It’s Semi-lockdown day 795, and it’s turned quite cool up here, but the good news is that the rain means there are plenty of insects for ground nesting birds like lapwings, curlew, redshank, oystercatcher, and of course grouse. I only hope we don’t get hail in early June like we did a few years ago, which had such large hailstones it killed many chicks, and even a few adult birds sitting on nests.
Can you help?
Mark Selby with his REACHReady hat on is trying to prepare some practical guidance for GB REACH where existing EU guidance may not yet be sufficient. Has anyone got specific examples of areas that may need clarity, or more importantly, examples of any rejections of GB dossiers or problems with submissions. This will of course be anonymous. (email@example.com )
If you have grandfathered any substances into UK-REACH, you may have received an email from the HSE directly on this issue.
The HSE have published yet more MCL Technical reports:
“A new batch of 10 GB MCL technical reports is now available for download at the end of the GB MCL publication table (.xlsx).
These GB MCL technical reports relate to substances for which the Committee for Risk Assessment (RAC) published a RAC Opinion under Article 37(4) of EU CLP during 2021, based on information submitted under the EU CLP Regulation. The scientific information supporting the RAC Opinion is evaluated under the GB MCL system.
At the time of publication, the classification and labelling proposed in these technical reports has not been agreed and/or adopted in Great Britain.”
It looks like there will be some more in June. It will be interesting to see how many of the EU new Harmonised Classifications in the 17th and 18th ATP make it into UK law.
A new feature in the newsletter, where we challenge misconceptions and misleading statements (it was nearly called “NGO naughtiness” as the NGOs are often involved). Feel free to send in your examples!)
We’re starting with a Swiss NGO. Alison Potts, our Regulatory Consultant at TT Environmental writes:
Systematic evidence on migrating and extractable food contact chemicals: Most chemicals detected in food contact materials are not listed for use
This link made me realise that the NGO concerned have failed to acknowledge the fundamental reason why the official database only contains hazardous substances, which is because it is only for those chemicals, and deliberately excludes those chemicals which are known not to be hazardous, or which are suspected not to be hazardous.
In other words, the regulators are “managing by exception”, that is they are assuming most chemicals used in food contact materials are not harmful, and prioritising those which are or which are likely to be, on the basis of their chemistry and human experience and knowledge.
This approach is also what ECHA are doing with the SCIP database, as we discussed last week. They are focussing only on articles containing SVHCs, and ignoring the ones which don’t contain those (potentially) hazardous substances. If we don’t focus on what’s really nasty and treat every industrial chemical the same, our entire society would grind to a halt!
Yet this Swiss NGO, and ChemSec are deliberately ignoring the scope and purpose of these regulatory databases in order to scare people, as a routine tactic.
In my correspondence with ChemSec over clarifying the “lead in pencil” issue (TLDR: a few propelling pencils have lead inside them, which ChemSec did not make clear), a ChemSec employee wrote this:
“Our article does not consider if there’s real life exposure to lead in any of the products in the database, not only to your example, as we don’t believe exposure is a good approach to determine the potential problems of hazardous chemicals.
You must not have followed ChemSec for long? 😊
I’d be interested to know what you think of that article, as it certainly didn’t do my blood pressure any good.
Jobs update (UK stats from LinkedIn)
Regulatory affairs 2,359 jobs and Health and safety 69,160 jobs, a slight fall in both disciplines. But there are still plenty of good quality jobs around, particularly in Regulatory Affairs.
You may have seen that the prospect of grain shortages due to the Ukraine invasion is leading to suggestions that we could use gene editing to improve crop yields, another barely-tested methodology of dubious value: https://www.telegraph.co.uk/news/2022/05/22/gene-edited-crops-sped-ease-ukraine-food-crisis/ – what could possibly go wrong? and why the haste to bring in these novel technologies, whether in vaccines or in crops? The end does not justify the means.
Speaking of ethics, I came across this Ethics Club poster ethics club poster.pdf from Simon Cassin of Ouch Training Team Ltd, https://www.ouchtraining.co.uk/ . I’m not sure item 5 applies to making hazardous chemicals!
Process Safety Corner
- 2 dead, many injuries at a biodiesel plant in Spain: https://www.linkedin.com/posts/george-mickiewicz-a7799746_dos-muertos-y-250-ni%C3%B1os-desalojados-tras-activity-6935642353441394688-qIqS?utm_source=linkedin_share&utm_medium=member_desktop_web
- no injuries but significant damage at grain silo explosion, Peoria, USA: https://www.explosionhazards.co.uk/update-estimated-2m-in-damages-after-major-grain-explosion-at-peorias-former-adm-plant/
- one dead, 9 injured in refinery explosion, South Korea: https://www.linkedin.com/posts/mohammed-al-saraf-mimarest-70166215_refinery-explosion-kills-one-injures-nine-activity-6935131127284162560-C9ws
- no injuries but damage – grain dryer explosion, ethanol plant, Ohio https://eu.coshoctontribune.com/story/news/local/2022/05/21/explosion-rocks-coshocton-ethanol-plant/9870341002/
A reminder that there have been 6 major fires in the chemical industry in Gujarat since 24th December last year, averaging 1 per month – https://www.linkedin.com/posts/kompalli-ravishankar-33b053b5_ani-on-twitter-activity-6932552562218782720-mvTo?utm_source=linkedin_share&utm_medium=member_desktop_web
A very good comment by Alicia Gilpin on the gap between hands on engineers and university educated engineers, and why it needs to be closed: https://www.linkedin.com/posts/alicia-gilpin-ali-g-8675b322_at-some-point-the-separation-between-the-activity-6934986402732404736-Wxc4 .
Two of the best process engineers I know, in terms of being able to actually build, run and maintain plants (and improve the design) are an instrumentation engineer, (chemicals sector) and someone who originally trained in agricultural chemistry (whisky distillation), and it has been a privilege to have worked with them both.
If you are interested in, or concerned by, the idea of “Safety II”, a new way of approaching safety, there is an article here on Science Direct (open access for a couple of weeks) – https://www.sciencedirect.com/science/article/pii/S0925753520304446?dgcid=author .
And an article of moving away from the “zero accident” culture for occupational health and safety: https://www.ohscanada.com/opinions/moving-away-from-zero-busting-the-no-harm-myth-in-the-workplace/ .
The Weekend Watch
The CSB have published a safety video on the dangers from allowing incompatible chemicals to come into contact each other, which resulted in the incident at AB Silicones:
The Weekend Recipe
We’re nearly at the Platinum Jubilee Weekend, so I thought a celebratory recipe might be in order.
It’s actually been quite disappointing to see the “Platinum Pudding” winning recipe, https://www.fortnumandmason.com/media/fortnums/blogpost/pdf/jemmas-lemon-swiss-roll-amarettii-trifle-winner-2.pdf because it’s a really complicated trifle, and if you don’t like lemons, or you can’t get hold of them (my local farm shop is sold out), it would be pretty tricky to make.
I consider myself to be a reasonable home cook and baker, but it just seems like too much effort, and bit too “cheffy” (home made ratafia biscuits?). It is possible to cheat a bit with this, e.g. buying lemon jelly, and using ready made swiss rolls, but even then it’s still going to take quite a lot of work.
So I thought I’d look at making a crown cake. Funnily enough, there don’t seem to be many versions going around, there’s a professional style one here (the top tier): https://www.hobbycraft.co.uk/ideas/How-to-Make-a-Platinum-Jubilee-Showstopper-Cake.html, but I wanted something homely, and easy to do, and which would be based on the Imperial State Crown, which is actually made of a platinum base.
A neighbour’s son’s birthday yesterday gave me the opportunity to experiment, so here goes (it is a bit of a work in progress, so if you try it yourself or have any ideas please email them in!)
Platinum Jubilee Cake
The idea is to make a Victoria Sandwich cake, and decorate it to look like the Imperial State Crown. The fabric inside the crown, the Cap of Maintenance, is purple velvet with an ermine trim, but you could use red colour instead as this is sometimes used – this is the cake itself. Then use sweets to make the crown metal pieces and jewels.
Make a Victoria Sponge in 2 tins, with either 3 eggs or 4 eggs, and allow to cool thoroughly.
Whip half a pint/ 250 ml of double cream until stiff.
Icing for the cake top (sides optional): make some glace icing with icing sugar and blackcurrant cordial (I used Schweppes, Ribena is fine), which makes a pinkish icing. I added in some dried bilberry to make a purple colour, which gave the icing a wonderful tangy flavour. It’s a (rather expensive) health food but gives a nice colour and flavour. You could use dried blackcurrant instead. You can use purple food colouring, but you need a lot. Alternatively, use ready made purple fondant icing. (If making a red cap, colour with red icing instead).
Jam for the filling – a purple jam like bilberry (if you can get it) or blackcurrant
Optional, if you haven’t any jam of the flavour you want – make some butter icing with 3 oz butter and 3 oz icing sugar, and add in some dried bilberry or blackcurrant.
Take the two layers of cake and sandwich together with jam and cream, or jam and plain butter icing, or flavoured butter icing and cream. If making a red cake, use strawberry or raspberry jam instead.
Then ice the top of the cake with the coloured glace icing, and fill in the sides with the remaining cream (as if making a crumb coat). (You could use plain butter icing instead of cream, if you’re worried about the cream melting if it’s a warm day). If you have enough glace icing, or you’re using fondant icing, feel free to cover the cake sides as well as the top. The glace icing will have to be quite stiff so it doesn’t run down the sides of the cake (unless that’s the effect you’re after).
Now the fun stuff – decorations! The crown itself is the circle of metal outside the cap, which has crosses and fleur-de-lys and lots of jewels on it, then you have the arches (4 on the UK crowns, 8 on continental crowns like the Dutch), then a sphere, the monde (symbolising the earth) on top of the arches, and another cross on the top, called the cross pattee.
I used curly wurly bars (which bend) to make the crown base and arches (a malteser under each arch to raise it – my curly wurlies were all broken, probably why they were so cheap from Amazon, so I was improvising). I made 2 mondes, by covering a malteser in icing and then rolling it in small silver balls, so used them both on the cake, but ran out of time to make the cross pattee, and cross or fleur de lys for the crowns. However some large wine gums gave the effect of jewels, and overall I think it looks all right, and it should be good to eat. The finished cake: Jubilee cake version 1.pdf
It would be good fun to get children to help decorate the cake, depending on the degree of accuracy you want and how many sweets you have, as
some most will inevitably get eaten.
Tips: you can cheat and cover a bought cake with bought purple or red fondant and decorate with sweets. Or instead of using sweets, you could print out and make a paper or card crown, e.g. simple ones https://www.firstpalette.com/printable/princess-crown.html, or more complicated: https://www.firstpalette.com/printable/king-queen-crown.html which the children could colour in. Sweets can also be added to the cake as well, of course! To cover the malteser with icing easily, I speared it carefully with a skewer, dipped it in the glace icing then rolled it in some silver balls – really easy to do.
My final tip is to do this on a day off or an evening when you can take your time and really have fun with the decorating. More is definitely better for this design!
Reasons to be cheerful
Today’s Reason to be Cheerful is based on the Platinum Jubilee, it’s a 15 minute colour news report (from the days when news was available in the cinema) of the Coronation,. This took place on 2nd June 1953, more than a year after The Queen’s accession:
I do wonder what Her Majesty thinks of reigning for so long, after all it has only been possible because her late Father, King George VI, died prematurely.
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, on Wednesday because of the two day Platinum Jubilee Bank Holiday on Thursday and Friday.
TT Environmental Ltd