It’s Day 539 of Semi-Lockdown, and the weather has definitely broken, it’s been raining on and off, and has turned cooler. It’s not stopping the courgettes from growing though. On Saturday, I made another batch of ratatouille for the freezer, which seems like a small victory in life!
Titanium dioxide labelling guidance published by ECHA
If you’re on the BCF mailing list, as several of our readers are, you will have already received a notice about the new Titanium Dioxide labelling guidance which has just been published by ECHA: guide_cnl_titanium_dioxide_en.pdf
Many thanks to Kerry Knowles of CPG Europe and Aaron Turrall of FSi Ltd for passing this link on. Aaron notes that this doesn’t seem to be available on the ECHA website, and I’ve also searched and it brought up an empty “newsletter archive” page.
Have you ever known ECHA do a comprehensive guidance document like this for one substance reclassification in an ATP so specifically?!
From our experience, companies are doing all sorts of approaches on the liquid mixtures. We have some labelling with EUH211, some labelling them with EUH212 saying they are viscous liquids and so to be considered as though they are solids, and then some not labelling at all saying the consistency of the product means the risk is not present, “expert judgement”.
There are member states issuing their own opinions too, all different. The German authorities published their opinion which was very detailed and seemingly again their own take on things.
It looks like the Titanium Dioxide issues just keep coming.
Single Use Plastics labelling in the UK
Colin Pratt emailed me about this issue last week, and you may have seen it as a discussion topic on the CHCS forum, so apologies for being a bit late with this information. If you are not on the CHCS forum, you can sign up here: https://chcs.org.uk/chemical-hazards-forum .
Briefly, there was an EU directive requiring specific labelling on single-use plastics which was published on 17th December 2020, coming into force 20 days later, and therefore outside the scope of Brexit, see https://eur-lex.europa.eu/legal-content/EN/TXT/PDF….
As a directive, this does not automatically apply to member states, who are required to put it into their own local laws in order for it to be implemented. I am unsure as to whether this has happened for Northern Ireland yet.
These new labelling requirements cover nappies, feminine hygiene products, some types of tobacco products, and single use plastic glasses (the full list is in the Directive, only 10 pages long). There is a requirement for a new symbol comprising two boxes, side-by-side, showing “don’t put this down the toilet” and “may harm aquatic creatures” (I’m sure there’s a better description!).
Zuzana Horovka of Bartoline commented via email: Luckily we have been able to action on this quite quickly, but I noticed that although the legislation have fair bit of requirements on the logo appearance, it’s very hard to find it in decent format/resolution for download. I had our design agency to create one for us, and thought I share it with you and anyone who might need it. . EU Plastic in Product logo – 25-03-2021.pdf . Many thanks to Zuzana for her generosity.
The EU have also provided eps format files here: https://ec.europa.eu/environment/topics/plastics/s…
Via the CHCS forum, Mel Cooke of Alchemy Compliance highlighted that there is an earlier Directive, 2019/904, covering single use plastics, which came into force on 5th June 2019, and Nicola Kaye of REACH Law confirmed that this has been adopted as part of the Pollution Prevention and Control Act, see https://www.legislation.gov.uk/uksi/2019/1417#text%25253D2019%25252F904, but Nicola has searched the UK legislation.gov.uk website and has not been able to find any reference to the new Directive.
Even if there is no information about Northern Ireland yet, it would be prudent to assume that this Directive will have to be implemented under the terms of the Withdrawal Act and the Northern Ireland Protocol, and ensure that any Single Use Plastics you are selling there are compliant with this new label information.
It has recently been announced that the vaccine passports idea for gatherings over a certain number has been scrapped for England, see https://www.bbc.co.uk/news/uk-58535258 , although it is being enforced in Scotland, see https://www.bbc.co.uk/news/uk-scotland-58422607. And, frankly, if anyone in government in Westminster or any other part of the UK, tells me the time, I will check my phone (as I no longer wear a watch), so I wouldn’t be surprised if the idea comes back into England.
On a personal note, I spoke to a friend a week past Saturday, he was in his car and I was outside, who has since tested positive for Coronavirus. Eek! We found out on Friday night, and I remembered on Saturday afternoon that I’d chatted to him briefly.
So, despite being double-vaccinated, I thought I’d better check myself out in case I’ve picked it up. It’s the Chemical Regulations Self Help Group tomorrow, Tuesday 14th September, so the last thing I want to do is infect our lovely members who’re braving the first live meeting since Spring 2020.
This saga involved checking what to do online on the government website at https://www.gov.uk/order-coronavirus-rapid-lateral…, checking to see if I had coronavirus symptoms, https://www.nhs.uk/conditions/coronavirus-covid-19… (high temperature, a new continuous cough, or loss of taste or smell).
As I didn’t have the main symptoms, just felt a bit tired (admittedly after a rather busy week), I needed to pick up lateral flow tests, so checked out the Government website which shows nearby pharmacies who have them, see https://maps.test-and-trace.nhs.uk/ . I then drove out to the nearest pharmacy… only to find it closed! I ended up getting 2 packs from our local Asda pharmacy, which is actually nearer, and open.
There are 7 tests in each pack. The tests involve taking a swab from where your tonsils used to be (if you’re old, like me) or your actual tonsils, if you still have them; then from your nasal passage; transferring the swab contents into a fluid medium, and dropping it onto a reader which looks like a really cheap pregnancy test, then waiting 30 minutes.
The tests looked such a faff that I couldn’t be bothered to take one until Sunday, which proved negative, and again this morning, which is also negative. All good? Not really, when you read the instructions, it says “If you get a negative result, it is likely you were not infectious at the time the test was taken. A negative test result, however, is not a guarantee that you do not have COVID-19“!
I will take a third test tomorrow morning before our Self Help Group meeting, just to be on the safe side.
Apparently, there’s a chap who checks published sugar structures: https://pubs.acs.org/doi/full/10.1021/acscentsci.1c00660. He claims that an incorrect structure gives him a headache! A rare talent, I think, never really having been able to “see” optical isomers very well.
Reasons to be cheerful
This week, there is a stushie (pronounced “stooshie”, a good Scots word) about the rather adult comedian Roy “Chubby” Brown being banned from playing a gig in Sheffield, see https://www.itv.com/news/calendar/2021-09-10/roy-c… .
So in the interests of non-political correctness, we’re going with some clips from him (do NOT watch if you are easily offended or don’t like adult humour). The first clip is, rather topically, “My Corona”: https://www.youtube.com/watch?v=MAP1bZ56nVQ (based on the Knack’s “My Sharona”, the original is here: https://www.youtube.com/watch?v=bbr60I0u2Ng ). And our second clip is another musical selection (just as rude): https://www.youtube.com/watch?v=x3awoM0Ue8Q .
Many thanks to everyone who has contributed to the newsletter today. 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 and your family and friends are all safe and well, and looking forward to whatever challenges the week ahead may hold, and I’ll write to you again on Wednesday.
TT Environmental Ltd