to follow the European Court’s decision on Titanium Dioxide, presumably it will take some time to work through.

Keeping an eye on ECHA and the EC

Aaron McLouglin notes on LinkedIn: Something to keep some entertained over Christmas. Santa will deliver the CLP Delegated Act and the ordinary legislative proposal on 19 December. https://www.linkedin.com/posts/activity-6999306721….

Why do most of the important decisions seem to be over Christmas, like this, or finalising the Brexit negotiations prior to Exit Day?

Jobs update (UK stats from LinkedIn)

Regulatory affairs 988 jobs or 4890 jobs – yes, two numbers! looks like there is something strange going on with the LinkedIn job search function on my laptop at the moment, although the lower figure does contain more true chemical industry jobs, and there are some really good quality jobs being advertised at the moment (see below). Health and safety decreases slightly at 54,725 jobs.

If you’re looking for work, some excellent advice on how job postings work on LinkedIn, and to not allow the perceived number of applicants put you off https://www.linkedin.com/posts/markrwilson_complia….

And whatever stage of job-hunting you’re at, at least you’re in a better situation than all those poor ex-Twitter employees trying to find their first job in the real world (satire, and do watch to the end):

Process Safety Corner

Recent incidents

Historic incidents

An interesting HAZOP problem encountered by Tony Ennis, independent DSEAR and COMAH consultant: https://www.linkedin.com/posts/tony-ennis-4ab66218… and some common HAZOP failures and how to deal with them: https://www.linkedin.com/posts/rossbenton_hazop-fa… .

Shameless plug #1: if you’re looking for a HAZOP chair, I strongly recommend Chris Swift of Vysus Group, formerly Lloyds Register, see https://www.linkedin.com/in/chris-swift-187a4b8/. Full disclosure, Chris worked for TT Environmental for just over a year until we had to downsize in the 2008 crisis, and has worked for Lloyds/ Vysus ever since. He’s run more HAZOPs than most people have had hot dinners.

Shameless plug #2: Sean Moran of Expertise Ltd has just completed his Dictionary of Chemical Engineering Practice, see https://www.linkedin.com/posts/sean-moran-chemical… . Full disclosure, like all recommendations for third parties, I don’t receive any money for making them or for making any kind of referrals, so we do our best to ensure that these are people we know and trust.

A video on Quantitative Bow Tie analysis compared to LOPA https://www.linkedin.com/posts/chrisbrookesmann_lo… . (Note that the speaker says Bow Ties have only been used qualitatively “until recently”. At TT Environmental, we developed an in-house version of qualitative Bow Ties for assessing the probability of Major Accident and MATTE hazards for COMAH ERA purposes around 2013, but haven’t publicised it, and I’m sure other companies have done similar things. I have also been on LOPA training subsequently, but for environmental purposes much prefer Bow Ties).

The Trish and Tracey podcast is here: https://www.chemicalprocessing.com/safety-security…

Incident prevention – a reminder to check for buried services before you dig any holes in the ground: https://www.linkedin.com/posts/phil-cornforth-0a98…

Occupational Health and Safety Corner

A very interesting document from ILO, the International Labour Organisation, on the impact of chemicals on people around the world https://www.linkedin.com/posts/nancy-m-mcclellan_i… .

This document states that around 1.5 million people die every year due to “chemicals”, yet, rather like the figures from the European Environmental Agency on chemical deaths in August this year, https://www.ghsclassificationcourses.com/coronavir… it includes asbestos on this list, which is not attributable to the global chemical industry but also mainly down to mining and construction, and also silicosis where exposure is again generally due to the construction industry.

By failing to make it clear that a lot of these chemical exposures are cause by businesses outside what we would consider the classical chemical industry supply chain, these reports are adding to the impression that “chemicals” as a whole are dangerous. This promotes chemophobia, and by extension tars the whole industry as “the bad guys”, when most of the time we are working responsibly to enable people to live safe and health lives.

Even if the death toll globally from chemical exposure is 1.5 million, how many billions are alive today because they have access to one or more of these things, facilitated by the chemical industry in one way or another: clean water, a secure food supply thanks to fertilisers, pesticides, refrigeration and freezers; modern healthcare, including vaccines against the most hazardous childhood diseases; clothing and footwear; and so on.

The Weekend Watch

Following on from last week’s Weekend Watch on the two schools of thought about human error, another video from Lund university – 3 traps in incident investigations Three analytical traps in accident investigation . We all carry out investigations into things which go wrong, in our personal lives just as much as at work, some great tips in this video.

The Weekend Recipe

As we are still in pheasant shooting season (bird flu permitting), I thought you might like my recipe for pheasant and mushroom pasties. You can substitute pheasant with chicken, or even Quorn (other meat substitutes are available).

Rough puff pastry ingredients

  • 8 oz plain flour (Be-Ro is my preferred brand, and yes, good quality flour does make a difference to pastry or a delicate sponge, less so with a strongly flavoured recipe)
  • 6 oz fat, either 3 oz lard and 3 oz butter, or all butter for a very rich pastry (to veganise, use coconut oil instead, and keep your kitchen cool so it doesn’t melt – you may want to use a bit less coconut oil eg 4oz and make a shortcrust instead – I’ve only made shortcrust pastry with coconut oil, so can’t guarantee flaky/rough puff pastry will work with it)

First, make your flaky or rough puff pastry (usually better the day before), or cheat and buy some, if you must.  Sift the flour into a bowl, and add the fat(s) you’re using.  Chop the fat up with a pair of table knives, one in each hand, to form little cubes, then add enough water to make a dough.  Roll out the pastry and make a book fold, then turn and repeat.  Put in the fridge to cool for 15 mins, then repeat the process two or three more times.  As you roll the pastry, the cubes of fat will spread out to help form that all-important lamination.

For a more thorough description of how to make rough puff pastry, see https://www.bbc.co.uk/food/recipes/roughpuffpastry….  There is also Paul Hollywoods cheat’s method here: https://www.bbc.co.uk/food/recipes/cheats_rough_pu…

Filling ingredients

  • leeks
  • mushrooms
  • ​pheasant or chicken breasts, or quorn or other meat substitute​

Take a medium saucepan (which has a lid), and lightly stew some chopped leek in butter in it. Add chopped button mushrooms and stew gently for 5 or 10 minutes until cooked. In a separate frying pan, lightly brown pheasant breasts chopped into small bite sized pieces, then add to the leek and mushroom mix. Add chicken or game or veggie stock (use a stock cube if you don’t have fresh stock), and season to taste with salt and pepper. Finally, add thyme (fresh or dried) to flavour the stew. Cover the pan, and simmer for about half an hour until fully cooked and the flavours blend together. Then thicken the stew to make a fairly thick sauce using cornflour (as usual, slake it in water before adding, then cook out for a couple of minutes), Take off the heat and leave to cool. Don’t try to use this warm, it will destroy the pastry!

Set your oven to Gas Mark 7, and only start to assemble the pasties when it’s up to temperature.  You want to get them in the oven as soon as you’ve made them up, ideally.  Roll out the pastry (about 2mm) and cut round a side plate or dinner plate (depending on how large you like your pasty!). Place a good spoonful on one side of the pastry round, then fold up into a semi-circle and seal the edges by crimping together. Top tip – you will find you need less filling than you think.  It’s important to be able to seal the filling properly inside the pasty! Move onto a baking tray (a fish slice is helpful), and slash the top in a couple of places to allow the steam to come out. Then coat with beaten egg (not sure what the vegan equivalent would be – perhaps an oat milk?). Repeat to use up all the filling, and bake at Gas Mark 7 until done (around 20 mins, may be longer if larger).​

Best warm from the oven but also good cold.  If they’ve gone cold and you want to eat them warm, make sure you reheat them to piping hot standard, either in the oven, or microwave (although that’s not ideal for pastry).

Reasons to be Cheerful

Continuing our mini-series of Harry and Paul doing Dragons Den, we have The Bag Bag 

(apologies for video quality, haven’t been able to find a better version).

Did you see the wonderful Google Doodle on Marie Tharp this week? How the North Atlantic Rift was discovered through painstaking work, including comparing answers from another discipline and finding congruence. https://www.upi.com/Science_News/2022/11/21/google….

And you know you’re a nerd when you see a “motivational” infographic, and all you can think is that (a) water doesn’t flow like that in pipes and (b) they haven’t put any leaks at the pipe joints, where leaks are most likely to occur! https://www.linkedin.com/posts/sameer-chadha-a0729…

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

Janet Greenwood

TT Environmental Ltd

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