Chemicals Coffee Time, 9th June 2023

Dear Friend,

Happy Friday!

It’s been another week of good-ish weather up here, with some cloudy cool mornings turning into warm summer afternoons, but the temperature moderated by a cool wind.

Mike has been growing a courgette plant on the kitchen windowsill, and is swithering (good Scots word for being uncertain) about when to pot it up outside. Luckily there is a heatwave due over the weekend, although there may be thunderstorms to go along with it., so I think he’s going to risk potting the courgette out tomorrow. Who says country life isn’t exciting?

NRES update

Speaking of “exciting” situations, there is some news on the NRES discussions which have been running in this newsletter. Briefly, there has been some confusion over whether you should provide full registration data when you make an NRES, if it is available to you.

We understand that legally an NRES registration should be as full as possible, but that there is some concern within the regulators that this may disadvantage companies if there is a change to the REACH data costs e.g. through data falling into the public domain due to the 12 year rule.

The advice from consultants who know more about this than I do, is that if you are making an NRES registration, liaise carefully with the HSE to ensure that you are providing only the data which is required, and not spending money too early in the process.

Hearing from the HSE

The HSE continue their herculean efforts with MCL technical reports (or is that perhaps sisyphean efforts? They have published a further 7 technical reports this week on:

  • Perboric acid, sodium salt [1]; perboric acid, sodium salt, monohydrate [2]; perboric acid (HBO(O2)), sodium salt, monohydrate; sodium peroxoborate [3]; sodium perborate [4]
  • Perboric acid (H3BO2(O2)), monosodium salt trihydrate [1]; perboric acid, sodium salt, tetrahydrate [2]; perboric acid (HBO(O2)), sodium salt, tetrahydrate; sodium peroxoborate, hexahydrate [3]
  • Sodium peroxometaborate
  • 1H-benzotriazole
  • Methyl-1H-benzotriazole
  • Sodium 3-(allyloxy)-2-hydroxypropanesulphonate
  • N,N’-methylenediacrylamide

We know that the WTO submission (see covers the substances in the 17th and 18th ATPs to EU-CLP, and presumably the latest technical reports relate either to substances which GB has an interest separate to the EU, or to substances which will be included in the EU’s 19th and 20th ATPs (currently in draft stage).

Keeping an Eye on ECHA

ECHA has released the recordings from yesterday’s webinar on the IUCLID6 2023 releases, see .

They have also set up a new webpage on temporary revocations and invalid REACH registrations: .

Another view on scale up

Following last week’s item on scale up and why academics don’t understand it, there is a further burden on companies scaling chemical products, which is the need for regulatory information and compliance under REACH.

A really interesting snippet from Tjeerd Bokhout on scaling up gradually so you can test the market as you uncover the hazards of a novel substance:

In theory, the “regulatory drag” that REACH brings should give known, well characterised existing chemicals a competitive advantage against novel chemicals, yet we are finding that these chemicals are often being proposed for restrictions or outright bans. What on earth is going on in the regulators’ minds?

Change of UK scheme on trading with developing countries

Binny Todd of White Sea and Baltic writes: Thought this might be of interest to readers (if you haven’t already seen it).

See below the change of regulation from GSP to DCTS, Developing Countries Trading Scheme.

This comes into force 19th June 2023, link to regulation below ttps://

These two pieces of legislation allow preferential trade between the UK and developing countries through low or no tariffs being applied.

Can you help?

The CIA and Chemicals Northwest has been asked by the UK Government to organise a specific workshop on Critical Minerals and the Chemical Industry, and they are looking for participants.

The bad news is that it’s due to be held at very short notice, on the 15th June between 11am and 1pm, and participants have until today to join the attendee list. More details here:

Chemical snippets

An interesting safety statistic

Is there really a higher incidence of accidents and incidents in companies with a higher than average number of people holding MBAs?

Of course correlation does not equal causality, but it is recognised among the SME community that MBAs are designed for people being trained to run very large companies. Once a company gets to a certain size, it seems to me that their management teams almost automatically start to see people as pieces on a chessboard, rather than as fully rounded individuals.

The way round this appears to be splitting larger organisations down into component teams, e.g. like the army which goes from platoon up to brigade, see

Near miss reporting can affect who is promoted

And the suggestion that near-miss reporting may give an advantage to a lucky manager rather than a skilful one who prevents near misses in the first place:

AI corner – 7 productivity tools

For once, a useful article on AI rather than a “why oh why” complaint that it’s either faking information or will take over jobs:, a list of ways to use AI productively.

I suspect that AI is just another tool, which will be a good servant, but a bad master.

Jobs (UK LinkedIn stats)

Regulatory affairs, 1,728 jobs; and Health and Safety, 48,590 jobs.

Ricardo have a number of chemical risk jobs, see

Process Safety Corner

Recent incidents:

A very thoughtful quote from the then Bishop of Grimsby in a sermon delivered during the memorial service for the 28 workers killed in the Nypro chemical plant explosion on June 1, 1974 (Flixborough)

The CSB have a good infographic on the importance of valve maintenance

And an interesting article from Ron Butcher on “Significant Injuries and Fatalities…A Message Not a Metric.”

Infographic of the week

From Mike Lever – where learning happens: infographic – where learning happens.jpg; and a related infographic from Amy Edmonson – how psychological safety relates to performance standards sketchnote.jpg

The Weekend Read

A short but important article on expertise:

The Weekend Recipe

The British asparagus season traditionally ends on St John’s Day, June 24th, so we’ve not got long to celebrate it.

Grace, our student, recommends a pasta and asparagus recipe from BBC Good Food, with a few tweaks to make the cooking even easier. The original is here:, but for Grace’s version, including pecorino cheese which she thinks goes better with asparagus than parmesan, read on…

Ingredients (for 2 people)

  • small tub of double cream, 142ml/ 1/4 pint
  • a bunch of British asparagus
  • 2 cloves of garlic, peeled but left whole
  • grated pecorino or parmesan cheese, 25 g/ 1 oz
  • shaved pecorino or parmesan cheese, 25 g/ 1 oz
  • tagliatelle, 250g/ 1/2 lb

Method: First, place your cream in a small saucepan with the cloves of garlic, and bring to the boil, then remove the cloves and leave the cream to cool. Bend the asparagus spears to find the breaking point, then snap them off. Discard the woody base, and then cut the tips off, as the stems and tips will be cooked at different times. Make the pasta according to the instructions on the packet, and when the pasta has about 4 minutes to go, add in the stems. The asparagus stems and tips will be floating on the surface of the water, so pick these out of the hot water before you drain it off (fork, strainer, tongs – the choice is yours). Then drain the pasta well and put on one side. Take the asparagus stems and grated pecorino or parmesan, and add to the garlicky cream, then either blitz with a hand blender, or pour into a jug blender and blitz until smooth.

To serve: place the cooked pasta in a large dish, add the sauce and asparagus tips, and toss to mix. Serve in pasta bowls, topped with the shaved parmesan.

Food nerd note – Grace isn’t sure if she’s using pecorino sardo or pecorino romano, as she’s buying it just labelled “pecorino”. We suspect it’s pecorino romano. The main difference between pecorino and parmesan is that it’s a hard sheep’s milk cheese, whereas parmesan is made from cow’s milk.

Reasons to be Cheerful

This week in our “It’s a Southern Thing” sequence, a couple on Southern cooking:

And a few variations on “Murphy’s law” for engineers:

And no need for builders to worry about Chat GPT:

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