Chemicals Coffee Time, 4th August 2023

Dear Friend,

Happy Friday!

I hope this finds you well, and not growing webbed feet in response to all this rain. Mike and I can’t remember what the weather was like on St Swithin’s Day, 15th July, but the evidence would suggest it rained! (For the prophecy, see

Ah well, at least we’re not being distracted from work by sunny weather.

First, some updates from our lovely readers, which we always appreciate very much (even/ especially when they pick up on our mistakes and omissions).

DGSA readers – an update

Andy Lines of Total Compliance (full name “Total Compliance in Consultancy & Training for Transport, Logistics & Construction) is another newsletter reader and DGSA, you can find their website here: .

Andy is trying to publicise the impact of Lithium battery fires, which are much more widespread than many people realise: and also occur at sea:

Andy notes: “It’s an important area that, although widely reported every time they happen, is causing concern amongst DG professionals due to the lack of government urgency“.

EU Cosmetics list updated link

Breda Kosi writes, of the EU Cosmetics Lists updates I mentioned in last week’s newsletter: You can find it in OJ L

Annex II to Regulation (EC) No 1223/2009 is amended

Commission Regulation (EU) 2023/1490 of 19 July 2023 amending Regulation (EC) No 1223/2009 of the European Parliament and of the Council as regards the use in cosmetic products of certain substances classified as carcinogenic, mutagenic or toxic for reproduction (Text with EEA relevance)

Annex III to Regulation (EC) No 1223/2009 is amended

Commission Regulation (EU) 2023/1545 of 26 July 2023 amending Regulation (EC) No 1223/2009 of the European Parliament and of the Council as regards labelling of fragrance allergens in cosmetic products (Text with EEA relevance)

Many thanks to Breda for this information.

Rev 10 of GHS now published

Breda also emailed me to say that GHS Rev 10 has just been published, see

This document is currently only available as a non-editable pdf or print version. (The editable pdf is the most useful, in my experience, and well worth the cost).

The summary of changes given on the UNECE website is: “…addressing, among other topics :

  • the classification procedure for desensitized explosives (chapter 2.17);
  • the use of non-animal testing methods for classification of health hazards, in particular: skin corrosion/irritation (chapter 3.2), serious eye damage/irritation (chapter 3.3) and respiratory or skin sensitization (chapter 3.4);
  • further rationalization of precautionary statements to improve users’ comprehensibility while taking into account usability for labelling practitioners; and

the review of annexes 9 and 10 to ensure alignment of the classification strategy, guidance and tools on metals and metal compounds with the provisions for long-term aquatic classification toxicity in chapter 4.1.” Call us cynical, but this list definitely doesn’t include changes which may turn out to be most important to industry… and of course it will take some time to work through the changes as a whole and think about their implications.

Ali would like to draw attention to a significant change in Annex 3 which allows for more flexibility in combining H-Statements where there may be insufficient space on the label. For example, if your product has multiple hazard classes which are all category 1 you could create a combined statement for the label which reads “May cause an allergic skin reaction, genetic defects and cancer”.

In theory this would be beneficial (label space is always at a premium)! But trying to think of all the potential combinations and permutations of translations makes us think it’s unlikely that the EU could ever adopt this in practice. And it’s a nearly impossible goal for software companies that offer translation of labels and Safety Data Sheets!

Thanks again to Breda for this important news, which I understand was broken in the EU by CIRS. Ali’s been pretty impatient waiting for this one since the UN committee on GHS met on July 10th and there’s at least one company that’s been advertising the print edition for over a month despite it not being published yet!

Hearing from the HSE and the UK

Not the HSE this week, but the UK in general. On Tuesday, it was announced that the UK would accept the CE conformity mark for the foreseeable future, many thanks to Elaine Field for asking what we think about this.

In practical terms, this is a very good thing for industry because there will not be a need for dual accreditation where your product needs to undergo a conformity assessment.

Unfortunately its a big loss for the test facilities bodies based in the UK as they are not able to certify under the European Conformity Assessment scheme (the UK accreditation body does not have a mutual recognition agreement). This means that companies that send their products to UK facilities to gain their conformity accreditation will not have access to the EU market.

Regrettably you can’t even use the Northern Ireland loophole in this instance. Products certified by the Notified Bodies in Northern Ireland can only affix the NI(UK) mark, and not the CE mark and cannot be made available in the wider EU.

In summary – a good deal for importers but bad news for exporters. And terrible news for the test facilities in the UK. We can only hope that someone is working on a Mutual Recognition Agreement for the Notified Bodies.

Then in the ridiculously early hours of Wednesday morning, DBAT put out a press release on Modernising Product Safety Laws. They’ve managed to hint at a lot in very few words:

  • Strengthening regulations for online/remote sales
  • Overhaul of furniture and fire safety laws
    • This seems to be regarding an upcoming consultation on hazardous chemicals used for flame retardants in domestic furniture
  • Digital labelling

Ali notes that while the press release implies this is part of the effort to review legislation before the ‘Retained EU Law Revocation Act’ passes at the end of the year, this actually has more in common with the EU ‘Fit for a Digital Future’ project which underlies many recent (and proposed) changes to EU legislation.

Keeping an Eye on ECHA and the EU

Alternatives to Authorised chemicals

ECHA have recently published a list of alternatives to Authorised chemicals, which you can download from this webpage in xlsx format: .

I’d be interested to hear from anyone using one or more Authorised chemicals whether the proposed alternative(s) will work for your particular product(s) or applications(s).

There are some genuinely innovative solutions on the list. But there are also quite a few that have switched to equally harmful/toxic materials that themselves are on the candidate list or are in the process of being considered for authorisation and/or restriction. In those instances, it concerns me that all those companies have achieved is a small regulatory extension for a sizeable financial investment.

EU updates Toy Directive (chemicals mentioned specifically)

Phil Rowley writes: EU now consulting on an update to the Toys Directive :-

Many thanks to Phil – the two reasons given for the update are:

  • increase protection from harmful chemicals (extending the rules from CMRs to include Endocrine Disruptors, chemicals affecting the respiratory system, and STOTs)
  • strengthen enforcement (including a Digital Passport for toys)

Process safety corner

Recent incidents:

The latest Trish and Traci podcast is out now, on lessons from Piper Alpha:

Jobs update (UK stats from LinkedIn)

1,757 jobs in Regulatory Affairs (although the LinkedIn algorithm may be playing up), and 50,787 Health and Safety jobs.

PIP Chemicals in Northern Ireland are hiring a chemist as Head of Technical:

I don’t recommend this as a method for producing a CV, but someone has used ChatGPT and a number of other tools to try and outsmart the machine-reviewing of CVs which is now used in larger companies: but .

So what happens when the person who is good at stitching bits of IT together to optimise their CV gets the job, and can’t do it? (unless that job is in IT or websites or similar in the first place….)

Infographic of the week

An really good series of infographics/ carousel on The 8 wastes of Lean Manufacturing:

The Weekend Read

An excellent article on the PERT distribution, and why it’s likely to be misleading

The Weekend Recipe

It’s the summer time (allegedly) and that means a classic British pudding, Eton Mess, so called because it was invented at Eton school.

It’s deceptively simple, even more so if you cheat and use shop-bought meringues, although they tend to be quite dry and don’t have the same lovely texture of a home-made meringue. Foodie note – this is technically a French meringue recipe, which doesn’t rely on a thermometer to work (as Italian and Swiss meringue recipes do).

Meringue ingredients:

  • 3 egg whites (use the eggs for hollandaise sauce, or in a custard or omelette)
  • around 6oz caster or granulated sugar (I was brought up with 2 oz sugar to 1 large egg white, but experts will weigh the egg whites and adjust the weight of sugar accordingly, working in grams for accuracy)

Meringue method:

  • set your oven to gas mark 2 or gas mark 1, and line a couple of baking trays with greaseproof or baking paper (don’t grease it though)
  • whip your egg whites in a bowl until they form stiff glossy peaks. This will only work if there is no trace of yolk or other fatty substances, so everything needs to be scrupulously clean. You may cheat and use an electric whisk or hand beater, or a food processor, but you will get a very even pore structure which isn’t necessarily as nice as hand whipping. Top tip – older eggs have lost moisture, and the whites whip up much faster than fresh eggs (but don’t keep eggs too long just for that reason)
  • add a tablespoon of sugar and whisk again until stiff and glossy, and repeat until all the sugar is used
  • place in mounds on both baking trays and bake for about an hour in the very low oven (if you think it’s cooking to fast, turn it down). If you can switch your oven off, (not possible with a Rayburn, Stanley or Aga), you may want to leave the meringues in the cooling oven
  • when cooked, cool on a wire tray (take off the paper as well). The meringues can now be sandwiched together with cream, or used in Eton mess

Making the Eton mess:

  • the baked individual meringues
  • 1 pint double cream
  • 1 lb strawberries
  • a little sugar, to taste

Wipe the strawberries clean and take the hulls out (if they are ripe, you should be able to pull them out). Take half the strawberries and puree them in a blender with a little sugar, or mash them with a potato masher (depends on what texture you want). Chop the remaining strawberries into bite-size pieces. break up the meringues into similar sized pieces. Whip the cream and fold through the meringue and strawberry pieces, then ripple the puree. Serve immediately – enjoy! (

Notes – You can make everything beforehand and simply mix together before serving. Some people make this a lot fancier, e.g. by sieving the puree to remove the strawberry seeds, or adding a splash of booze.

The most extreme version i could find was a professional chef named Marcus Wareing – Eton Mess? more like Eton Tidy! .

Keeping the Chemicals Coffee Time newsletter private yet open to interested parties – continued

We are looking at a number of options for the newsletter, including how to host it going forward, and perhaps introducing a small charge for new readers. All thoughts and opinions gratefully received!

Reasons to be Cheerful

Continuing our mini-series of Mitchell and Webb videos, here’s Alien invasion .

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