Chemicals Coffee Time Monthly, September 2024
Janet Greenwood
Helping Regulatory Affairs and H&S(E) professionals comply with chemical regulations. CLP & SDSs | COMAH | EPR IPPC
Dear Reader,
September was a very busy month in terms of regulations (particularly from the EU), so let's get right on with the news.
Hearing from the HSE, DEFRA and the UK
Scam letter warning
A warning from the HSE about scam letters purporting to come from their head office about Electricity at Work, see https://www.dhirubhai.net/posts/health-and-safety-executive_scam-alert-we-have-received-reports-of-activity-7242548556325097473-BLUB.
GB Authorisation opinions published for chrome plating operations
A list of chromium authorisation opinions under UK-REACH is out now, see https://content.govdelivery.com/accounts/UKHSE/bulletins/3b67ceb
EU-BPR consulation on pyrithione zinc - reminder to comment
The HSE have spotted an EU-BPR consultation on the possible substitution of pyrithione zinc, and recommend that anyone interested in this substance should comment on the EU's consultation, see HSE's email here: https://content.govdelivery.com/accounts/UKHSE/bulletins/3b57f4b and consultation link here: https://echa.europa.eu/current-candidates-for-substitution-and-derogations-conditions/-/substance-rev/77601/term . Note that the consultation ends on the 4th October.
The HSE email states that "Please note this consultation and its outcome are not applicable under the GB Biocidal Products Regulations (GB BPR)." However, given the close links between the EU and GB, if you are using this substance or products containing it, you may wish to make your views known to ECHA.
GB Biocides
If you are on the HSE's Biocide mailing list, you may have received a stern email recently about the number of biocides which are due to be withdrawn from the UK marketplace, see https://content.govdelivery.com/accounts/UKHSE/bulletins/3b1cef2 . As usual, you need to download the data in excel form from this page: https://www.hse.gov.uk/biocides/uk-article-95-removal-list.htm?
Some interesting statistics - there are a total of 2727 biocide/ product type/supplier combinations, which sounds like a massive amount; although it does break down to 114 individual substances across 630 suppliers (or 4.3 substances per supplier on average).
If you are unsure whether a biocide you are using is being supported by your supplier past the 3rd March 2025, you can check from the spreadsheet. I know that biocide suppliers will be waiting to see if there is sufficient demand for their products to re-register them, but if enough end users express interest then that should help retain as many biocides on the market as possible.
Notice to exporters - customs declaration service
If you export from GB, there's been an update about the Customs Declaration Service, see https://www.gov.uk/government/publications/notice-to-exporters-202419-customs-declaration-service-cds-exports-important-information
Keeping an Eye on ECHA and the EU
EU-CLP Legislative Act (lack of) progress
There was no further progress on the EU-CLP Legislative Act from industry's perspective. We are still waiting for its official publication in the EUR-Lex journal. In the meantime, we have the unusual spectacle of its Corrigendum document being published first, at least in draft!
EU-CLP Corrigendum published
Huge thanks to Aaron McLoughlin who has shared this news on LinkedIn, see https://www.dhirubhai.net/posts/aaron-mcloughlin-1a86281_meeting-agenda-updates-activity-7237035695322599425-siji .
Thanks also to everyone else in industry and chemical trade bodies who emailed me about this too - I really appreciate you taking the time to let us know, and "better to hear twice than not at all". We have such a lovely group of readers, I'm very grateful to you all.
The corrigendum document is at https://www.europarl.europa.eu/meetdocs/2024_2029/plmrep/COMMITTEES/ENVI/DV/2024/09-04/2022_0432_COR01_EN.pdf which I have definitely NOT read in Ali's absence.
A reader writes: I haven’t had chance to read the whole text, but did look at Article 2 and the application dates – the references to the parts which caused the confusion with the application dates - this has been amended - formatting for fold out labels is brought in after 18 months (now point (4) not (3b), the other label formats after 2 years. Changes to Annex VIII now in Annex IV and also apply after 2 years, as Article 2 (3) now refers to Annex IV.
Jan Robinson of AISE also writes:
The two content changes I immediately spotted were in Article 48 (the additional statement for consumers has been shortened slightly - some might not consider that substantive though) and in Annex I section 1.2.1.6 (additional elements added to the front page of a fold-out label - possibly correcting an accidental omission from the provisional agreement text?). I'd be delighted to hear of any others that your readers noticed! Overall it's nice to have a version of the text where at least the numbering etc. is fixed, although it's not completely free of typos (e.g. "eproductive toxicity" in Annex II ??). Unfortunately the transitional provisions have not been made a lot easier to read/understand - that would have been a plus!
Many thanks to our readers for spotting this. It's really good to get the timelines sorted out. If you have the time to go through this and see any other significant changes, please let me know and I will include it in another newsletter.
Talc proposed reclassification
News in after close of play on the 26th September from one of our lovely readers, who writes:
Not sure if you have seen this, as didn't make ECHA Weekly but a summary of the RAC meeting is on the ECHA news site.
There are links to the minutes and full list of decisions, but the one highlighted is Talc. RAC opinion agrees with the proposal for STOT RE but proposes a more severe classification for carcinogenicity. Not just for the inhalation route, covers all routes and not just based on the rat data but also included limited evidence from humans.
You can find out more at https://echa.europa.eu/-/highlights-from-september-2024-rac-and-seac-meetings.
Many thanks to our reader for the information.
The ECHA website states: RAC adopted 13 opinions on harmonised classification and labelling of hazardous substances. One of these was on Talc, where the committee recommends adding the following classification:
RAC assessed a vast database of information on Talc and concluded that there is sufficient evidence that exposure to Talc may cause cancer. This conclusion was based on limited data from animal studies (lung tumours in female rats exposed via inhalation) and human studies (ovarian tumours in women following genital/perineal use).
I do wonder how accurate the human data is - whether it is from talc contaminated with asbestos, or pure talc.
Update to REACH test methods regulation agreed
Gabriele Scibilia and his team at Flashpoint Srl have spotted that the EC has adopted an update to the REACH test method regulation, EC) 440/2008, on the 23rd September . It's to align the Regulation with related legislation, particularly CLP, and add in new test methods.
We will provide the links once publication has actually happened, although Gabriele's webpage has links to the drafts in Italian if you want an early warning about what's included (google translate is your friend!): https://www.flashpointsrl.com/news/2024/09/25/19535/chemicals-aggiornamento-dei-metodi-di-prova/ .
Many thanks / grazie to Gabriele and his team for spotting this.
Proposed update to EU-packaging regulations on reusing transport packaging
Martin Engelmann of IK Industrievereinigung Kunststoffverpackungen e. V. (the German Plastic Packaging Association), has a very thought-provoking article about how these proposals are "a massive overreach" - https://www.dhirubhai.net/posts/martin-engelmann-615312a8_reuse-obligations-for-transport-packaging-activity-7245002691645456384-HgMW .
Around the World
Did you know Melissa Owen has an online crash course in the various forms of REACH being implemented in Latin America? https://www.dhirubhai.net/posts/melissa-owen_chemical-registration-in-latin-america-ugcPost-7244770863437242369-VPAQ . This and other courses from her are available here: https://ambientelegalacademy.teachable.com/p/home . (and no, I'm not on any commission!).
Infographic of the Month
Another cracking infographic from Tanmay Vora - the difference between efficiency and productivity https://www.dhirubhai.net/posts/tnvora_leadership-sketchnote-sketchnotes-activity-7237396890718240768-Foqt
The Weekend Read
An excellent graphic novel from Ramin Abhari, P.E. , this time on the Bhopal disaster: https://www.dhirubhai.net/pulse/butterflies-bhopal-ramin-abhari-p-e--htawc . This is just one of a sequence of graphic novels on major accidents he has produced, all of them thoroughly recommended.
The Weekend Recipe
I made this chutney a few weeks ago as a way of preserving our precious courgettes, they are the star, and then I added in vegetables we happened to have in the fridge at the time.
Ratatouille chutney
Method: prepare the vegetables (chop to slightly larger than the size you want in the chutney - the vegetables will reduce in size during cooking), and place in a large stainless steel pan over a low heat. Add the vinegar, stir in the sugar until dissolved (shouldn't take too long), and add the flavourings. Bring to the boil, and simmer for about an hour and 20 minutes until the liquid is mostly absorbed and the volume has reduced significantly.
Pour into sterilised jars (use your jam funnel, which I usually forget to sterilise and have to wash with boiling water from the kettle at the last minute), and put the lids on while still hot. Mature in a cool dark place for at least 1 month, ideally 3 months, before using. I got a 2lb 12 oz yield (2 bonne maman jam jars and 1 Hartleys jam jar full).
Findings: this tastes good even before maturing, so I'm hopeful it's going to be really nice once it's been matured. With hindsight, 12 oz sugar/ 3/4s of a pint vinegar would have been enough for the volume of vegetables, as it was quite "wet" and took quite a bit of time to boil off. Having said that, the level of sweetness may be one reason why it tastes good . Time will tell.
Reasons to be Cheerful
September's videos were a bit of a "mixed bag", as I did my best to keep cheerful during a very busy time personally and at work:
Many thanks for reading this LinkedIn newsletter, and many thanks to everyone who has contributed, through sending in links, queries, comments etc. If you have anything you'd like to share, please email me or send a DM, and I'll do my best to include it in the next Chemicals Coffee Time Monthly.
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Look forward to chatting to you in late October or early November.
Kind regards,
Janet
Janet Greenwood, TT Environmental Ltd
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Chemist interested in human health
1 个月Thank you Janet Greenwood for keeping informed.
Principal Process Engineer
1 个月Hi Janet, Thanks for highlighting my work in your informative monthly newsletter.
Thanks so much for all you do to keep us all informed Janet Greenwood - humbly trying to do the same for my region of Latin America - appreciate you and the support!