It’s Semi-lockdown day 788, and the weather has gone from warm and sunny yesterday to cool, cloudy and rain due this afternoon, typical for the time of year. Grace, who helps out with art work and admin every Thursday, lives in the bottom of Luddenden Dean (our valley), and reckons it’s about 2 degrees cooler up here, even though she’s only about half a mile away as the crow flies.
We can even see the hawthorn or May trees down in the valley bottom in full bloom, while the one in our garden is stubbornly refusing to flower. Did you know that the saying “cast ne’er a clout til May be out” (“cast never a cloth”, that is don’t take off your winter clothes) refers to the tree and not the month? it makes sense because in colder areas or a cool spring, the tree will flower later.
In coronavirus news, you may have seen that the UK Government (and the EU, and many other countries around the world) intend to sign up to amendments to an existing treaty whereby the World Health Organisation would take charge during a pandemic. Is it me, or is that giving away individual countries sovereignty into some kind of world government by the back door?
In the meantime, there’s been a lot happening in chemicals this week.
Official consolidated versions of UK-REACH and GB-CLP
There are now official versions of these documents, which you can find here:
- UK-REACH https://www.legislation.gov.uk/eur/2006/1907/contents (many thanks to Simon Tilling for spotting this)
- GB-CLP – https://www.legislation.gov.uk/eur/2008/1272/contents (many thanks to Nicola Kaye for finding this following the UK-REACH announcement)
- GB Cosmetics https://www.legislation.gov.uk/eur/2009/1223/contents (well done again to Nicola!)
However, you will need to be careful when reading them, for example in GB-CLP:
- Annex VIII has been included in the consolidated version (as we suspected, although whether this means it will be retained is another matter).
- Annex VI has been removed, presumably as the MCL list is now published in Excel format on the HSE website.
- There are also issues around Titanium Dioxide, as neither EUH211 nor EUH212 appear to be within the document – presumably some kind of transcription error? (and these have all been spotted on a very quick reading, there may be more anomalies)
Northern Ireland Protocol changes and how it may affect chemical regulations
The UK’s Foreign Secretary, Liz Truss, announced this week that the UK will seek to unilaterally change the terms of the Northern Ireland Protocol, which in turn may affect the chemical regulations in force in NI itself (currently EU-REACH and EU-CLP, for example). However, the UK will also continue to negotiate with the EU.
The Daily Telegraph summarised the situation as being:
- Set up a new “green” channel for goods which are moving from GB to Northern Ireland and which are not due to leave the UK market. This will see red tape slashed and include the introduction of a trusted trader scheme.
- Enable businesses to choose between meeting UK or EU standards in a new dual regulatory regime.
- Give the UK the ability to decide on tax and spend policies across the whole of the country.
- Introduce penalties which will be imposed on any company which tries to abuse the new trading system.
However, it’s completely unclear at this stage if REACH, CLP, PIC etc will be involved in this, and what they mean by “choose between meeting UK or EU standards” is anybody’s guess.
Liz Truss also wrote an article on this, which doesn’t give a great deal of detail: Liz Truss_ These moves are not about scrapping the Protocol, but making it work.pdf
Watch this space….
ChemSec statement on Lead
Alan Ritchie rang me yesterday to pass on this link: https://chemsec.org/9-out-of-10-items-in-eus-new-product-database-contain-lead/ .
A quick glance at this article, titled “9 out of 10 items in EU’s new product database contain lead” demonstrates how ChemSec are being misleading and alarmist at the same time.
Misleading, in that the statement could easily be read as if the database contained all articles on the EU market are involved, although this is actually the SCIP database, which is only for chemicals containing SVHCs, that is it is a small subset of all articles on the EU market, of those which contain SVHCs. And given the fact that lead is a very useful and common chemical, we shouldn’t be surprised that it is the most commonly encountered SVHC.
And alarmist in that:
- there is no reference to amounts of lead, as we all know “the dose makes the poison”,
- or any reference as to whether the lead is present as metal, or as a (more soluble and therefore much more toxic) salt
- or any indication on how the lead might get out of the articles, either intentionally or unintentionally (because the lead has to be ingested in order to cause harm – in the environmental world, we call this the source-pathway-receptor model – if there is no pathway, there is no pollution)
Anyone who hasn’t a knowledge of chemicals might think they were about to be poisoned!
There was also a claim in ChemSec’s article that there is lead in pencils, which we challenged in an email this morning. It turns out that ChemSec are basing this claim on information from the ECHA website, but it refers to a chuck ring in a propelling pencil, and not all pencils. In my opinion, by failing to make the distinction between pencil types clear, ChemSec are misleading the general reader.
(I’m sure you are aware that the use of the term “lead” in normal wooden pencils is incorrect, it has always been graphite, originally mined in Cumbria and mis-identified as lead, and the name has stuck, even though it’s chemically incorrect. https://www.cumbria-industries.org.uk/wad/.
The HSE have just published some Agency Opinions on proposed Mandatory Classifications in the UK.
“The first batch of 23 GB MCL Agency Opinions are now available for download in the GB MCL publication table (.xlsx) (see https://www.hse.gov.uk/chemical-classification/gb-mcl-list.htm).
These GB MCL Agency Opinions relate to substances for which HSE (as the GB CLP Agency) published Agency Technical Reports under Article 37 of the GB CLP Regulation in June 2021.
At the time of publication, the classification and labelling proposed in these Agency Opinions has not been agreed and/or adopted in Great Britain“.
Keeping an Eye on ECHA
Did you notice the ECHA website was down unexpectedly on Monday 16th May, returning around 11am on Tuesday 17th May? They never publicised it as a planned outage, as far as I’m aware, or put up error information their twitter page (the usual communication method).
It’s a real worry if you rely on access to their information to do your work, and it seems to be getting worse. I can’t help feeling the SCIP database (around 7 million entries) can’t help stability either.
Immediately after Brexit, I wasn’t sure about the HSE’s method of displaying information on CLP and REACH, which is to hold the data in a downloadable excel file. This takes longer to download and then view on your own device than being able to view online like ECHA, but the upside is that their website is very stable and available most of the time.
REACH-IT update webinar
ECHA ran a webinar on Wednesday 18th May about the April 2022 REACH-IT update, which may be useful if you have a valid REACH-IT account (either you’re domiciled in the EU, or you have an EU legal entity and can access REACH-IT by that route). https://echa.europa.eu/-/reach-it-april-2022-release .
Jobs update (UK stats from LinkedIn)
Regulatory affairs 2,433 jobs and Health and safety 73,555 jobs, a slight decrease and increase respectively, but overall the figures are fairly stable at the moment.
Our friends at LB, formerly Lomon Billions, have a regulatory affairs position https://www.linkedin.com/feed/update/urn:li:activity:6929466010328543236/ .
Following on from recent discussions about hydrogen and how it can be used as a store of energy, a similar idea from the USA where carbon dioxide could be used as an energy store on an industrial scale: https://www.technologyreview.com/2022/05/03/1051644/carbon-dioxide-storage-energy-dome/ . This would be rather safer than using hydrogen, as carbon dioxide is not flammable!
And a new updated version of the periodic table from IUPAC https://iupac.org/what-we-do/periodic-table-of-elements/ (apparently the atomic mass of Niobium is slightly less uncertain than before).
Process Safety Corner
- Chicago, USA, 19th May – 4 students (school children) hurt in “some sort of explosion” when a school experiment went wrong: https://abc7chicago.com/students-hurt-chemistry-experiment-explosion-north-central-high-school/11865454/
- Gujarat, India – 25 injured in a firea t Bharat Rasayan Ltd’s chemical plant in Dahej: https://www.daijiworld.com/news/newsDisplay?newsID=959385
An excellent animation/ model demonstrating “sloshing” inside bulk tankers, and how baffles reduce this (the original post text is in Turkish, but you can use the “translate” facility on LinkedIn: https://www.linkedin.com/feed/update/urn:li:activity:6932562358116470784/ .
IT security – think before you link
In the chemical industry, we sometimes forget that we are responsible for critical infrastructure which may be of great interest to terrorists and hostile states.
The UK Government has set up a body called CPNI, the Centre for Protection of National Infrastructure, who have provided an excellent video on being aware of who you are connecting with on LinkedIn and other social media: https://www.cpni.gov.uk/security-campaigns/think-you-link
The Weekend Watch
Some good news on the pollution side of things (for a change):
- An enzyme has been discovered which breaks down polyethylene much faster than anything else found so far: https://phys.org/news/2022-05-enzyme-pet-plastic.html
- And people are working on making water-soluble plastic bags, see https://www.linkedin.com/posts/mehrtash-soltani-ph-d-2a15b323_mehrtashsoltani-ugcPost-6931234105678286848-OMN8 , although whether they have thought about the consequences of the chemicals which are released into the water is another matter (not to mention whether your bag might dissolve if you get caught out in the rain!)
Personally, I think that these types of technology would be best applied in a controlled environment (e.g. waste treatment stations) where the breakdown products could be handled appropriately, and reused.
The Weekend Recipe
After last week’s recipe for hollandaise sauce, it’s time to think about mayonnaise. As you probably know, mayonnaise is simply an oil in water emulsion, where the water comes from beaten egg yolk (which interestingly contains natural emulsifiers called lecithins), and the oil comes from vegetable oil. So in theory, making mayonnaise is nothing to be afraid of, although in practice there is a lot of worry and myth-making around it.
The key parts are to use eggs which are at room temperature; and to always have a spare egg or two on hand in case the mayonnaise “splits”, that is it forms a water-in-oil emulsion instead of the desired oil-in-water one; to add the oil veyr and to put in enough energy through beating to form the correct emulsion in the first place. Oh, and you don’t want to use a strong olive oil, it has to be something mild.
- Egg yolks
- Oil, eg sunflower, rapeseed or a very light olive oil (you can use part olive oil, part tasteless oil if you like)
- Flavourings, e.g. mustard, lemon juice, vinegar, salt and pepper
Separate a couple of egg yolks into a bowl (a glass one is useful to see what’s going on), and keep the whites on one side for another recipe. You can add some flavouring at this stage, eg lemon juice if you like, or you can add it at the end. If using mustard, add it at the start as it may help the emulsification.
With a balloon whisk (recommended) or wooden spoon, beat the egg yolks to break the sac and make them smooth. If adding an acidulant, you may notice the yolk colour lightens a little.
Then carefully add a very small amount of oil to the yolks and beat hard to form an emulsion. Continue adding oil drop by drop while beating hard. If you pause, the emulsion should be retained, and not split.
If your mayonnaise does split, then simply put it into a small bowl, clean out your main bowl thoroughly, break a new egg yolk into the bowl and start again, adding the split mayo instead of oil, and beating hard to keep the emulsion working this time.
Continue beating until the mayonnaise is at your desired texture, and add in any extra flavours.
Of course with the current sunflower oil crisis, we could be looking at mayonnaise becoming a luxury product, as it used to be when I was a girl!
Tips – you can cheat and do this in a food processor but it won’t be the same (you can use whole eggs in a food processor, I understand).
“proper” recipe with measurements here https://www.bbcgoodfood.com/recipes/basic-mayonnaise
Reasons to be cheerful
Our British Comedy classic is Mick Wragg of Lubrizol’s favourite Two Ronnies sketch, the Pub and Wallpaper
Many thanks to everyone who has contributed to the newsletter 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.
TT Environmental Ltd
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