Happy Friday! It’s Day 193 of Lockdown/ Semi Lockdown here in the UK, quite misty with us, and definitely getting colder.
Meg, our old dog, has come into season, and I had a Facebook message from a neighbour asking if we’d lost her for a bit. She’d run off while we were out for a walk, and was looking at the farm dogs (she’s no idea why she’s interested in them). So it’ll be lead walks for a while, as the last thing we need are cocker spaniel/ collie puppies!
Breaking news – UK REACH raised in Parliament
Neil Hollis of BASF reports that concerns about UK REACH have been discussed in Parliament, see https://www.linkedin.com/posts/neil-hollis-44733130_haggisuk-on-twitter-activity-6717479989316485120-0P-q .
If you or your family members are out and about on foot as we enter the dark part of the year, it’s worthwhile making sure you have hi viz or light coloured clothing.
A very scary example of how “invisible” children can be in muted clothing:
(and yes, the child is standing in exactly the same place in both photographs).
Less pessimistic coronavirus information
The Daily Mail (not everyone’s favourite newspaper) has produced some graphs showing good news about Coronavirus which haven’t been widely publicised, see https://www.dailymail.co.uk/debate/article-8791859/BEN-SPENCER-analyses-good-news-graphs-experts-didnt-you.html
Methanol – new restriction in windscreen wash in the pipeline
Our hand sanitiser correspondent, the indefatigable Adam Hunniford of PIP Chemicals, writes:
Interesting observation as we come into screenwash season: https://ec.europa.eu/growth/content/new-restriction-methanol-car-windscreen-washing-fluids_en
I have known about this but never really thought in context of hand sanitiser. In that case, as you know, 200ppm is the guide (0.02%). But HSE won’t enforce, it is only ‘guidance’. As a result we are well aware that IDA is being used and we will expect levels of a couple of percent, where it is used. So the stupidity becomes that these hand sanitisers, which HSE won’t act against, would be considered to be 30-50x the acceptable level for a screenwash and would immediately be removed. How silly is that?!
Infographic – the SCIP database
You may have spotted my weakness for a good infographic, and ECHA have produced an interactive one that tells people what their SCIP duties are at various points in the supply chain, see https://echa.europa.eu/scip-infographic .
Poison Centre Notification update
Victoria Sayer of John Hogg Technical Specialities writes:
Just wondered if anyone had picked up with you on poison centres and Brexit.
The lastest ECHA guidance makes it clear that UK companies cannot make notifications once we leave….the obligation fall on the importer.
Joss (North) queried this with ECHA and got the following reply:
The CLP Regulation only applies to actors established in the EU/EEA and therefore non-EU companies are not directly bound by this legal act. The responsibility for fulfilling the obligations of Article 45 and Annex VIII to the CLP lies with the European importers and downstream users (DU). UK withdrew from the EU but a transitional period applies until the end of 2020. According to the information available at the moment, from 1 January 2021 CLP will not apply in the UK and UK companies will no longer be subject to the notification obligations and will not be able to submit a notification dossier by using their ECHA account. An exception could be Northern Ireland on the basis of the final text of the Northern Ireland Protocol.
Should the customers of the UK company in the EU Member States become EU Importers, they will have to submit a notification themselves before importing the mixture into the EU, in each country where they place the mixture on the market (note that import is deemed to be placing on the market). Notification made by a UK supplier before 1 January 2021 will not suffice for the EU customer to fulfil their obligations.
We confirm that the information submitted by UK companies before the Brexit date via the ECHA Submission portal, will not be automatically deleted and will remain in the data base. After the Brexit date, UK company will not have the possibility to submit PCN notifications anymore.
I am sure may importers from UK companies will not be willing to do the poison centre notifications….I wonder how many UK companies have picked up on this….
And a possible solution for PCN
I have been discussing Poison Centre Notification with the ECHA staff in their Poison Centre LinkedIn group, coming at this problem from the angle of whether a UK-generated UFI can be used after Brexit, and discovered that UK (and other non-EU companies) can appoint a representative in the EU to make PCN on their behalf.
If you appoint a company in the EU, they will generate a UFI for you, using their VAT number etc, and make a voluntary submission on your behalf. Then you supply your product to companies in the EU with this UFI on the label. Your customer will need to create their own PCN, either using 100% of your mixture, with its UFI, if they’re only using or reselling; and if they’re using your mixture in their mixture, make a second PCN using your mixture with its UFI at the appropriate percentage.
That way, your info has been deposited with ECHA’s portal, but your downstream user doesn’t have the full compositional information.
Section 4.2.5 of this guidance applies in detail: https://echa.europa.eu/documents/10162/13643/guidance_on_annex_viii_to_clp_en.pdf/412c5874-f8ec-cf52-fe1e-2fbe08fe2d11
Warning – this guidance is going to be updated as part of the PCN changes, but as I was pointed towards it by ECHA’s team in their PCN group on LinkedIn recently, I think it should be OK. But it will be worthwhile checking the updated guidance anyway.
There is a draft available here, but I always recommend treating drafts with caution as there can be significant changes once they are finally published (voice of experience): https://echa.europa.eu/documents/10162/23047722/guidance_on_annex_viii_to_clp_v40_peg_en.pdf/2a2792ee-d094-8397-8d65-d38852faddf7
The Weekend Recipes
Aaron Turrall of FSi Ltd was inspired by my chickpea curry recipe the other week to send in some of his favourite lentil recipes. The two curries look good hearty meals for the cold weather, and you can always serve one of them alongside a meat curry if you’re a carnivore, although I find lentils are quite “meaty” anyway.
Not to be outdone, Sarah, my admin and marketing lady, has provided her husband’s grandfather’s lentil soup recipe as well. (We could have our own competition – Great British Lentil Recipe challenge, anyone?)
Aaron writes: With each of these recipes, rinse the lentils and pick out any bad ones. No need to soak though ☺️.
Aaron’s Mum’s Lentil Curry
- 3 tablespoons vegetable oil or ghee
- 1 large onion, chopped
- 2 garlic cloves, chopped
- 1 inch ginger root or 1 tsp ginger powder
- 1/2 teaspoon chilli powder
- 1 teaspoon ground coriander
- 1 teaspoon ground cumin
- 1 teaspoon paprika
- 90g/ 3 oz red lentils
- 3/4 pint vegetable sotkc
- 250 g/ 8 oz chopped tinned tomatos
- 50 ml/ 2 fl. oz. coconut milk
Heat the oil, add the chopped onion and fry for 3 minutes. Stir in the garlic, ginger, chill and spices and cook for 1 minute. Stir in the lentils, stock and tomatoes, and bring to the boil. Simmer for 30 mins. Stir in the coconut milk before serving.
Aaron’s Mum’s Vegetable Dhansak
- 2 onions, chopped
- 2 sweet potatoes, cut into chunks
- 2 carrots, sliced
- 2 large garlic cloves (crushed)
- 1 & 1/2 teaspoon ground ginger
- 1/2 reaspoon chilli powder
- 2 heaped teaspoons ground cumin
- 2 heaped teaspoons ground coriander
- 1/2 teaspoon ground turmeric
- 1/4 teasponn cayenne pepper
- 200g red lentils (washed)
- 700 ml vegetable stock (add more if needed)
- salt and pepper
- Can of chopped tomatoes
- optional – cauliflower, fine green beans
Method: Fry onions, add spices and sweet potatoes and carrots. Add, garlic, red lentils and tomatoes, stock and simmer. Add pineapple just before serving.
Aaron also recommends trying Lentil Brownies, there is a small amount of flour in them but you can use gluten free. He writes: I did make lentil chocolate brownies the other week, they were really nice too. I was sceptical that it was going to work if I’m honest. Recipe at https://www.veganricha.com/lentil-brownies/ .
Robbie McLellan’s Grandfather’s Lentil Soup
Soften 2 white onions and a leek in salted butter. Add 3l water. Add 4 veg stock pots, 2 cups of red lentils. Grate in 2 large carrots. Bring to the boil. Simmer for 40 minutes.
I don’t believe Robbie’s grandfather would have used vegetable stock pots, but apart from that the recipe seems traditional. You can use other forms of stock, traditionally a ham bone or cooked mutton bone would be used.
Reasons to be cheerful
Morecambe and Wise with Shirley Bassey, from the 1971 Christmas special: https://ok.ru/video/40844659271 .
And Ice Cream (many thanks to Alan Ritchie for that clip).
Thanks to everyone who has contributed to the newsletter today, and, 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 lovely weekend and manage to take time off from work or your projects to relax with your family and friends (as much as we can in the circumstances).
TT Environmental Ltd
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