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SUMMER 2017

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UK and World News Supply Chain Process Safety Solvents Industry REACH

You have one year to go until the final REACH registration deadline (of May 31st 2018) for your “phase-in” substances (these are the substances that were pre-registered before May 31st 2017). By the 2018 date, all non-exempt substances manufactured in, or imported into, the EU in quantities of 1 – 100 tonnes per year must be registered with ECHA or disappear from the market. So, if your company has any outstanding REACH registration obligations, now is definitely the time to act.

If your existing substance was not pre-registered by May 31st this year, you will no longer be able to manufacture or import that substance prior to registration (and this will have to proceed via the more time-consuming ECHA Inquiry Dossier process). At ECHA’s recent Stakeholders’ Day in Helsinki, Geert Dancet (the Executive Director) said that this year is “crucial” for anyone pre-registering within the REACH Annex VII and VIII tonnage bands, as it is “the only way to get immediate access” to data held by other (potential) registrants.

For companies approaching REACH for the first time, it can be surprising how time- and resource-consuming (and potentially expensive) it is to put together a satisfactory registration dossier. This is particularly true for SMEs. While there is a wealth of guidance and support materials available through ECHA, national competent authorities and sector-specific trade associations, the whole REACH registration process can still be daunting if you do not have the expertise in-house. And in certain cases – such as chemicals being registered under Annex VIII (10 – 100 tonnes/year) that are classified as hazardous to human health and/or the environment – there are many additional tasks required (e.g. a detailed worker exposure and risk assessment), for which an experienced service provider with a proven REACH track record is the ideal support.

Bibra is well placed to help you fulfil your REACH registration needs. We’ve worked on 100s of successful REACH lead registrations for the previous (2010 and 2013) deadlines, and are currently working with companies and Consortia on over 100 substances (including precious metals, petrochemical additives, SVHCs, fragrances, UVCBs, intermediates) ahead of the 2018 deadline. Our extensive experience in searching for, collecting and reviewing REACH-relevant data, developing Integrated Testing Strategies and Data Gap Analyses, and in the preparation of dossiers (e.g. developing Robust Study Summaries) in IUCLID 6 format, is highly regarded by our clients – the optional offering of our IUCLID 6 webhosting service is also utilised by several of our current REACH patrons. If required, we also have experience of the preparation of member (co-registration) dossiers in IUCLID (or directly via REACH-IT). Bibra scientists specialise in the use of read-across (including the preparation of robust justification reports sympathetic to ECHA’s 2017 Read Across Assessment Framework; RAAF) and (Quantitative) Structure-Activity Relationships ((Q)SAR), in predicting the likely toxicokinetics/ADME of substances (e.g. based on physical-chemical characteristics), deriving D(M)NELs and PNECs, proposing classification and labelling according to the EU CLP regulation, and in the compilation of Chemical Safety Assessments (CSAs, as documented in the CSR).

Navigating your way through the complex and resource-intensive process of REACH registration can be a daunting task. We can help relieve the anxiety of coping with REACH registration, and beyond, by providing you with sensible and expert advice as to your various options at each crucial stage. We have a long and proven history of working closely with clients in ways that best suit them, openly discussing problems and the costs associated with the particular task in which we are involved. We will not forget that this is your dossier, and you call the shots.

If we can be of assistance to you, or you would like more information, please contact us +44 (0)20 8619 0770 | www.bibra-information.co.uk

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SUMMER 2017

WELCOME z

Welcome

It’s always later than you think

It’s funny how big things can sneak up on you. You know that big birthday is going to happen or that you’re off on that holiday of a lifetime but it all seems a long way away. Then suddenly you realise it’s next week and start to panic. So much to do!

That’s pretty much what is happening with the REACH registration deadline which will occur on 31 May 2018. That’s less than a year away.

registration but smaller companies do not have the same resources as large ones which means that the final deadline will pose them particular problems.

In our special report on REACH, Christel Musset, Director of Registration at the European Chemicals Agency, flags up some worries which the industry must address over the next few months as the deadline looms.

As Christel says, even the simplest cases take time so leaving it to the last minute is not a wise course of action. Her message is one that comes over loud and clear.

John Dean Her message to the industry is simple; don’t

Editor in chief

be caught out. This is going to happen and you have to comply.

As she warns: “This last deadline is the most challenging one, both for companies and ECHA.” One of the reasons for that challenge relates in part to the immense volume of registrations to come, which are expected to be two to three times more than in the previous deadlines.

If too many companies leave it to the last minute, there is a danger that the system could be overloaded.

As Christel says ‘based on anecdotal feedback we get from our stakeholders, many registrants, maybe even a majority of them, are leaving the decision to register very late.’

That’s a big worry and not just for the system.

We all know that leaving things to the last minute increases the danger of making mistakes or missing the deadline because something else just as urgent comes along to distract you.

There is another worry. Many of the companies involved are small and mediumsized enterprises. This is complex stuff which requires companies to budget both time and money to generate the data needed for

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One of the other complications relating to REACH is the impact of Brexit, an event which has convulsed politicians and worried business people ever since the British people voted in June last year to leave the European Union.

Brexit presents many challenges and in the second part of our REACH special report, Peter Newport, Chief Executive of the Chemical Business Association, considers the findings of the House of Commons Environmental Audit Committee, which recently published the results of its inquiry into the future of chemicals regulation post-Brexit.

As he observes: “Immediately after the referendum result, it all seemed so simple. The Brexit Secretary, David Davis, said ‘Britain must be back in control. That means EU law must cease to apply. EU law will be transposed into domestic law on exit day.’

“At the time, there were murmurings from industry organisations that things might not be that simple or straightforward. Since then, these murmurings have increased in volume.”

Peter is right, of course. Whatever your view on Brexit, it promises to pose some pronounced challenges for the chemical industry and, as with REACH, burying your head in the sand and hoping it all goes away is not an option!

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SUMMER 2017

CONTENTS z

Contents 28

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Foreword

4-5

Contents

6-11

UK News

13-17

World News

18-19

Supply Chain

22-23 Big Interview

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26-37 Process Safety 40-41 Solvents Industry 46-55 REACH 58-59 Health and Safety

Editor

John Dean john.dean@distinctivepublishing.co.uk

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Design

Distinctive Publishing, Unit 6b, Floor B, Milburn House, Dean Street, Newcastle Upon Tyne NE1 1LE Tel: 0845 884 2385 www.distinctivepublishing.co.uk

Contributors

John Dean & Francis Griss john.dean@distinctivepublishing.co.uk

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Distinctive Publishing or Chemical Industry Journal cannot be held responsible for any inaccuracies that may occur, individual products or services advertised or late entries. No part of this publication may be reproduced or scanned without prior written permission of the publishers and Chemical Industry Journal.

z NEWS

SUMMER 2017

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Responsible care awards are presented The Chemical Business Association (CBA) has unveiled the winners of its annual industry awards for Responsible Care.

They were presented at CBA’s Annual Lunch at the Grosvenor House, Park Lane, London, before an audience of more than 1,100 industry representatives and their guests by impressionist, comedian, and writer, Rory Bremner.

Fred Worle, Group Operations Director, receiving the Award for distributors with operating sites and the overall CBA Responsible Care Award on behalf of Brenntag UK & Ireland

CBA’s Awards recognise excellence in relation to Responsible Care, a voluntary industry programme promoting continuous improvements and best practice in health, safety, security, and environmental management. Each year, CBA publishes the aggregate performance data for all its member companies.

The winner of the CBA Award for a distributor company with an office-only operation was Bradford-based Chantry Chemicals Limited.

The award reflects the company’s integration of Responsible Care into all its business operations and for its work with the local community. Lesley Jones, Managing Director, received the award on behalf of the company.

The winner of the Responsible Care Award for distributor companies with operating sites was Brenntag UK and Ireland Limited.

The company also won this year’s overall CBA Responsible Care Award.

The award reflects the exceptional commitment of the company to achieving a strong safety culture through training and communication throughout the workforce and its engagement with the local communities

Liran Maller, Group Director of Human Resources, receiving the Community Interaction Award on behalf of the 2M Group Limited

Lesley Jones, Managing Director, Chantry Chemicals Limited, receiving the Responsible Care Award for office-only companies

in which it operates. Fred Worle, Group Operations Director, received the Award on behalf of the company.

to recognise an outstanding contribution to community interaction by a member company, or one of its employees, or group of employees.

The judging panel awarded a Certificate of Commendation to Monarch Chemicals Limited to reflect the effectiveness of its internal communication strategy.

The winner was the 2M Group Limited.

The award reflects the strong involvement of the company, in working with young people in schools, colleges and universities, to promote science, technology, engineering, and mathematics, and providing many with workplace opportunities. Liran Maller, Group Director of Human Resources, received the Award on behalf of the company.

The Chemical Business Association also announced the winner of its annual Community Interaction Award.

CBA’s Community Interaction Award aims

CBA elects new chairman

The Chemical Business Association has elected Mottie Kessler MBE, Chairman and Chief Executive of the 2M Group as its new Chairman for a two-year term.

Mottie Kessler founded the 2M Group twelve years ago and, since that time, it has evolved into a portfolio of chemical distribution and service companies. The business now has an international footprint, exports to over 90 countries, and employs 250 people.

He received the Director of the Year award

for mid-market enterprises and the award for Global Director of the Year from the Institute of Directors in 2015.

This year, he received an MBE in the New Year’s Honours List for his services to industry and exporting in the North West of England.

Mottie said, “It is an honour to be elected as CBA’s Chairman. The chemical business provides crucial building blocks to all

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UK industries. In the next two years, the industry will face many challenges. Our key objective is to work with our members and policy makers to ensure we sustain the profitability and growth of the UK chemical supply chain.”

The Chemical Business Association represents the independent chemical supply chain. Its membership includes distributors, traders, warehouse operators, along with logistics and transport companies.

SUMMER 2017

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NEWS z

Honour for professor

Professor Tony James, from the Department of Chemistry at Bath University, has been awarded a 2017 Royal Society Wolfson Research Merit Award.

The award recognises scientists of outstanding achievement and provides support to enable them to continue their work in the UK. Tony has developed a broad interdisciplinary approach to research, with a focus on the development of modular sensors where he has pioneered a range of reporting regimes.

His research is directed towards the development of novel sensors and imaging agents for diseases associated with ageing.

Taking a new look at innovation A former Government minister has called for a shake up in the way the UK promotes innovation and research in a speech to a major chemical industry audience.

Former Science and Universities Minister Lord David Willetts called for a network of new research institutes to capitalise on original research and bring new technologies to new markets, in his speech at the Society of Chemical Industry evening.

Lord Willetts welcomed the Government’s recently published Industrial Strategy, and called for an expansion of the network of Catapult Institutes which have been founded

by Innovate UK to connect businesses with the UK’s research and academic communities.

He said the UK scores high in curiositydriven research taking place in universities, but is weak on funding the institutions that deliver applied research, which can then be commercialised.

Sharon Todd, SCI Executive Director, said: “Following the Brexit vote, the UK needs to develop an Industrial Strategy that will deliver both long term economic value and societal benefit.

And he said the Government should be prepared to bear the risk of applied research rather than depending on businesses to fund their own research.

“The UK needs an Industrial Strategy that fosters science and innovation, funds research, recruits the best talent, and provides a competitive base for business.

Lord Willetts said: “The fundamental responsibility of government is to bear risk, to take science from the laboratory to the market place. It is not the role of companies.”

“It needs to once more bring together scientists of all disciplines with entrepreneurs in an environment that enables invention and success.

He said it was vital that the UK achieves more successful application of science, both in more innovative large companies and through successful start-ups and scale ups.

“The Industrial Strategy should draw on the history and experiences of SCI and embrace the whole spectrum of industry, including infrastructure and energy, to rebalance the economy for long-term growth.”

He contrasted US companies on the Fortune 500 lists, which were generally different from those 30-40 years ago, to those in Europe, which have virtually no new entrants.

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Step forward for technology

The Centre for Process Innovation has announced that it is collaborating with PragmatIC, a world leader in ultra-lowcost flexible electronics, to develop its FlexLogIC system.

FlexLogIC is a fully automated system for high throughput manufacturing of flexible plastic semiconductor devices and the first system will be co-located with PragmatIC’s existing pilot production in Sedgefield, County Durham, in facilities leased from the Centre for Process Innovation (CPI) at the UK’s National Printable Electronics Centre.

The system will enable PragmatIC to produce flexible integrated circuits in the volumes needed for mass market roll-out, including labels, packaging, fast moving consumer goods, toys and games.

Ship goes into service

A new liquefied ethylene gas carrier (LEG) that will transport ethane to a SABIC cracker has been brought into service.

Operated by German shipping company Hartmann Reederei and GasChem Services, the vessel will carry shipments of ethane gas from Houston in the US to SABIC’s cracker at the Wilton site on Teesside.

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SUMMER 2017

NEPIC’s Industrial Leadership Team meet newly appointed CEO, Iain Wright

Former MP becomes chief executive of industry organisation NEPIC, the North East Process Industry Cluster, has named former MP Iain Wright as its new Chief Executive.

Iain, 45, served as a Labour MP for Hartlepool over the past 13 years and was most recently Chair of the Business, Energy and Industrial Strategy Select Committee.

He was Minister for Housing and Planning between 2007 and 2009 and Minister for Schools and Apprenticeships in 2009-10.

He served as Shadow Minister for Industry between 2011 and 2015.

Prior to being elected as MP for Hartlepool in 2004, he worked at One NorthEast, the regional development agency.

Together with Ian Swales and the Board of Directors, Iain will focus on representing member firms, championing the region’s process industries and identifying growth opportunities.

Ian Swales said: “I am delighted that Iain has agreed to join NEPIC. He is well known for his passion for industry and passion for the North East region and I’m sure he will do an outstanding job. Iain’s decision to join NEPIC shows the huge importance of the process industries in the region and I look forward to the sector getting even stronger in the future.”

Iain will work alongside outgoing chief executive, Dr. Stan Higgins, during the summer as they coordinate a smooth and effective handover.

He said: “I am really proud and honoured to have been appointed Chief Executive. Under Stan’s excellent leadership, NEPIC is a powerful organisation, representing firms in the North

Dr Stan Higgins with newly appointed CEO, Iain Wright, and NEPIC’s Chairman, Ian Swales East’s biggest industrial sector and working with them to create jobs and prosperity for our region. Stan will be a tough act to follow, but I am determined to work hard with companies to champion this vital sector and our great region.

“Future economic success for the North East will be based upon science, innovation, skills and a nimble and competitive manufacturing base. With great co-ordination and collaboration across industry, we can unlock still further the enormous potential of this sector in our region, ensuring that the North East of England can be seen across the world as the place to invest in chemicals, science and

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pharmaceuticals, and for firms in the region to export their excellent goods and services around the globe”.

Outgoing chief executive Dr Higgins added: “It’s reassuring that such an outstanding candidate has taken over this important leadership role. I believe Iain’s national business and industry experience will help NEPIC’s members and the sector into the future.”

Privately-owned and led by industry, NEPIC supports cluster members to become successful and sustainable organisations in a collaborative business environment that helps them to grow.

www.chemicalindustryjournal.co.uk

SUMMER 2017

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z NEWS

SUMMER 2017

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Companies move in

Two companies founded at the University of Bristol, including a chemistry start-up, have become the first tenants to move into new scientific innovation centre, Unit DX.

The move took place in the same week that the University signed a partnership agreement with the centre to support its graduates in the commercialisation of research.

The partnership between the University of Bristol and Unit DX will accelerate the new scientific network developing in Bristol, supporting University researchers in their efforts to convert elements of its world class research into new scientific jobs for the city and its graduates.

Unit DX is located in St Philips, an area that will soon see the addition of the University of Bristol’s Temple Quarter Campus and the Engine Shed 2, as the area becomes a focus for research and development in the South West.

Ziylo, formed in 2014 in the Davis research group, and NuNano, formed in 2011 by Dr James Vicary and Professors Heinrich Hoerber and Mervyn Miles, have become the anchor tenants at the facility.

Chemistry start-up Ziylo moved its team of ten people into the building from their previous laboratory space at the University of Bristol and their offices at the Easton Business Centre.

Their new base will allow them to accelerate their development of potentially life changing sugar monitoring technology, and provide wet lab space for their recently expanded team of chemists.

Johnathan Matlock, Senior Scientist at Ziylo, said: "Ziylo is, first and foremost a synthetic chemistry company and therefore needs

Unit DX, Bristol high-specification lab space, equipped with fume hoods to successfully achieve our long term objectives. Therefore, the infrastructure and facilities in place at Unit DX have provided a blank canvas and have really allowed Ziylo to tailor the laboratory space to our requirements.

"In short, establishing Ziylo’s long term future as an SME is only possible thanks to the lab space solution provided by Unit DX." NuNano specialises in the design and manufacture of probes for atomic force microscopy and other cantilever-based sensor devices. Founded with the vision of developing new manufacturing methods for devices that are used for the nanoscale characterisation of materials, the company is moving its sales and management functions from the Engine Shed to Unit DX.

Unit DX has been working closely with the University since the idea for the project was formed in 2015. Having recently completed the building conversion in St Philips, just 10 minutes’ walk from Bristol Temple Meads, this working relationship has now been formalised with an official partnership, and will assist Unit DX in supporting University start-ups and spin outs.

In addition to providing class 2 laboratory space and office facilities, Unit DX will offer incubation programmes for academics as well as established start-ups, which will focus on the challenges specific to scientific companies.

Nishan Canagarajah, Pro Vice-chancellor for Research and Enterprise, said: "The building is an excellent asset for the city and we are proud to be able to support it and the enterprises that stem from it."

Internet of Things is focus for new project The Centre for Process Innovation (CPI) is leading a new collaboration with thirteen partner organisations designed to take advantage of the opportunites presented by the the Internet of Things (IoT).

IoT involve the integration of electronics into a wide range of everyday items and the Necomada (Nano-Enabled Conducting Materials Accelerating Device Applicability project will develop technologies in clothing, healthcare, printing, domestic appliances, smart packaging, and consumer goods.

The Necomada project involves the Centre for Process Innovation Ltd, Henkel Electronic Materials, PragmatIC Printing Ltd, Teknologisk Institut), Contitech Elastomer-Beschichtungen, Nanogap SubNM-Powder SA, Thomas Swan & Co Ltd, BSH Electrodomesticos Espana SA, Henkel KGaA, Crown Packaging Manufacturing UK Ltd,

Fraunhofer FhG, Tyoeterveyslaitos and NXP Semiconductors.

The project will use CPI’s open access pilot facilities at the UK’s National Centre for Printable Electronics in the North East to develop integration systems for printed electronics as well as new materials development.

Jorge Alamán, of BSH Electrodomésticos España, said: “The Necomada project allows us to participate in and be at the forefront of these new technology developments, as well as make use of the end products.

“Not only will the final user benefit from this technology, but all other users that are in contact with the product during its life cycle will benefit from enhanced technical assistance, product production and recycling.”

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Olaf Lammerschop, Innovation Manager, Henkel KgaA, said: “Being involved from the start of the project will enable us to better serve the needs of our customers. To address the IoT, Necomada will bring innovative electronics into our everyday products.”

Jon Helliwell, Business Development Director, Centre for Process Innovation, said: “We believe that the unique blend of skills and capabilities within our consortium will enable us to develop materials that will support high-speed, roll-to-roll integration of hybrid and large area electronics. This will unlock many of the opportunities that the Internet of Things presents to a wide range of stakeholders.”

The project has received funding from the European Union’s Horizon 2020 research and innovation programme.

SUMMER 2017

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NEWS z

New structure is created

A team of scientists from the University of Bristol have designed a new protein structure.

The chemists and biochemists from the Bristol BioDesign Institute say the new research will help to design small proteins and small molecules that could be the basis for future biotechnologies and medicines.

Chemist’s work offers hope for people suffering sight problems.

A synthetic, soft tissue retina developed by an Oxford University student could offer fresh hope to visually impaired people.

Until now, all artificial retinal research has used only rigid, hard materials. The new research, by Vanessa Restrepo-Schild, a 24-year-old doctoral student and researcher at Oxford University's Department of Chemistry, is the first to successfully use biological, synthetic tissues, developed in a laboratory environment.

The study could revolutionise the bionic implant industry and the development of new, less invasive technologies that more closely resemble human body tissues, helping to treat degenerative eye conditions such as retinitis pigmentosa.

Just as photography depends on camera pixels reacting to light, vision relies on the retina performing the same function. The retina sits at the back of the human eye, and contains protein cells that convert light into electrical signals that travel through the nervous system, triggering a response from the brain, ultimately building a picture of the scene being viewed.

Vanessa Restrepo-Schild led the team in the development of a new synthetic, doublelayered retina which closely mimics the natural human retinal process.

The retina replica consists of soft water droplets (hydrogels) and biological cell membrane proteins. Designed like a camera, the cells act as pixels, detecting and reacting to light to create a grey scale image.

Vanessa, from Colombia, said: “I have always been fascinated by the human body. I want to prove that current technology can be used to replicate the function of human tissues, without having to actually use living cells.

‘The synthetic material can generate electrical signals, which might stimulate the neurons at

They say that this much simpler than most naturally occurring proteins, which has allowed the scientists to unpick some of the molecular forces that assemble and stabilise protein structures.

Dr Emily Baker, who led the research, said: “Our work has implications not only for understanding the basic science of protein folding and stability, but also for guiding the design and engineering of new proteins and drug molecules."

the back of our eye just like the original retina.’

The study shows that, unlike existing artificial retinal implants, the cell-cultures are created from natural, biodegradable materials and do not contain foreign bodies or living entities.

In this way the implant is less invasive than a mechanical device, and is less likely to have an adverse reaction on the body.

Vanessa said: “The human eye is incredibly sensitive, which is why foreign bodies like metal retinal implants can be so damaging, leading to inflammation and/or scarring.

But a biological synthetic implant is soft and water based, so much more friendly to the eye environment.”

“I want to take the principles behind vital bodily functions, e.g. our sense of hearing, touch and the ability to detect light, and replicated them in a laboratory environment with natural, synthetic components. I hope my research is the first step in a journey towards building technology that is soft and biodegradable instead of hard and wasteful.’

Although at present the synthetic retina has only been tested in laboratory conditions, Vanessa is keen to build on her initial work and explore potential uses with living tissues.

This next step is vital in demonstrating how the material performs as a bionic implant.

She has filed a patent for the technology and the next phase of the work will see the Oxford team expand the replica’s function to include recognising different colours. Working with a much larger replica, the team will test the material’s ability to recognise different colours and potentially even shapes and symbols.

Looking further ahead the research will expand to include animal testing and then a series of clinical trials in humans.

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Company signs up

Fujifilm Diosynth Biotechnologies, a world leading developer and manufacturer of biologics-based medicines, has taken 15,000 sq ft of space at The Wilton Centre on Teesside on a new ten-year lease.

The company is expanding its development facilities, presently located in Billingham, by equipping two floors at the Centre. It has more than 25 years of experience in process development and manufacturing.

Small is beautiful

Researchers have developed the world’s thinnest metallic nanowire, which could be used to miniaturise many of the electronic components we use every day.

The researchers, from the Universities of Cambridge and Warwick, have developed a wire made from a single string of tellurium atoms, making it a true one-dimensional material. These one-dimensional wires are produced inside extremely thin carbon nanotubes (CNTs) – hollow cylinders made of carbon atoms. The finished ‘extreme nanowires’ are less than a billionth of a metre in diameter – 10,000 times thinner than a human hair.

SUMMER 2017

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Modernising OPRA

For some years, the Environment Agency (EA) has used its Operator Risk Appraisal (OPRA) system to score sites operating under an environmental permit according to their environmental risk.

The OPRA score is derived each year from compliance. The existing OPRA compliance the EA’s assessment of a site’s complexity, bands of A-F will be replaced by four emissions and inputs, location, operator descriptive bands: Exemplary, Expected, performance and compliance record. Each site Improvement Needed and Significant is banded according to its OPRA assessment, Improvement Needed. Operator behaviours For some years, the Environment Agency places more emphasis on performance and the banding influences the amount(EA) ofhas used itssuch as responsiveness than attitude compliance.will The be existing Operator Risk Appraisal ratherand compliance of A-F will systemassessed to score sitesto operating regulatory resource that will be devoted(OPRA) to the judge theOPRA likelihood ofbands an adverse under an environmental permit according be replaced by four descriptive bands: site. incident as well as the hazards arising from Exemplary, Expected, Improvement to their environmental risk. The OPRA and the regulated activity and Significant Improvement score is derivedthe eachtype year from thescale ofNeeded Needed. Operator behaviours such EA’s assessment of a the site’s site’s complexity, and environmental sensitivity.

FEES as responsiveness and attitude will emissions and inputs, location, operator Sites which achieve compliance andthe nolikelihood more be assessed to judge performance and compliance record.

Importantly, it also determines the annual of an adverse incident as well as the Each site is banded to the its Expected willaccording fall into band.

Exemplary hazards arising from the type and scale and the banding subsistence fee and any other fees that OPRA mayassessment, be sites, those that go above and beyond mere of the regulated activity and the site’s influences the amount of regulatory payable, for example for variation applications. compliance, could a formsensitivity. of regulated environmental Sites which resource that will be devoted to the site. enjoy Permit subsistence fees for large chemicals achieve compliance and no more will self-assurance, light-touch regulation and Fees fall into the Expected band.

Exemplary sites are substantial nowadays, and OPRA lower subsistence fees than Sites Importantly, it also determines the sites, thoseat thatpresent. go above and beyond provides a strong incentive to devote resources annual subsistence fee and any other in the lower two bands expectcould more merecan compliance, enjoy a form fees that may be payable, for example to improving management systems and of regulated self-assurance, attention from the EA and higher fees. light-touch for variation applications. Permit regulation and lower subsistence fees compliance. subsistence fees for large chemicals than at present. Sites in the lower two The nowadays, EA ran aand 4-weekbands informal consultation on sites are substantial can expect more attention from OPRA providesthese a strongproposals, incentive ending May. Itfees. will use the the EAinand higher CHANGES to devote resources to improving responses to develop a formal consultation The EA ran a 4-week informal management systems and compliance.

Now, the EA is proposing to move to a new which it plans to launch in July.

Operators consultation on these proposals, ending in May. It will use responses to assessment scheme which places moreChanges subject to OPRA scoring would bethe well advised Now, the EA is proposing to move develop a formal consultation which emphasis on performance rather than to a new assessment to look out which for that consultation paper and scheme it plans to launch in July. Operators

Modernising OPRA.

study it to find out what impact the proposals are likely to have.

COMMENT

subject to OPRA scoring would be well Operators will also be keen to ensure that advised to look out for that consultation new are properly evidence papercategorisations and study it to find out what impact and the proposals likely to have. based it mayare therefore be worth some investment of time and resource to ensure that Comment Operators will also be keen to ensure all appropriate material is available so as to that new categorisations are properly ensure that the right regulatory conclusions evidence based and it may therefore are drawn. be worth some investment of time and resource to ensure that all appropriate

material is available so as to ensure that For more information contact; the right regulatory conclusions to be paul.bratt@symmetrylaw.co.uk drawn. victoria.joy@symmetrylaw.co.uk For more information contact; paul.bratt@symmetrylaw.co.uk victoria.joy@symmetrylaw.co.uk

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01/06/2017 14:22

05/06/2017 16:50

SUMMER 2017

www.chemicalindustryjournal.co.uk

WORLD NEWS z

US region ‘could be major chemicals centre’

A new report has shown that the Appalachian region could become a second centre of American petrochemical and plastic resin manufacturing, similar to the Gulf Coast.

The report was compiled by the American Chemistry Council (ACC), whose President and CEO Cal Dooley said: “The Appalachian region has distinct benefits that could make it a major petrochemical and plastic resin-producing zone.

“Proximity to a world-class supply of raw materials from the Marcellus/Utica and Rogersville shale formations and to the manufacturing markets of the Midwest and East Coast has already led several companies to announce investment projects, and there is potential for a great deal more.”

ACC’s report is based on a hypothetical scenario that includes the development of a storage hub for natural gas liquids (NGLs) and chemicals (e.g., ethylene, propylene), a 500-mile pipeline distribution network and associated petrochemical, plastics and potentially other energy infrastructure and manufacturing in a quad-state area consisting of West Virginia, Pennsylvania, Ohio and Kentucky.

According to the ACC, the economic benefits could be substantial. By 2025, the region could see 100,000 permanent new jobs, including 25,700 new chemical and plastic products manufacturing jobs, 43,000 jobs in supplier industries and 32,000 jobs in communities

where workers spend their wages, according the report.

The new investment could also lead to $2.9 billion in new federal, state and local tax revenue annually.

Cal Dooley said that the support of politicians was important to turn the theories into reality, adding: “The right policies are critical to realising this opportunity. Uncertainty around financing is a key barrier to the development of energy infrastructure in the Appalachian region.

“Policymakers can help by affirming that NGL storage and distribution projects are eligible for existing private-public financing programmes. As Congress and the Administration consider infrastructure modernisation legislation, the Appalachian Hub should be a priority.”

ACC’s analysis projects a $32.4 billion investment in petrochemicals and derivatives and a $3.4 billion investment in plastic products, put toward the construction of five ethane crackers and two propane dehydrogenation (PDH) facilities.

Three of the crackers would produce polyethylene and two would supply downstream petrochemical derivatives. Each

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PDH facility would contain a polypropylene resin plant. These capital investments are already under way and will likely continue through the mid-2020s.

Plentiful and affordable supplies of natural gas and NGLs are enabling companies from around the world to build new U.S. facilities or expand production capacity.

Since 2010, 301 projects cumulatively valued at $181 billion have been announced, with nearly half completed or under construction.

• According to the American Chemistry Council (ACC), the U.S. Chemical Production Regional Index (U.S. CPRI) edged higher by 0.1 percent in April, following flat growth in March, and a 0.3 percent decline in February.

During April, growth in the Midwest, MidAtlantic, Southeast, Northeast and West Coast regions was offset by declines in the Gulf Coast and Ohio Valley regions.

There were gains in the production average output trend of pharmaceuticals, fertilizers, coatings and adhesives. These gains were offset by declines in the output trend in synthetic rubber, pesticides, other specialties, plastic resins, consumer products, organic chemicals, chlor-alkali, industrial gases, other inorganic chemicals and manufactured fibres.

z WORLD NEWS

www.chemicalindustryjournal.co.uk

SUMMER 2017

Xergi’s largest biogas plant makes milk production greener

Xergi is to deliver its largest biogas plant to date to Danish dairy company Arla Foods with green energy for the production of milk powder.

The Nature Energy Videbaek biogas plant is expected to be up and running in the autumn of 2018, using converting biomass to electricity and heat.

The main shareholder is the energy company Nature Energy while Arla Foods, Xergi and local farmers’ association Videbaek Biogas have smaller holdings in the plant.

Xergi CEO Jorgen Ballerman said: “We have been involved in the project development right from the start 5-6 years ago. Therefore, we are very pleased that we are now on target with the project.”

With five biogas digesters each with a capacity of 9,500 cubic metres the biogas plant can handle about 600,000 tonnes of biomass a year and produce 16.5 million cubic metres of bio-methane.

The plant is thus the largest Xergi has ever built since the company began constructing biogas plants more than 30 years ago.

Jorgen said: “The plant will be built in accordance with our design principles which over the years have ensured stable and high gas production at a number of large biogas plants delivered in countries such as UK, France, USA and Denmark.

“The plant will be equipped with a number of new technical solutions developed by Xergi. The solutions improve the gas yield from organic residues from the food industry, agriculture and households. The Nature Energy Videbaek plant will therefore – internationally – become an important reference plant in the transition to green energy.”

The biogas plant provides Arla Foods with the opportunity of using green energy, which is partly produced by one of the company’s own by-products. Every year a total of 40,000 tonnes of the residual product Perlac 14 will be digested in the biogas plant.

The rest of the 600,000 tonnes of biomass will primarily come from agriculture in the form of

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manure and deep litter, but a smaller quantity of residual products from other food industries also ends up in the biogas plant. The residual biomass is used as fertiliser by local farmers.

Jorgen said: “When manure and deep litter are treated in the biogas plant the nutrients are made easily available for the crops. This means that farmers can utilise the fertilisation value of their manure better and at the same time new nutrients recycled from industry are continuously being supplied to agriculture. In this way agriculture receives greener and more environmentally-friendly fertiliser while Arla Foods receives a green energy supply.”

The plant is being constructed in the village of Trøstrup south of Videbaek in the western part of Denmark and will handle produce 16.5 million cubic metres of bio-methane and handle 600,000 tonnes of biomass annually.

It has three primary biogas digesters with a capacity of 9,500 m3 each and two secondary digesters with a capacity of 9,500 m3 each.

SUMMER 2017

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z WORLD NEWS

BASF joins initiative for circular economy BASF has joined two Ellen MacArthur Foundation programmes to further advance its existing circular economy solutions.

Founded in 2010, the Ellen MacArthur Foundation works with businesses, government and academia to support an economy that is ‘restorative and regenerative’.

Dirk Voeste, Vice President Sustainability Strategy at BASF, said: “The circular economy is much more than waste management. It requires substantial changes in terms of behavior and technology use. Circular economy thinking cannot be restricted to a company’s own operations.

“A smart circular economy concept has to be integrated within product development, production processes, use and re-use systems right from the beginning.”

Nano-Material successfully tested

Heroes of Chemistry are honoured

Scientists who developed products that have led to significant advancements in human health, technology, the food supply, and the environment, will be inducted into a scientific Hall of Fame.

They will become he newest Heroes of Chemistry, an honour bestowed by the American Chemical Society (ACS), the world's largest scientific society.

Allison Campbell, ACS president, said: “We are honouring scientists whose risk-taking and drive to innovate have contributed to the advancement of the human condition. Their creative spirit, commitment to excellence, and technical talent are tangible evidence of the ACS Vision: "Improving people's lives through the transforming power of chemistry."

The teams will be inducted in a ceremony on Sunday August 20 during the Society's 254th National Meeting & Exposition in Washington, D.C. They are: • Bristol-Myers Squibb: Pioneered the development of direct acting antiviral agents that have produced hepatitis C cure rates of greater than 95%.

• Corning Incorporated: Invented ClearCurve®

optical fiber, a revolutionary product which allows cabled optical fiber to be bent around very tight corners with significantly less signal loss than with traditional fibers.

• DuPont Crop Protection: Discovered DuPont™ Zorvec™, the first member of a novel class of fungicides to control diseases caused by oomycete pathogens.

• Genentech: Discovered and developed ERIVEDGE® (vismodegib), the first medicine to be approved for the treatment of metastatic or locally advanced basal cell carcinoma.

• Merck: Developed ZEPATIER®, a prescription medicine to treat chronic hepatitis C infection in adults • The Dow Chemical Company: Developed AVANSE™ acrylic resins and EVOQUE™ pre-composite polymers to help make architectural paints greener and more economical.

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Zenyatta Ventures Ltd has successfully tested the company's graphene oxide material as part of work to develop silicon-graphene anodes for the next generation of lithium-ion batteries.

Aubrey Eveleigh, President and CEO of Zenyatta, said: “Given the present limitations on the existing lithium-ion battery, the world needs to develop a super-battery.

“Silicon-graphene is the next generation anode being developed for batteries by many advanced material companies.”

Plant scales up

The Dow Chemical Company has announced that its joint venture in the Middle East, called the Sadara Chemical Company, has achieved the commercialisation of Sadara’s entire plastics franchise.

The start-up of Sadara’s high-pressure low-density polyethylene plant adds to the company’s mixed feed cracker and the three additional polyethylene trains currently in operation at Jubail, Saudi Arabia.

z WORLD NEWS

SUMMER 2017

www.chemicalindustryjournal.co.uk

US company boosts production US-based Eastman Chemical Company has announced an expansion of its Performance Films manufacturing capacity in Martinsville, Virginia.

The expansion is expected to be complete in late 2017 and will increase capacity for both paint protection films and window films to support the continued growth of the LLumar® and Suntek® brands.

Eastman says that it continues to drive investments related to product development and innovation, manufacturing and quality excellence to support growth of the window film and protective film markets.

The move is Eastman’s largest film expansion to date and the plant will produce high performance films for the automotive and architectural markets.

Darrell Reed, Performance Films commercial director for Americas, Europe, Middle East & Africa, said: “We see exciting growth potential for our portfolio of films and our dealer network," said “We are making these investments in product innovation, manufacturing capacity, and marketing and support services to help our customers provide high-quality products to meet the needs of consumers and ultimately to allow our customers to further differentiate and grow their business.”

According to the company, the expansion will provide additional high-quality jobs for the Martinsville Henry County community.

The project is in addition to the $40 million investment that was announced in September of 2013.

Travis Smith, vice president and general manager of Eastman’s Performance Films business, said: “This expansion positions Eastman to meet the great growth in demand for window and paint protection films we’re seeing from our customers around the world.

“This investment further solidifies Eastman’s commitment to the window and paint protection films markets and to making our manufacturing site in Henry County a stateof-the-art facility that produces the world’s highest quality films products.”

Performance Films is a part of Eastman’s Advanced Materials business segment. With 60 years of experience, Eastman is the world's leading manufacturer and marketer of high performance window and paint protection films that are used in automotive and architectural applications.

Eastman Chemical Company has also announced that it has partnered with Phoenix Venture Partners LLC (PVP) via an investment

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in its officially closed new venture capital fund PVP II LP. As a leading venture capital firm focused on Advanced Materials, PVP is recognized by entrepreneurs and corporations around the globe. PVP forges deep partnerships with its strategic investors and works closely with them to identify attractive market opportunities.

Dr Brendan Boyd, external innovation director for Eastman, said PVP is a natural fit for Eastman as it accelerates external innovation sourcing.

Dr John T. Chen, Managing General Partner of PVP, said: "With its portfolio of Advanced Materials and Additives and Functional Products businesses, Eastman can leverage collaboration with start-ups in these sectors that will accelerate innovation and deliver value."

Dr. Zachariah Jonasson, Managing General Partner of PVP, added, "We are excited to be working with Eastman to connect them to entrepreneurs globally."

SUMMER 2017

www.chemicalindustryjournal.co.uk

Hydrogen technology is showcased Air Products, the industrial gases company, has showcased its latest hydrogen technology at a major event in China.

The company showed off the patented SmartFuel® hydrogen fueling station technology at the 11th China Hydrogen and Fuel Cells Expo held in Shanghai.

Air Products says that introducing the technology demonstrated its commitment to support the country’s hydrogen infrastructure development as China moves towards more environmentally clean energy.

“We are honoured to have been involved in several demonstration projects in the country, among which the hydrogen fueling station for 2008 Beijing Olympic was the first of its kind in China. We will continue to contribute to the development of hydrogen infrastructure in China through our technology and expertise.”

The company signed a Memorandum of Understanding last year to work with the National Institute of Clean-and-Low-Carbon Energy, a research and development institute affiliated with the Shenhua Group on hydrogen fueling projects in China.

Air Products’ hydrogen also powered the official shuttle buses for the 2008 Beijing Olympic Games, 2010 Asian Games and 2011 Shenzhen Universiade to drive the use of clean energy in

European chemical industry leaders have identified the drive towards cleaner energy as a business opportunity for companies.

It also says that reducing energy waste will also help companies that manufacture products needed for the move to low-carbon usage.

Marco Mensink, Cefic Director General, said: “By matching climate ambitions with commercial opportunities, the EU Commission

Andrew Liveris, chairman and chief executive officer of American firm the Dow Chemical Company, has been appointed co-chair of the newly launched Saudi-U.S. CEO Forum, set up to develop the partnerships between the two countries.

The first meeting of the forum brought together chief executive officers of major Saudi and US companies in several industries and senior Saudi government officials. Discussions focused on opportunities to strengthen bilateral trade and investments and strengthen economic ties.

Hundred year old beers help chemists

Cleaner energy ‘presents business opportunities’ Cefic, the EU chemical industry association, says that the EU’s support of new energy technologies will open new opportunities in areas including the development of industrial chemicals used to make wind turbines, solar panels and insulation.

CEO takes on role

Dow has been investing in Saudi Arabia for more than 40 years and is the largest foreign investor in the country.

Hydrogen has been incorporated into China's energy strategy and the country plans to build 100 hydrogen fueling stations by 2020 and 1,000 by 2030.

Frank Yu, vice president - Eastern China, Industrial Gases at Air Products, said: “China has a well-developed energy plan with a clear hydrogen growth roadmap and targets. With the proven technologies, supply capabilities and safety performance, Air Products is committed to help the country realise the scale-up and commercialization of hydrogen energy.

z WORLD NEWS

has provided the basis to make sure Europe leads the way on clean energy.

“We believe this proposal can boost Europe’s record as a clean energy leader, and if wellexecuted also open markets for new European products and drive job creation in Europe.

Our industry looks forward to supporting the package by manufacturing smart materials that are in high demand by other major EU sectors such as construction and automotive.”

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A trio of century-old bottled beers discovered in the Czech Republic could help scientists better understand the chemical changes that occur in beer over long periods of time.

According to the American Chemical Society, the bottles were uncovered in 2015 during reconstruction of an old brewery. The lagers were apparently produced during the World War I and stored in a large cold cellar at the brewery where they remained to gather dust.

Initial sensory analyses found that the beers ranged from intensely sulfuric to sour, and had off-flavors that ranged from fecal to fruity. Using high performance liquid chromatography and other techniques, the researchers compared the beers’ features to those of modern day brews. For example, the century-old beers had higher alcohol content and were less bitter. They also contained more iron, copper, manganese and zinc

z SUPPLY CHAIN

SUMMER 2017

www.chemicalindustryjournal.co.uk

Current order books and sales

continue to rise

– but margins remain neutral Current order books and sales have continued to rise over the last three months for the UK’s chemical supply chain – but whilst current sales margins remain neutral, the outlook for future sales margins has entered positive territory for the first time this year.

The Chemical Business Association’s latest Supply Chain Trends Survey was conducted on-line during the two weeks, 5-19 June 2017, and is based on responses from 37 member companies.

Overall, current levels of trading activity are returning to more normal levels after turning sharply negative in the aftermath of the Brexit vote. However, member companies remain cautious about forecasting continued sales growth or significant improvements in current and future sale margins.

ABOUT THE SURVEY CBA’s Supply Chain Trends Survey asks companies to provide information on order books, sales, sales margins, and employment, on a ‘better–worse–same’ basis. To measure short-term trends, the analysis ignores responses answering ‘same’ and focuses on the positive or negative balance provided by the difference between the ‘better-worse’ responses.

• CURRENT ORDER BOOKS – SIGNIFICANT IMPROVEMENT

Members are asked if their order books are better, worse, or the same than in the

previous three months. The survey shows a positive balance of +54%, a marked improvement on the figure of +37% recorded CBA’s last survey in March 2017.

• SALES VOLUMES – CURRENT SALES CONTINUE TO RISE – BUT MAY LOSE MOMENTUM Respondents are asked to compare their current sales volumes with the preceding three months and indicate their expectations for the next three months.

Current sales volumes are now showing a positive balance of +51% that continues the upward trend from the last survey (+31%).

Members are less confident that sales will continue to rise over the next three months with a positive balance of +16% of respondents taking a bullish view of future sales - compared with a positive balance of +39% in the March 2017 survey.

• SALES MARGINS – REMAIN NEUTRAL WITH MARGINAL IMPROVEMENT IN THE PIPELINE Companies are asked to compare their current sales margins with the preceding

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three months and forecast their trend over the coming three months. Current sales margins are neutral, with exactly the same number of respondents reporting an improvement in margins as are reporting a decline in margins.

Future sales margins are creeping into positive territory with a positive balance of 8% of respondents expecting them to improve over the next three months as opposed to a negative balance of -15% in the March 2017 survey.

• EMPLOYMENT – POSITIVE TREND CONTINUES Member companies remain positive about employment levels. The current Survey shows a positive balance of +29% in the number of companies believing they will increase employment over the next three months (March 2017, +27%).

SUMMER 2017

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SUPPLY CHAIN z

SUMMER 2017

www.chemicalindustryjournal.co.uk

How can the chemical sector thrive in a post-Brexit Britain? at trading relationships further afield than the continent.

We know this makes it even more important for us to continue to engage with our clients to openly discuss their future plans. To determine how these plans fit into the wider economic environment and to help them to build better, stronger businesses.

Matt Brown

Partner at Brabners LLP

Part of our role in guiding clients will be to continue to consult with government, ensuring that we’re able to influence laws so they not only serve the needs of the businesses we work with, but also those of British industry.

Brexit talks are firmly underway and the magnitude of the task facing Britain’s team of negotiators has come sharply into focus.

The opening gambits have received a tepid response from the European Union and the uncertainty that has consumed British industry for the past 12 months shows no sign of abating.

This is particularly concerning for the chemical sector where more than 50% of trade is with the EU. A report from credit insurance solutions provider Euler Hermes predicted that the industry would lose close to £7bn in sales should a free trade agreement not be reached.

The question for the industry now is how to adjust to life after Brexit.

EU, it will likely feel the full brunt of Brexit upheaval.

As a law firm with more than 200 years’ experience, we have witnessed our fair share of seismic events in the past. Yet there is always a common backdrop among the businesses we work with - an attitude of determination and an ambition to succeed.

Commercially, organisations cannot halt their plans and wait for politicians to guide us through uncharted waters.

Ultimately, it’s those organisations that refuse to stand still in the face of adversity that will steal a march in their sectors. That is especially true for chemicals. As an intensely regulated sector that heavily relies on trade with the

As we move closer to the March 2019 negotiation deadline, the true nature of Brexit will become clearer. At the same time, the business environment will continue to evolve and new challenges will emerge.

Regardless of the type of Brexit we are faced with, it will be important for chemical companies to retain strong ties with their supply chain, both inside the EU and out. The main change will be that these relationships may have to be approached differently and reviewed on a more case-by-case basis. This will be particularly important for those looking

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Ultimately, it is our aim to work with our clients and offer them the sector-specific, commercially focused legal advice they need to make the right decisions for the future.

The post-Brexit landscape will be formed over the next 18 months and those organisations that continue to find more efficient ways of working, and that continue to invest and collaborate, will be the ones that succeed.

For many, this will mean a shift in operating strategies, and perhaps forging new partnerships. While it’s natural for change to bring apprehension, it’s vital to adapt. We see our role as helping businesses to make the right choices to achieve this.

Our experience of working with clients in the chemical industry has shown us that that innovation breeds resilience. Now is the time to be optimistic, proactive and set out a plan for the future, not sit back and let uncertainty hold us back.

SUMMER 2017

www.chemicalindustryjournal.co.uk

Insurance services for the chemical industry Much was said in the previous edition of the Chemical Industry Journal in the way of Industry 4.0 and the Internet of Things.

There is a new tide of technological advancement and as Cisco’s Maciej Kranz pointed out, ‘the most important decision you can make now is how to be a part of it’.

Harnessing the power of big data, chemical factories can forecast problems before they occur. Well just in the way that businesses in the chemical industry must adapt to changing trends, so too must the insurance for them.

OAMPS Hazardous Industries’ insurance proposition for the chemical industry does not just adapt however, it leads the way.

A commercial combined insurance policy will typically include cover for material damage, business interruption, employer’s liability and public/products liability as standard. Disasters can happen, factories and equipment can be damaged but these events should be covered depending on the cause. The risks associated with handling Chemicals are well known, but can be mitigated by training of staff and adherence to correct procedures. In the event that things do go wrong personal injury as well as property damage may result. The financial costs of this too should be covered.

With over 30 years of experience in this sector, OAMPS understands that these standard covers alone are not enough. Under our proposition, chemical companies also enjoy enhanced Professional Indemnity and Product Recall cover, which is all the more appropriate in a landscape of ever changing REACH and COMAH regulations. The Chemical Industries Association found that 80% of companies asked, expect to increase or maintain R&D spending in 2017. Here too we provide cover for R&D activities including the cost of repeating development work after an insured loss.

CONSTRUCTION -LIABILITY

© OHES Environmental At OAMPS we understand that businesses in the chemical industry are committed to loss prevention and so we take an interest in their risk management programmes. OAMPS clients are usually offered free risk management surveys by experienced engineers. These ascertain whether the business’ existing risk management procedures are adding the value they intend or whether they are in fact simply adhering to procedures that may themselves be flawed. In this way, we do not just arrange pay out when the loss happens but we provide advice to prevent the loss from happening.

Should the worst happen, chemical businesses can be reassured by the access that they receive to our 24/7 emergency spillage response service – one of the most celebrated features of our offering. Our sister company OHES Environmental provides a 24 hour incident reporting line. Chief Scientific Advisor at OHES, Bill Atkinson, explains what happens when a call is placed to them to report a spillage, ‘The Incident Advisor will answer the call directly on a recorded landline and ascertain the facts of the spill. They will make an assessment of whether the incident requires the intervention of the emergency services or whether another response (e.g. a specialist clean-up) can be effected’.

© OHES Environmental

Bill then discusses a recent incident that OHES were involved in, where ‘a batch of a corrosive

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and oxidising steriliser product had reacted after some containers were not adequately sealed and allowed rainwater to seep in.

The fire service attended and, under our advice, isolated each of the containers in the pallet and placed the worst affected into an overdrum for disposal. We then arranged for a response team to collect and dispose of the rest of the affected batch’.

In over 9,000 incidents handled by OHES, no client has been prosecuted for causing pollution when OHES managed the emergency response. We get to the problem fast and find a solution that works for you. We also model ourselves on being easy to do business with and our in house claims team means we can achieve exactly this. OAMPS customers enjoy continuity in our service from their initial enquiry to the moment the accident arises.

Other industries look to the chemical sector to lead the way in embracing change. The sector can do this more easily with the right insurance in place.

Contact us to find out more: OAMPS Hazardous Industries Kings Court, 41-51 Kingston Road, Leatherhead, Surrey KT22 7SL Telephone: 01372 869762 Website: www.OAMPS.co.uk Email: Ian.Peach@OAMPS.co.uk

EVERYTHING YOU NEED TO PROTECT YOUR BUSINESS

SPECIALIST PROVIDERS OF INSURANCE SOLUTIONS TO THE CHEMICAL INDUSTRY Our insurance solutions are designed for businesses in the manufacture, blending, supply, import, wholesale and distribution of chemicals: • 24/7 emergency spillage response • Access to OHES Environmental Consultancy • Product recall • Clean up of own land • Crisis management and media protection • Statutory environmental protection • Professional indemnity • Financial loss cover

01372 869762 | www.OAMPS.co.uk Ian.Peach@OAMPS.co.uk

OAMPS is a trading name of Pen Underwriting Limited, which is authorised and regulated by the Financial Conduct Authority (FCA number 314493).

Registered Office: The Walbrook Building, 25 Walbrook, London EC4N 8AW. Registered in England and Wales. Company Number: 5172311

z BIG INTERVIEW

www.chemicalindustryjournal.co.uk

SUMMER 2017

Looking to

future needs crucial for the chemical industry Talk to Sean McDonagh and it does not take long for the subject of safeguarding the future of the chemical industry to enter into the conversation.

As the Head of Chemicals for Siemens Industry, based in Manchester, Sean believes strongly that the sector must do more to cope with the twin challenges presented by an ageing workforce and old equipment in desperate need of upgrading.

He says that it is vital that a new generation of workers are brought through to replace the increasing number of long-serving men and women who are retiring and depriving the industry of invaluable experience.

Although that means enthusing children about the chemical industry from primary school age then supporting them as they go through to apprenticeships and university, Sean’s route into the chemical industry was a little more circuitous.

Although he started his career as an apprentice, it was in a very different field to chemistry because he began at sixteen as a helicopter maintenance engineering apprentice with British Airways in the South East.

“I am seeing our industry lose a lot of experienced people, people who have reached their fifties and are now looking towards retirement, and we have to replace them. ”I saw a figure four years ago that said that, within ten years, 50 % of chemical engineers will have retired so we have to bring in young talent.”

Part of the Siemen’s approach to the challenge is the Curiosity Project, a programme aimed at bringing science, technology, engineering and mathematics (STEM) to life for young people in the UK. The project provides free STEM-related resources to schools and Sean said: “The company is doing a lot of work with young

Having being made redundant due to cutbacks in the company, he then worked in sectors as varied as sewage treatment and printing and imaging technology before moving into sales and gravitating to the chemicals and pharmaceutical sectors.

He joined Siemens twenty five years ago and is responsible for managing a highlyexperienced Chemical & Pharmaceutical sales team, with additional responsibility to lead the regional strategic development of the chemical business. As part of his job, he advises on the challenges faced by UK and Irish manufacturers and engineering businesses.

Among the challenges is the impact of an ageing workforce. Sean said: “A few years ago, I became increasingly interested in the idea of safeguarding the future of the industry and a big part of that is ensuring that we have new talent coming through.

I saw a figure four years ago that said that, within ten years, 50 % of chemical engineers will have retired so we have to bring in young talent.

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people, having switched a significant proportion of its sponsorship to encourage them to consider STEM-based careers.

“We have reached 4.5 million children in primary schools, we have five hundred apprentices and 250 graduates. We are trying to get them interested in the subject from a young age and then attract them into the industry as they leave university.”

Sean’s concerns about the future do not stop at ageing staff. He believes it is also vitally important that chemical companies take advantage of the latest technology to upgrade their ageing plants.

As a front runner in the world of automation, Siemens is developing the digitalisation of its own business and the wider industry and the company believes that companies of any size can benefit from Industry 4.0 and the Internet of Things.

These relate to the way technology talks to each other and, for industry, that means creating the ‘smart factory’ in which systems communicate in real time via the Internet rather than being disconnected from each other.

Siemens programmes streamlines processes by connecting hardware and software to not only collect and process data from machines and plants, but to turn that data into competitive advantages. It believes that new technologies provide opportunities to reduce time-to-market, improve flexibility, and increase efficiency and quality as well as allowing companies to individualise products in ways previously considered impossible.

SUMMER 2017

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BIG INTERVIEW z

Sean McDonagh Sean said: “Unlike fast-moving industries like automotives and aerospace, chemical plants tend to be installed and allowed to age.

“It became clear to me that investment was needed to bring them up date and we have done lot of work to bring in new technologies. A lot of our work is promoting the opportunities presented by technologies such as the Cloud.

Despite the challenges, Sean is bullish about prospects for the industry. He said: “I am very confident. Siemens hit the majority of its global targets in 2016 and enjoyed a record year.

“It was a challenging year in some ways because we had the downturn in oil and gas, to which we have exposure in certain divisons, but in fact we exceeded our global targets.

“The skillsets needed by engineers are changing and our message is that more needs to be done to upgrade ageing plant with the new technologies that are now available.

“When the Brexit vote happened last year, I expected a knee-jerk reaction but, although there was maybe two or three months when investment was down, it picked up again.

“Safeguarding the Future is a theme that I am increasingly championing, both in the upgrading of ageing technologies and in the recruitment of the chemical engineers of the future.”

“I think business realised that despite the uncertainty there was still work to be done and we have seen increasing investment, mainly in smaller projects rather that large ones.

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“I am confident that investment will continue.

Indeed, if you look recent research done into the industry, the results predict a three or four per cent global growth over the next five years, slightly down on initial predictions of five per cent but still growth.

“The opening months of our year have seen business in our Process sector 50% up and I do not think that is all down to price.

“Yes, price is always a driver, and we are seeing project managers seeking the best price, but we are also seeing them looking for quality and reliability of service.”

z PROCESS SAFETY

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SUMMER 2017

Progress: our vision for pr safety management In this edition of the Chemical Industry Journal we discuss process safety with Richard Roff an engineer with experience in a number of major hazard industries and Chair of the Process Safety Management (PSM) Competence Project Board.

Richard is a Fellow of the Institution of Mechanical Engineers working for Costain as head of Process Safety. He advises the group on the strategic implementation of process safety management techniques across all of its sectors and service lines but with particular focus on contracts with clients whose operations could suffer potentially catastrophic incidents.

The PSM Competence Programme Board brings together senior industry representatives and stakeholders from trade associations, professional bodies and the Health & Safety Executive to act as proactive advocates of a campaign to make high hazard industries a safer place to work. The Board provides guidance and expert advice on the development of national training standards for process safety management which underpin cutting-edge training courses. It has also published a National Strategy for Competence in Process Safety Management which can be found via the PSM Competence Programme Board webpage, hosted by Cogent Skills.

A STRATEGY FOR ALL

A little over two years ago, the PSM Competence Project Board launched an update to its National Strategy for Competence in Process Safety Management to help UK companies to manage hazards with the potential for major or catastrophic incidents that could cause widespread harm to workers, to the public or to the environment. The strategy’s purpose was simple: To support employers in managing process safety and improving staff competence through targeted quality-assured training, helping companies to obtain the right knowledge and skills at all organisational levels to better manage catastrophic incident hazards and therefore to improve process safety performance across their businesses.

Whilst significant progress has been made, much more can be done. We are pleased that the Chemical Industry Journal is placing an emphasis on process safety management as we strive to take the national campaign to new organisations across the UK – even to organisations that may believe process safety isn’t for them.

It may be tempting to think that events with large losses of life or other major damage can only occur at large scale operations but, on the contrary, business and local economic impacts may well be more significant in smaller enterprises where even small losses might lead to the end of operations, therefore affecting livelihoods and communities beyond those directly involved. Indeed, smaller incidents continue to occur and we can and should do more to prevent these.

In May 2017, The Occupational Safety and Health Administration in the USA issued the report, Process Safety Management for Small Businesses, it reported that, “Catastrophic highly hazardous chemical release events continue to occur among smaller companies.”

It said one study estimated that employers with 1-25 employees are 47 times more likely to have a release and 17 times more likely to suffer an injury, per employee, than facilities with 1,500 or more employees. It also stated that the release of highly hazardous chemicals not only risks employee safety, but the safety of surrounding populations and structures because small businesses often are located in populated areas. Indeed, in our recent history in the UK we have witnessed major incidents at smaller companies; the Bosley Wood Flour Mill explosion, SP Plastics (stored fireworks) explosion and a major blaze at a plastic waste recycling plant in Stoke on Trent. All stark reminders that the practise of process safety management applies to organisations of all sizes. Although full details will emerge only after proper investigation, the catastrophic fire at Grenfell Tower in London suggests there may be room for process safety thinking in sectors beyond those traditionally associated with these approaches.

For any organisation unsure about where to begin their process safety journey there is a wealth of information online. There are also organisations such as Cogent Skills, Health & Safety Executive, Chemical Industry Association, UKPIA, Tank Storage Association and UKPPLG, which are all willing to provide advice and guidance, and throughout the year there are numerous conferences, events and networking opportunities designed to share best practise.

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BUILDING THE RIGHT CULTURE IMPROVES SAFETY PERFORMANCE

The process industries increasingly recognise the importance of the cultural aspects of process safety management. This is due in part to findings from investigations into major disasters in those sectors; Texas City, Chernobyl, Challenger and Columbia investigations concluded that systems broke down catastrophically, despite the use of complex engineering and technical safeguards.

These disasters were not primarily caused by engineering failures, but by the action or inaction of the people running the system in the context of their organisations.

To prevent the harm that can be caused by catastrophic incidents, the PSM Competence Programme Board wishes to drive home the importance of having the right culture.

A properly-focussed process safety culture considers competence, perceptions, attitudes, values and behaviours of the employees throughout the organisation; without doubt, a positive process safety culture depends on its people, especially leaders in the organisation who can drive change and adopt the right standards so that process safety management becomes an integral part of ‘business as usual’.

Boardroom decisions have a direct bearing on process safety outcomes and the Board sets the vision and culture for the entire organisation. Effective governance on process safety is essential for a sustainable business performance. Many companies in high-hazard sectors have made important strides in establishing the necessary corporate culture and leadership to minimise the frequency and severity of process safety incidents and this progress is extremely pleasing.

The PSM Competence Programme Board has overseen the creation of a framework of industry-assured competence standards and supporting training courses, designed to allow employers to apply consistent approaches and deliver the organisational competence required to manage process safety risks, not only contributing to compliance with regulation but also bringing business benefits from loss reduction. It would be prudent for organisations to take a periodic check of their

SUMMER 2017

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rocess safety culture in order to understand whether safety programmes are working reliably to a high level and to understand if the workforce is truly engaged.

When engaging with senior leaders I often ask the question ’how will you know what impact your business decisions have on the level of risk at your sites?’ – and not just now, but several years into the future? This brings focus on understanding the consequences of leaders’ decisions.

Leadership is vital, because it is central to the culture of an organisation, and it is the culture that influences employee behaviour and safety. Process safety tasks can be delegated, yet responsibility and accountability should always remain with the senior leaders, so it is essential that they promote an environment which encourages safe behaviour. It is extremely important to empower employees, to make it ‘safe’ for staff to report issues and to respect and reward them for doing so.

I am a firm believer in this top-down approach; In Costain, our education programme for process safety, began with senior leaders and directors and has been cascaded throughout the organisation across diverse sectors and job roles. We have used the programme of training courses produced through the PSM competence board to give us quality assurance and consistency

ON A FINAL NOTE…

I would like to reach out to major accident hazard organisations to engage with the PSM Competence Programme Board to increase its membership and to improve engagement with trade associations whose members process or handle hazardous substances or manage major accident hazards. My contact details are available on the PSM Competence Programme Board webpage and I would encourage you to contact me if your organisation would like to be part of the movement to safeguard people and the environment and to promote UK major hazard industries’ best practices on a global scale.

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PROCESS SAFETY z

z PROCESS SAFETY

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SUMMER 2017

2017 will see over 8000 delegates go through the Cogent Skills Process Safety Management Programme Cogent Skills sits at the centre of the science industries and supports all levels of vocational training, qualifications and skills development across a wide range of industry sectors.

One of the key focuses for Cogent Skills, as determined by employers is Process Safety Culture and Awareness. Their unique approach is to assist companies in improving process safety at three distinct levels (Strategic/ Leadership Level; Tactical/Management Level; Operations Level) and establishing a strong organisational process safety culture, within the organisation.

Cogent Skills has worked with the industry led Process Safety Management Competence Programme Board (PSMCPB) to develop a comprehensive Process Safety Management Programme and a portfolio of courses which are underpinned with industry specific training standards designed to ensure relevance and secure impact. Members of the PSMCPB include CIA, HSE, BACS, UKLPG and key industry partners who continue to meet to ensure the relevance of the standards within industry.

Each of the Process Safety Management courses are relevant to COMAH and non COMAH sites, where operators are handling or processing potentially hazardous materials, and could be exposed and vulnerable to explosion, loss of containment or other major accident hazards which may pose a threat to the environment or general public. Cogent Skills can adapt their courses and select trainers so that the course is particularly relevant to the organisation.

The HSE has recognised that companies who adopt these standards can achieve effective Process Safety Management. The Better Regulation Executive (BRE) has recognised this training as good practice in addressing the Principles of Process Safety Leadership.

Ron Ramshaw, Health and Safety Manager at Interconnector said, "the Process Safety Leadership for Senior Executives course was very well received by all participants and it has helped improve our levels of Process Safety understanding - we couldn't have done it without Cogent Skills!

In 2017 Cogent Skills will see the 8000th delegate go through the programme.

However, only 170 COMAH sites have taken part. The PSMCPB including the CIA have recognised that this is not enough. It is strongly advised that more Major Accident Hazard organisations adopt these standards to prevent major accidents occurring and

limit the consequences to people and the environment as well as the business.

• Improving stability, productivity and product quality

Andrew Mawson, Group SHE Manager at px Group commented, ‘the course syllabus matched almost exactly the level of process safety knowledge that we wanted our Process Safety Champions and Sponsors to have. In addition the course lends itself to training our next generation of process safety leadership.

The Foundations course has been excellent. All attendees have been very positive and have said how much the course has increased their competence and allowed them to support the other sites in the improvement of process safety performance.”

• Protecting & enhancing corporate image

Cogent Skills also understands that a company may have its own culture and this should be recognised and integrated when process safety training is designed and deployed. In order to enable this, there is a bespoke solution that can be adapted to any organisation in order to match the standards with existing policies, procedures, processes and systems.

This Program goes much further than increasing process safety awareness. It has also been designed to impact on business performance by: • Reducing costly process incidents, downtime and maintaining process operations

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• Enabling effective life cycle plant management and asset realisation • Developing the tools and knowledge to implement a process safety culture through the business “Before starting the PSM training, the companies focus was on the shift from personal safety to process safety. Following the training we have improved our process safety culture and performance through enhancing personal safety with process safety.

Cogent played a central role throughout, and the fact the programme is developed by peer companies is very valuable. The participants noted it was the most relevant training they had ever been on.”

Tony Johnson, Production Support Manager, Huntsman Polyurethanes (UK) Ltd. The key to safety is in your hands, is your process safety up to standard?

If you would like to find out more information about what is available, you can contact Cogent Skills on 01325 740900 or email industry@cogentskills.com

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Process Safety Is it time for you to adopt the standards?

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www.kindlow.co.uk 0800 634 8565 info@kindlow.co.uk

PROCESS HAZARDS INVESTIGATED

Process Safety Process safety is a vital part of any operation but the knowledge and expertise to achieve it may not always be available in house.

At Kindlow Safety Services your process safety is our number one priority. We understand that it is necessary to control hazards and potential hazards such as dust explosions, thermal decomposition and runaway chemical reactions in order to achieve safe operating conditions. Our dedicated team have decades of experience originating from industry and can provide expert knowledge and advice to support you in achieving your safe working parameters; whilst our fully equipped laboratory can provide the test data required to meet legislation.

Our fully equipped laboratory can perform a full range of process safety testing including; Chemical reaction hazards Runaway reactions Dust explosion testing REACH Aerosol safety testing

Based on decades of science and experience our experts can offer specialist consultancy and advice to assist with your process.

Tailored training courses designed to increase your staff’s skill levels and breach any knowledge gaps.

Understanding Process Safety Management ...and having the right test data for you A successful Process Safety Management system starts with getting the basics right. No amount of technical safety measures or operational procedures will save your plant if your power supply is failing monthly. No Risk Analysis methodology will protected you from undefined or inexact risks. If you have a poorly designed process, in the first place (i.e. erratic yield, quality or through-put), you will not be operating the originally analysed process six months down the line.

Therefore the three fundamentals of Process Safety Management are:• Good engineering practice • A robust process design • Good safety data Once these three foundations are in place the next step is a structured Risk Analysis, to identify the known hazards so that effective Measures can be deployed to control known Risks to an acceptable level. The most popular methodology to achieve this is HazOp, although other check-list based methods are available. In cases where the hazards are exceptional or potentially wide ranging then further analysis such as QRA and dispersion modelling may be required, additionally.

There is an excellent website www.harsnet.net where these three fundamentals are examined in detail.

All of the above and a suitable Management of Change System (MOC) must be incorporated into a Formal Management System (POCMARS, Plan, Organise, Control, Monitor, Audit, Review and Spotcheck) in order to achieve effective process safety management.

Good Safety Data This can be divided into two types: 1. Data related to substances Physico-chemical properties such as; flash point, auto-ignition temperature, flammability and explosive properties, to name a few can be determined through appropriate testing. For example test data required for a dust include; Kst/Pmax, Minimum Ignition Energy (MIE), Minimum Ignition Temperature (MIT) and Layer Ignition Temperature (LIT).

The thermal stability of reaction masses can also be quantified, which may include the intermediates as well as the starting and finished products. For this an under-standing of such terms as Time to Maximum Rate (TMRad), Onset Temperature, point of no return and gas evolution among others is required.

Kindlow Safety Services can help determine your testing requirements; which can then be performed in our fully equipped laboratory.

2. Data related to the chemical reaction Data can be obtained in a range of different sets of apparatus. The type used will depend upon the data required. Such things as; Heat of Reaction, Heat Capacity, Adiabatic Temperature Rise, Rate of Heat Production, Amount of Heat Accumulation, Gas Evolution, Effect of Maloperation (runaway reactions) can be determined.

Kindlow Safety Services can provide chemical reaction hazards testing to define the characteristics of your chemicals and their safe processing parameters (Process Hazard Investigation). Our dedicated team have years of experience and skilled knowledge in chemical reactions hazards and can help you determine your Basis of Safety. Through our roots in industry our team can also give further support by interpreting the results obtained from testing to offer solutions and guidance for your process.

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People Plant Process Productivity

z PROCESS SAFETY

SUMMER 2017

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Process Modelling improves plant safety Dynamic simulation can provide a way to document and understand the complex risks of process plant, while paying for itself in improvements.

Dr. Ben Firth Technical Director, Flex Process

The first step of risk assessment is by now very familiar to all of us: Identify the hazards.

This is true whether we’re assessing an office or a chemical plant. Once we know what the hazard is, we then move on to understanding the impacts it can have, and how we may prevent it. However, there is a significant difference between assessing slips, trips, and falls, and the hazards of industrial chemical processes. Complexity.

Complex processes present complex hazards.

In fact, even seemingly straightforward processes present complex hazards. Runaway reactions, overfilling, utility failures, etc. can happen at any site. While larger chemical processes tend to involve significant interactions between plant, assessing process hazards properly is never simple. This is why we rely so heavily on well-run hazard studies, with a multidisciplinary team to carry them out.

Over the last half a century, hazard studies have developed from a set of internal processes within ICI, to a standardised, methodical approach used around the world. In parallel, quantitative risk assessment has grown, responding to the needs of process safety professionals to answer the big question: “What if?”

Meanwhile, dynamic process simulation has emerged from the technological revolution.

Process simulation is the modelling of plants and equipment using computer software.

Dynamic simulation involves running these

models in a time-based way, to see the effects of changes or failures. Physics, chemical, engineering, and thermodynamic equations combine to calculate every aspect of a process, every fraction of a second. Originally limited by the available hardware, complete plants can now be built, running real-world processes in a virtual setting, faster than real-time on today’s powerful PCs. While many are familiar with these models in Operator Training, or occasionally for one-off safety studies, their use in hazard studies is a newer phenomenon.

Imagine carrying out a hazard study by going out onto the built plant, and testing the failures. “What if this pump fails?” Turn off the pump. “What if this controller fails?”

Override the controller. Obviously impossible, both for design (when the plant doesn’t yet exist) and for existing plant (where intentionally introducing failures is manifestly unacceptable). This is what dynamic simulation offers the hazard study team; the opportunity to break the plant, and see and record what happens.

By integrating models into the hazard study, the risk assessment process can be greatly enhanced. Once a model is built, systematically going through the failure modes for equipment is trivial. This means that answers can be generated at the HAZOP table. Complex cases, such as site wide power or instrument air failure, can be run with a single click.

Identifying process hazards has never been more straightforward.

In the same act of identifying the hazards, the modeller is instantly presented with the effects. Vessels overpressure, relief valves open, pipework floods. These quantifiable results can then feed directly into the risk assessment. No need for gut feel, or rules of thumb.

Moving further through the steps, the mitigation measures can be studied. The effectiveness of controls and trips can be

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validated. Timings, peak pressures and temperatures, or any other process data can be instantly used as part of the Layer of Protection Analysis (LOPA). Set points can be tuned, and unexpected effects identified. The design can be demonstrated to be effective before a penny is spent.

Throughout this process, a library of hazardous scenarios is compiled, fully accessible and repeatable. This can then be integrated into the site’s Process Safety Management system.

When new safeguards are designed, their testing in the models can be validated and documented. Management of Change can integrate model testing into the process, so that the impacts of the change can be instantly assessed against the scenarios associated with the equipment.

By creating an accurate model of the plant, efficiency and debottlenecking opportunities are practically a by-product. In our experience, a model will ultimately pay for itself in terms of the plant improvements it makes available. The model provides a meeting place for engineers of all disciplines. Planners can predict the effects of new feedstocks. Control engineers can test their designs against a simulation which responds realistically.

Operators can be trained in how to handle the hazards they will hopefully never see. All of this may seem to put dynamic simulation into the “too good to be true” category, but it’s not.

It’s a platform which improves safety while increasing profits, available to everyone. It’s the future.

For more information visit www.flexprocess.co.uk or contact enquiries@flexprocess.co.uk

z PROCESS SAFETY

SUMMER 2017

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Overpressure Contours

Schematic of asset location

Cost–benefit analysis

Concept 1 - Wall strap retrofit

Concept 3 – Wall post retrofit

Concept 4 – Wall shield upgrade

Risk based building upgrades What to do when your risk study shows you have a problem Operators undertake a range of consequence and risk assessments to satisfy legislation that requires facilities handling hazardous materials to demonstrate the resulting risks are as low as reasonably practicable (ALARP).

Two common types of risk assessment for decision making are occupied building risk assessments (OBRAs) and quantitative risk assessments (QRAs). However, it can be difficult to translate the output from these analyses into a structured, well-balanced and defensible programme of effective risk mitigation that demonstrates ALARP has been achieved.

BakerRisk is aware of this challenge and has developed industry leading methodologies, softwares and services to support end users in navigating this process across complex sites or multiple facilities. A thorough approach to risk assessment and mitigation for buildings involves the systematic analysis of flammable, toxic, thermal and explosion hazards and the subsequent review of mitigation options for each hazard type. For simplicity the example presented here focusses solely on mitigation of blast risk through building upgrade.

The example images above show three blast resistant upgrade options available for an example occupied building, predicted to have an intolerable blast risk in its as-built condition. The level of protection differs for each of the concepts with each level

of upgrade and risk mitigation having an associated cost as can be seen from the riskcost chart. Concept 01 provides the lowest level of protection, mitigating blast risk to just within tolerable levels. Concept 04 provides the highest level of protection, exposing the building occupants to minimal risk.

This illustrative example only requires upgrade of the walls to adequately mitigate the risk associated with calculated explosion hazards.

Because of the simplicity of this example the risk-cost relationship is mostly intuitive.

However, quantifying both cost and risk gives operators valuable and defensible information on which to develop a risk mitigation programme, especially since these types of investigations are often more complex. For example: • Building with vulnerable roof systems or structural frames often have significant variation in risk mitigation design and upgrade cost; • Widening of the study to include a replacement new-build or series of newbuilds sited away from the process units posing the hazard; • Relocation or management of personnel within a building; • Removing or reducing the controlling hazards at source.

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When it comes to blast risk assessments, evaluating occupant vulnerability rather than building damage levels (BDLs) is critical when quantifying building individual risk (BIR) and building societal risk (BSR). Each building and upgrade is case specific, being analysed for that particular arrangement, rather than using generic building types. This is a significant refinement on historic approaches to OBRAs and QRA and adheres to guidance on occupied buildings published by the Chemical Industries Association, which specifically allows for the risk based design of occupied buildings.

Whilst risk to personnel is the principal driver from a legislative perspective, increasingly operators are seeing the value of also factoring in analysis of the vulnerability of critical equipment and control systems to these analyses.

In order to perform a risk based assessment for onsite buildings, BakerRisk can utilise either BakerRisk consequence and risk data or third party building risk data to develop mitigation schemes. These mitigation schemes are intended to be dynamic, with the ability to evaluate impacts from future operational changes such as the addition of process units, changes in operational conditions, occupancy distribution, etc.

Providing solutions to manage hazards and risk since 1984.

For over 30 years, BakerRisk has been successfully working with our clients to identify and analyse the risks posed by their operations and provide them with practical and pragmatic risk mitigation solutions to close the gaps highlighted by the analysis. Our staff has diverse expertise and experience in all facets of hazard and risk management, complemented by our state of the art laboratory and testing services, R&D programmes, and incident investigations.

The synergies of these capabilities makes BakerRisk truly unique in the industry. BakerRisk has over 160 employees operating across 6 main office locations. BakerRisk Europe Limited is the UK based entity of BakerRisk primarily serving clients in the UK, Europe, the Middle East, and Africa.

Our key services are: · Process Hazard Identification and Analysis · Structural Design and Analysis · Blast and Explosion Impacts · Process Safety Auditing and Oversight · Risk Management · Incident Investigation · Insurance Risk Engineering

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Or visit us at www.BakerRisk.com

A week in the life of Dr Carol Treasure first witnessed animal testing while working in the pharmaceutical industry and during her degree in Physiology and Pharmacology at Sheffield University, and resolved then that there had to be a better way, not just ethically, but scientifically, too.

She went on to complete a PhD at FRAME (Fund for the Replacement of Animals in Medical Experiments), followed by seven years with Cascade Biologics. Setting up Cascade’s European operation in 2003, Carol was able to use her scientific knowledge in a commercial context, preferring an environment where her skills could be used directly to make a positive impact on the industry and ultimately, replace animal testing.

When Cascade was acquired by a big corporation, Carol co-founded XCellR8 with Bushra Sim in 2008. The company provides animal-free safety and efficacy tests to the chemical industry, and uniquely, enables clients to claim regulatory compliance without the use of animals or animal products in their testing programmes.

Dr Carol Treasure Founder and

Non-Anim Managing Dire ctor of al Testin g Lab, XC ellR8

Monday

Wednesday

The week kicks off with a client meeting where I’m presenting to a group of scientists about how our skin sensitisation tests work. I explain why companies need three different tests (DPRA, KeratinoSens and h-CLAT) and what they measure.

I love this kind of meeting; you can see lightbulbs going off as people gain a deeper understanding of safety testing, and particularly how animal-free tests are scientifically advanced in terms of the results they deliver. The company has over 20 ingredients that need to be tested for the REACH deadline in June 2018, as do many other clients, so we see a busy summer ahead of us.

A number of new clients have contacted me asking for information about our safety tests so the day is spent liaising with our Study Directors and QA team. Because our testing methods are so innovative, people like to understand the methods, ask about the amount of sample we need and check pricing and turnaround times, which I think they’re always pleasantly surprised by, especially if they have been used to commissioning animal tests in the past.

Tuesday I’ve set this day aside to work on a grant application for a large R&D project we are leading and an early morning session in the gym gets me in the right frame of mind.

The project aims to continue development of our human cell based screen for acute toxicity – the only human health endpoint in REACH that doesn’t currently have a validated non-animal test. Our goal is to change that, by replacing the rat LD50-type tests with an approach that is far more relevant to real human exposure, and to achieve regulatory approval.

The funding will be significant, and the project will take at least three years, so the paperwork is similarly significant! But well worth it.

I take a minute in the afternoon to update our social media channels. One of our young scientists has an alternative life as a filmmaker and we discuss filming more videos of our work in the lab to share with people who can’t get to Daresbury to see it for themselves.

Thursday An exciting day today. I head to London to meet a high street giant who wants to talk about outsourcing the testing of their chemical ingredients. They’re a brand who care passionately about Corporate Social Responsibility and so I believe our combination of robust science, without the use of animals or animal derived products is appealing to their customers. I find it inspiring just sitting in the foyer of their HQ, and quickly find myself writing the synopsis of a blog post before I head in.

Friday After a long day yesterday, I give myself some time to walk the dogs before heading into the office.

My task list for the day includes preparing a presentation I’m giving to an industry conference in a couple of weeks’ time, reviewing CVs for the new laboratory technicians we need and checking in with the lab to see how the week has gone and what’s on the schedule for the rest of the month. By late afternoon, it’s wine o’clock and time to close the laptop. www.x-cellr8.com

Safe, and sound Animal-free, regulatory safety tests XCellR8’s GLP accredited laboratory provides companies with test results to demonstrate product safety and meet international regulatory requirements.

Our innovative in vitro methods enable you to adopt animalfree testing strategies that are both scientifically advanced and ethically sound.

With turnaround times as short as 4 weeks, why not ask us for a quote today?

REGULATORY Skin sensitisation Skin irritation Skin corrosion Eye irritation ALSO AVAILABLE Genotoxicity Cytotoxicity Acute toxicity

+44 (0) 1925 607 134 info@x-cellr8.com www.x-cellr8.com

z SOLVENTS INDUSTRY ASSOCIATION

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SUMMER 2017

The growing influence of the SIA Originally formed in 1973 as the Hydrocarbon Solvents Association, the Solvents Industry Association (SIA) as it is known today came into being a decade later when its scope was broadened to encompass the full range of chemical solvents. The SIA exists to promote the safe, sustainable and responsible use of solvents and solvent-based materials in the United Kingdom, although in practice its influence spreads far beyond this country.

Despite being based in the UK, the Association maintains a close and growing partnership with CEFIC, in particular with the European Solvents Industry Group (ESIG). The SIA is unique in that it is the only national trade association within Europe to represent the solvents industry. Its expertise and experience allows SIA member companies to directly contribute to and benefit from wider initiatives across Europe. This growing influence has been particularly evident in the past decade and looks set to continue to grow.

The Association’s strength is its members.

The membership is drawn from the complete supply chain and includes solvents manufacturers, distributors, hauliers, storage companies, packaging suppliers and other industry stakeholders. All member companies contribute to the Association’s output and the complete coverage of the supply chain gives the SIA its unique perspective on all aspects affecting the solvents industry.

Although it is led by its Executive Committee, the SIA’s powerbase is its Technical Committee, whose current Chair is Dr. Rob Oades of Shell Chemicals. Both committees meet quarterly, with the Technical Committee’s membership being drawn from 15 experienced technical personnel from member companies and whose range of activities cover all matters relating to Safety, Health, and the Environment (SHE). The group shares their knowledge

and expertise on industry best practice with Members, end-users and regulatory authorities. SIA members and committees come together each year for the Annual General Meeting where the activities of the Association are presented and industry-related guest speakers also address the Membership.

Speakers at this year’s AGM, which will be held in Cheshire in October, will be covering topics as wide-ranging as the “Trump Effect” on the chemical industry globally, REACH in the United Kingdom after Brexit, and the chemical industry in the North West of England.

So what does the Association do? Its three cornerstone activities are Product Stewardship, Advocacy and Communication. All are familiar words or phrases within the chemical industry but for SIA Members there are specific outputs generated from each area.

PRODUCT STEWARDSHIP

The SIA encourages best practice, principally through the publication of a series of Guidance Notes which cover all matters related to SHE. These notes are published, monitored and reviewed on a regular basis by the Technical Committee, whose industry experts are able to share views and formulate the Notes. Subject matter for these Guidance Notes includes the appropriate type of IBC to use for each solvent, working in confined spaces, solvents and static electricity and

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even how much solvent to fill into packages.

We all know the hazards that many solvents carry, but their use is often crucial to the modern way of life. In certain instances there is little or no alternative to the use of a certain solvent so all steps must be taken to enable its safe. Web-based Guidance Notes are a prime example of how best practice can be communicated across the industry on a global level.

ADVOCACY

The SIA regularly consults with and advises UK industry and regulatory bodies through its advocacy work, often working in partnership with bodies such as the Chemical Industry Liaison Group. Recognising the global aspect of the solvents industry (some of the Association’s members are global multinational companies), the SIA also has close contact with European legislators through its links with ESIG, enabling it to keep abreast of and influence international industry trends and developments.

COMMUNICATION

Perhaps the most valuable output from the SIA in recent times has been from the

SUMMER 2017

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SOLVENTS INDUSTRY ASSOCIATION z

Main image: Filming of the forthcoming transport safety film at a facility in Rotterdam Below: Drum filling – a source of static build-up

production of a series of safety films designed for all companies and employees handling chemical solvents. The most recent covered ‘Safe Handling of Solvents’, ‘Solvents and Static Electricity’, and ‘Solvents and IBCs’.

So far more than 10,000 copies have been distributed across Europe and beyond in five different languages. The SIA has also been the driving force behind an ESIG-produced film covering the ‘Safe Use of Gloves’. A further film covering the ‘Safe Loading and Transportation of Solvents by Road’ is currently in production and is due to be released later this summer. At first glance, many of these topics can appear to be unexciting but anyone who has viewed readily-available film clips of incidents which have taken place involving road tankers or in the filling of IBCs will be fully aware of the unseen risks which can exist in the handling of solvents. Preventative actions, assisted by such documents and visual aids as the use of Guidance Notes and safety films can only improve the practices of individuals handling solvents, wherever they may be.

seeking greater knowledge of the solvents industry. In the past three years it has already been delivered to over 200 delegates and has been rolled out across Europe in collaboration with ESIG. Such has been the success of the course that the Association is now in the final stages of launching its follow-up, ‘Solvents and their Applications’. Training is an integral part of any solvents education programme and these courses reinforce the SIA’s commitment to Responsible Care and to Product Stewardship, a fact recognised when the SIA was awarded the coveted SME Assistance Trophy by the Royal Society for the Prevention of Accidents (RoSPA) in 2013.

In addition to the production of safety films, the SIA is now presenting training courses. The most recent, ‘An Introduction to the Solvents Industry’, is aimed at new starters or those

Said to regularly punch above its weight, the SIA is now well established among the European chemical industry as a constructive and positive contributor to all matters

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related to the safe use of solvents. SIA General Secretary Andrew Norman commented, “Despite being a relatively small UK-based trade association, our outreach is now truly global. Whether it be the on-line availability of our safety films, training courses or Guidance Notes, the influence of the SIA now enables all sectors of the solvent-using supply chain to implement best practice wherever their operation may be.”

For further information, visit the SIA website at www.solvents.org.uk

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Post Brexit opportunities for Brenntag UK & Ireland Chemical Industry Journal asked Russel Argo, President Brenntag UK & Ireland for an update following the feature in the Spring issue.

WHAT IS THE CURRENT LEVEL OF BUSINESS CONFIDENCE IN THE UK CHEMICAL SECTOR? HOW WOULD YOU RATE THE IMPACT OF BREXIT?

There is certainly a degree of nervousness about what the outcomes of Brexit negotiations may bring in terms of trade fluidity with Europe. Recent devaluation in sterling versus the dollar and euro have meant any imported materials have proven to be more expensive than in the previous seasons, which has put many of our customers under pressure of increasing cost of manufacture.

Brenntag have been working very hard to try to mitigate and reduce the impact of this for all of our customers in the UK. I am supremely confident in the adaptability of our customers to be able to react to current changes. We supply chemical ingredients and products to the majority of British chemical industry and we have always recognised our customers’ innovative excellence, ability to respond to change and to seek new opportunities. Our agility, close working partnership with suppliers and customers and of course Brenntag’s economies of scale continue to be our ongoing strength. Brenntag UK & Ireland has the unique ability to assist our customers with various aspects in order to seize opportunities, whether in terms of formulating new products or providing alternative supply chain solutions. Certainly should we find a situation where importing material from the EU becomes more challenging or more expensive with for example trade tariffs, then we will be looking to the wider global marketwhich of course is easier for us with the global reach of the Brenntag Group.

WHERE DO YOU SEE THE MAIN OPPORTUNITIES FOR BRENNTAG UK& IRELAND IN THE NEAR FUTURE?

I believe change is good because we are uniquely able to adapt and support the change in the market place. We will always seek to ensure we have the right supply chain in place in terms of quality and value for our customers, across the complete range of their relevant requirements, be it technical and formulation support, sales, commercial or logistics. In order to achieve this, we will continue to invest and offer even higher level of expertise to serve them effectively across all sectors.

We focus on continuously enhancing our fleet’s efficiency in line with sustainability

and safety targets set within Brenntag.

For instance, only last week our Brenntag Sandbach site took delivery of 16 new Volvo Euro 6 vehicles as part of our ongoing investment plan to deliver Brenntag sustainability and safety strategy crucial to our long-term business success.

Throughout all our developments, customer service is always at the forefront of our planning and investment. Our program of investments allows us to offer our customers an even more comprehensive range of added value services for both life and material science sectors. We have built on our expertise in various markets, for instance dyestuffs, pigments and performance products through our well established Brenntag Colours business. Our Solvents business is having a really good year with good volume growth particularly in packed with some great market opportunities lined up; we continue to invest and our new life science filling facility scheduled to be completed very shortly will further our growth in the food/feed and pharma sectors.

We are progressing a great number of projects across the industries we operate in: actively developing the markets of metal surface treatment, agrochemicals and renewable energy, making a step change in oil & gas, paper, rubber & polymers, animal nutrition, building on our successes in cosmetics & pharma, food, coatings & construction, and industrial cleaning. We have always been an industry leader in water treatment, and have further invested in our technical and commercial capabilities in this sector with the expansion of the technical team, creation of a new water treatment laboratory for customer specific trials, and extension to the product range to achieve a highly efficient delivery process for our customers.

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LAST TIME WE SPOKE ABOUT A NUMBER OF ONGOING PROJECTS; COULD YOU UPDATE US?

Our product portfolio has been expanded with new distribution agreements and innovative product lines across all industries.

Ingredients supplied by Brenntag are on the list of some of the most innovative- as well as the most popular - products we purchase as consumers. Our teams have been instrumental in supporting formulation development of products and services across life science, material science and environmental applications. For example, new exciting products for consumer car and van market have been developed by our AdBlue team and recently launched at the Forecourts Show at NEC, Birmingham.

The offering of Brenntag Blending Services (BBS), which already maintains the highest level of service at a number of strategic operational locations across the UK & Ireland, is this year set to expand even further as we upgraded our blending facilities and the application laboratory at Bradford BBS facility.

We have just completed the major multimillion pound investment at Lutterworth, opening a brand new standalone blending facility which will enable us to meet all our customers’ solutionising needs, servicing the Midlands, the South of England and Wales.

The Brenntag Food Application Centre featuring formulation, product and stability testing is also completed and fully functional at our Widnes food hub site. To best enable our business partners to compete in today’s market and fully leverage our expertise in food applications, Brenntag food & nutrition team organises seminars, bespoke technical sessions and innovation workshops, featuring presentations by our key suppliers and industry institutes.

BRENNTAG UK & IRELAND The distribution of chemicals and ingredients is not just a business to us. It is our ambition to create true value for our partners through unrivalled market access and expertise.

We are the full line specialty and general chemicals distributor, offering: ■■■ ■■

LIFE SCIENCE MATERIAL SCIENCE ENVIRONMENTAL

www.brenntag.co.uk

■■ ■■ ■■ ■■

Strong market focus Dedicated team of industry experts Technical application facilities Unrivalled infrastructure Sector-specific accreditations Full commitment to safety

SUMMER 2017

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Global registration of chemicals How to make a core data set and secure data access The EU legislation on chemicals has set a new standard for registration of chemicals worldwide. Similar initiatives to strengthen the chemicals legislation are seen in many countries including China, Japan, Malaysia, Taiwan and Turkey. In the Republic of Korea, the new chemicals legislation (called K-REACH) became effective on 1 January 2015. Just like the EU legislation, K-REACH includes data requirements and risk assessment of all chemicals on the market.

This trend has a common background; a political intention to protect people and the environment from effects from hazardous chemicals. At the same time, there is a growing awareness of the lack of knowledge of the toxicological and ecotoxicological properties, and the actual use of a large volume of the substances on the market.

ADDRESS THE CHALLENGE

International suppliers of chemical substances should be prepared to address this regulatory challenge by collecting available – or procure access to all necessary – substance data. In other words, you should create a core data set. Data should include substance identity, physical-chemical data as well as available toxicological and ecotoxicological data.

RESTRICTIONS ON LETTER OF ACCESS

Access to data obtained via a Letter of Access (LoA) from an EU based consortium is normally restricted for use only within the EU. A new agreement is required if registrations are made outside of the EU and often the LoA does not allow sublicensing to co-registrants.

Together with the frequently high price for an LoA, these issues can be a barrier to the re-use of data across borders. Since GLP testing in qualified labs (OECD MAD compliant) is much cheaper in Asia, it is tempting to simply repeat the testing in order to get the full ownership.

WORRIES ABOUT DOUBLE TESTING

The EU industry is concerned about duplication of tests. Not only does the duplication of test entail the use of additional test animals, but may also give different test results. These will have to be considered by the EU registrant in their dossier updating if the results become publicly available.

OUR ADVICE: CREATE A CORE DATA SET

On a global scale, the requirements for registration of chemical substances are increasing. It is important for manufacturers and suppliers to prepare a strategy for their regulatory compliance in order to secure the markets. DHI advise clients to create a core

© Shutterstock / isak55 data set for all substances in their portfolio and to clarify data ownership, access to data and their user rights. The mapping should be matched against the data required by the authorities in the relevant countries to identify data gaps to be filled.

EXAMPLE OF SIMILAR DATA REQUIREMENTS

The data requirements are similar in the EU, China and the Republic of Korea. The table shows the requirements at the tonnage band from 10 – 100 ton per year. In general, test following OECD standard methodologies from GLP certified (MAD compliant) laboratories can be used. Non-test methods such as read-across and QSAR backed by adequate justification are also accepted. Sharing of data on vertebrate test data is mandatory in Korea but not in China, although the Chinese authorities encourage this. The Korean legislation enforces data sharing but it is possible to waive this if a ‘justifiable reason’ can be given, such as for reasons of confidentiality. It is also possible for a Korean registrant to waive joint submission due to cost reasons.

In the past 10 years, DHI has cooperated closely with the Korean research and consultancy institute KIST Europe, which has represented Korean chemical companies in the EU since 2006. As a Korean legal entity, KIST Europe provides services in K-REACH together with DHI. Through this unique collaboration, we have a long record of services to industry within all fields of chemicals regulation in the EU and abroad.

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EU

China

Korea

Skin irritation

x

x

x

Eye irritation

x

x

x

Skin sensitization

x

x

x

Mutagenicity

x

x

x

Acute toxicity

x

x

x

Repeated dose toxicity (28d)

x

x

x

Reproductive toxicity, screening

x

x

x

Toxicokinetics

x

x

x

Daphnia immobilization

x

x

x

Algal growth inhibition

x

x

x

Biodegradation

x

x

x x

Fish acute toxicity

x

x

Activated sludge inhibition

x

x

Abiotic degradation

x

x

x

Adsorption/ desorption

x

x

x

Terrestrial organisms toxicity

x

Fish long term toxicity

x

Daphnia long term toxicity

x

Bioaccumulation

x

Data requirements at the 10 – 100 ton per year level

For more information on DHI services within Product Safety, Environment and Toxicology: DHI Denmark Tel: +45 4516 9200 www.tox.dhigroup.com

CHEMICALS FOR YOUR GLOBAL MARKETS • • • • •

Risk assessment and regulatory compliance Worldwide chemical registrations IUCLID dossiers and other formats Alternative approaches to data gap filling Grouping, QSAR and read-across

Visit us at tox.dhigroup.com

DHI Agern Allé 5 DK-2970 Hørsholm Denmark

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SUMMER 2017

Last leg of REACH registration just around the corner The last REACH registration deadline on 31 May 2018 completes what started already in 2008: collecting information on all the chemicals in use on the European market and closing the gap of not having data on existing chemicals to do proper risk management. It is yet another important milestone towards the safer use of chemicals worldwide, and the European chemical industry is pivotal in making this happen. much information available on the low volume substances. This means that companies need to budget both time and money for generating the data needed for registration.

Smaller companies do not have the same resources as large ones. They are going through their portfolios very carefully, assessing which chemicals are really needed for the success of their business, and what the market demand and conditions are. As REACH registration is a long-term investment in product stewardship, a knowledge of the future market is also important. But, looking at the future in the current economic and political climate is not easy.

Christel Musset

Director of Registration European Chemicals Agency All existing chemicals manufactured or imported in the European Economic Area between 1 and 100 tonnes a year need to be registered by 31 May 2018 with the European Chemicals Agency (ECHA). This is the last deadline under REACH, and completes the transition period of 10 years for existing chemicals under the regulation.

This last deadline is the most challenging one, both for companies and ECHA. Firstly, the sheer volume of registrations will be two to three times more than in the previous deadlines. Secondly, many of the companies involved are expected to be inexperienced and small and medium-sized enterprises (SMEs). Thirdly, there is not that

Based on anecdotal feedback we get from our stakeholders, many registrants, maybe even a majority of them, are leaving the decision to register very late. This is obviously a challenge for their customers who would need certainty that the supply of their critical substances will continue even after the deadline. We are also interested in companies’ registration intentions to help us to better prepare for the workload next spring, and can only encourage them to be transparent to the extent possible and share this information with us.

Leaving the registration decision to the last moment creates additional challenges, as registration takes time even for the simplest cases. If a company needs to start from scratch, it has to reserve time for analytics for proper substance identification, discussions on data and cost sharing with co-registrants, and for gathering the information needed for registration. We know that many potential registrants are importers who might find it difficult to get information from non-EU suppliers.

Data on the substance’s properties, its impact on human health and the environment, and

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instructions for its safe use need to be provided in the registration dossier. When planning the schedule, it is good to take into account that that the laboratories doing analytical testing may be fully booked for months. Thankfully, there are now a variety of ways in which companies can estimate the likely effects of their chemicals without testing on animals.

It is now even mandatory to consider them before conducting any tests on vertebrate animals. Using alternatives to animal testing is not a quick fix though – they require specific expertise as their use needs to be scientifically justified in the registration dossier.

It is clear that complying with REACH is a demanding task, but it is manageable.

More than 10,000 companies have already successfully registered since 2010 with help from the national authorities, industry associations and ECHA. All these organisations

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are ready to support also the 2018 registrants.

ECHA’s REACH 2018 web pages offer a one-stop shop for registration advice in 23 EU languages.

With less than a year to go to the deadline, companies should be at full speed with their preparations. We expect to receive up to 60,000 registrations for 25,000 substances.

With less than a year to go to the deadline, companies should be at full speed with their preparations. We expect to receive up to 60,000 registrations for 25,000 substances.

This estimation is based on the calculations of the European Commission back in 2007, which we are trying to amplify by surveying industry associations and companies.

In June 2017, companies have submitted around 10 000 registrations for close to 5 000 low volume substances, with German, British and Dutch companies topping the chart. This is in line with our expectations. We have received fewer 1-10 tonne dossiers than estimated, whereas the 10-100 tonnes dossiers are coming in as predicted. This might be because companies registering more than 10 tonnes a

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year need to prepare a chemical safety report and, therefore, start to prepare early.

It is clear that the peak of submissions has not started yet, but we expect an increase in the last quarter of 2017. We are preparing now for the biggest peak to arrive one to three months before the 31 May next year.

I encourage you to register as soon as you are ready. This allows you to avoid a last minute rush. If you have to submit several registrations, and this is the first time you are doing it, a good idea is to choose one or two substances to start with so that you can get familiar with our process and tools. Another important aspect is to start discussions on forming the joint submission as soon as possible. This is a crucial step that can delay the progress later on.

z REACH

SUMMER 2017

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REACH and Brexit – Select Committee provides a reality check

The House of Commons Environmental Audit Committee has published the results of its inquiry into the future of chemicals regulation post-Brexit. Peter Newport, Chief Executive of the Chemical Business Association (CBA) considers the Committee’s findings. be that simple or straightforward. Since then, these murmurings have increased in volume.

The House of Commons Environmental Audit Committee (EAC) has now echoed many of the industry’s concerns - particularly about REACH and Brexit.

Its findings clearly show that it recognises the industry’s concerns and its report calls on the Government to take urgent action to resolve a number of key uncertainties in relation to the regulatory framework for chemicals postBrexit.

Peter Newport

Chief Executive of the Chemical Business Association (CBA) Immediately after the referendum result, it all seemed so simple. The Brexit Secretary, David Davis, said, "Britain must be back in control.

And that means EU law must cease to apply.

EU law will be transposed into domestic law on exit day.”

At the time, there were murmurings from industry organisations that things might not

In the words of the Committee’s Chair, Mary Creagh MP, “It is disappointing the Government has not provided the certainty that UK businesses urgently needs on their plans for the future chemical regulation in the UK. The timing of Brexit means that companies face significant costs to comply with EU regulations before we leave, with no guarantee that that investment will be useful to them in the future.“ The CBA made a written submission and was invited to give oral evidence to the Committee.

WE HAD THREE MAJOR CONCERNS. Firstly, transposing REACH into UK law presents the Government with a series of institutional, functional, and legislative challenges. It would be difficult to transpose the legislation without amendment or some

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form of opt-in – to the registration process and access to the REACH infrastructure, such as the European Chemicals Agency and its technical committees.

Secondly, many distributor companies importing from outside the EU could effectively be excluded from the European market by the current terms of the REACH legislation. They would not be ‘non-EU manufacturers’ as they import and distribute, rather than manufacture. As such, they could not appoint an Only Representative as the only other way to comply with the existing REACH provisions.

Thirdly, the status of products already registered under REACH in 2010 and 2013 needs urgent clarification (as well as substances scheduled for registration in 2018).

CBA welcomed the Committee’s report containing its five findings – three of which almost exactly mirrored our concerns.

THE EAC’S KEY FINDINGS WERE:

The chemicals regulation framework established by the EU through REACH is difficult to transpose directly into UK law.

The EAC added ‘writing EU regulations into UK law can not be done simply by having a line in the Great Repeal Bill deeming REACH to apply in the UK. REACH was written from the perspective of participants being within the

SUMMER 2017

EU, with much of it also relating to Member State co-operation and mutual obligations, oversight and controls, and freedom of movement of products.’

Companies face significant uncertainty over the validity of current REACH registrations after the UK leaves the EU: Government must clarify its position as a matter of urgency.

The Committee was also concerned about the next REACH deadline. ‘Companies face significant costs relating to the REACH registration deadline in May 2018, yet it is unclear whether these registrations will remain valid once the UK leaves the EU in 2019. This uncertainty may already be having an impact on long-term investment decisions by companies.’ The report adds that ‘UK companies will spend an estimated £250 million to comply with the REACH registration deadline in May 2018, yet have received no guarantees over whether these registrations will remain valid after the UK leaves the EU.’ In deciding the future of the UK's relationship with the EU's single market for chemicals, the Government should take a pragmatic approach – and, as a minimum, remain

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involved in the REACH registration process for chemicals.

To reinforce this point, the EAC added that ‘Involvement in registration would allow UK companies to share testing data with EU companies, sharing costs and allowing them to enter the market without double registration, even if the UK adopts higher standards of chemicals protection.’

Establishing a stand-alone UK system of chemicals regulation is likely to be expensive for both the taxpayer and for industry.

The Government did not provide the EAC with details of their scenario planning, ‘although they did admit that the cost of taking on the roles currently provided by the European Chemicals Agency could be in the tens of millions of pounds.’

The experiences of the United States as it introduces an improved system of chemicals regulation could be useful for the Government when planning the UK's approach.

Commenting on the emerging situation in the United States, the EAC’s report said, ‘the

CBA welcomed the Committee’s report containing its five findings – three of which almost exactly mirrored our concerns.

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US is in the process of updating its chemicals regulations. Federal agencies are currently developing their new approach to the assessment and regulation of chemicals, and the experiences of the US in developing its own system may prove useful to the UK.’ What captured the attention of the Committee’s members was the outcome of CBA research that one in five of our member companies were already investigating moving part or all of their operations to a member state of the EU following the Brexit decision. In business terms, this represents little more than prudent business planning. However, the EAC were clearly concerned about the consequent loss of jobs and tax revenue should these plans take effect.

Mary Creagh concluded by calling for an end to this uncertainty. "The Government has admitted that it will be difficult to transpose regulations such as REACH into UK law, yet it has not yet offered a vision for the replacement.”

“It needs to ensure it understands the complexity and importance of current regulations in enabling the UK chemicals industry to provide not only value to the economy but their expertise and high standards in protecting public health and the environment," she added.

Despite the scope of the impending Brexit negotiations, on behalf of our member companies, the industry must make sure that REACH and related issues remain at the top of the Government’s negotiating agenda.

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SUMMER 2017

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The clock is ticking…Will you REACH the deadline in time?

The countdown is on to the REACH May 2018 deadline – make Chemex your regulatory testing partner to help you REACH your goal!

The final REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) deadline for substances produced or imported in the EU in the 1-100 tonnes per year bracket is fast approaching. Don’t be caught out – we are seeing significant increases in the levels of work in the CRO industry and time scales for performing testing are extending. Don’t delay starting the process – there is much work to be done before you even broach the laboratory testing requirements, followed by further dossier completion and submission.

As the Phase 3, May 2018 deadline is relevant to low production volume substances it will mean many more SME’s are going to be involved in the regulatory process than with the previous phases in 2010 and 2013. It is likely that many of these organisations may not have had previous experience of registering substances with ECHA (European Chemicals Agency) and many may need assistance from expert regulatory consultants and experienced CRO’s.

Ask yourself; have you made a clear business plan to include all your regulatory obligations?

Have you set a budget? Have you laid out a realistic timeframe for completion? If you are not confident that you have the appropriate expertise in-house, have you identified appropriate partners to assist you in navigating the complex regulatory system?

Assessing costs and timescales early on may allow you to decide on the viable options for the business to move forward with. It may be that for some low volume substances the expense may be prohibitive, thus not cost effective for the business to continue with.

Do not underestimate the significant challenge ahead, the REACH deadline of 31 May 2018 may seem some way off, but don’t be fooled. Assess your responsibilities now and start preparations to ensure you fulfil your regulatory obligations in time.

To assist with the REACH process, ECHA (European Chemicals Agency) has produced a toolkit – the following links may be useful in understanding more about how REACH may affect your organisation: https://echa.europa. eu/reach-2018 and https://echa.europa.eu/ regulations/reach/understanding-reach Chemex is proud to be celebrating its 30th anniversary year in 2017. The business has evolved over the years to our current status as a well-respected, GLP Compliant Ecotoxicology Laboratory offering high quality laboratory services to a range of industries worldwide.

Our services cover a broad spectrum and include both Freshwater Ecotoxicology (for REACH) and Marine Ecotoxicology (suitable for OSPAR/OCNS registrations) testing against a range of species. A wide selection of Environmental Fate studies are also on offer. In addition, many Physico-Chemical properties can be determined, as required for REACH registrations. We have a range of instrumentation in-house, available to provide GLP compliant analytical support for studies.

Chemex works to internationally recognised guidelines including OECD, OPPTS, PARCOM, JMAFF and ISO with studies performed in support of new chemical registrations, REACH requirements, data gap filling and other nonregulatory purposes.

Chemex has been an associate member of EOSCA (European Oilfield Speciality Chemicals Association) for many years, we therefore have considerable experience in dealing with chemicals for the Oilfield sector.

Should you require any assistance with the testing of substances in this area for OSPAR/

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OCNS purposes, please contact us for further information on costs and timescales.

We have built our reputation by providing a competitively priced, reliable service and believe that we offer a personal approach that can be lost with larger organisations. At Chemex, we know that good communication is key and our staff are encouraged to work closely with clients at every stage of a project to ensure we are meeting their requirements.

Our Study Directors are available to assist with technical queries regarding studies at any stage and we believe that a high level of client contact is crucial.

Having gained a wealth of experience over the years, our team are able to assist with your REACH testing requirements. We can help you to achieve your goals in a timely manner and partner you through your regulatory journey to REACH compliance. It is important for the future of your business to implement your REACH plan without delay.

For further details on Chemex capabilities and how we can help you to move forward with your REACH testing plans, please visit our website www.chemex.co.uk or contact us on enquiries@chemex.co.uk for a competitive quotation.

Visitors to our site near Cambridge, UK are always welcome, please call to arrange a meeting today on +44 (0)1954-252519.

K ey t o S u cce s s f u l G l o b a l Co m p l i a n ce

DISCOVER A BETTER WAY TO MANAGE YOUR CHEMICAL COMPLIANCE PROJECTS. EUPHOR is a one-stop-shop solution designed to manage and track your registration activities from start to finish using a single platform.

We help chemical organizations streamline compliance processes, monitor registration dossiers in real-time, and enhance collaboration with team members.

WHY EUPHOR? is the only software solution designed in partnership with Product Stewardship professionals specifically for the Chemical Industry, allowing you to complete complex compliance projects successfully and with peace of mind.

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10010110 01000101 10110010 00010000

automatic reminders

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pre-configured queries web-based application

SCHEDULE A DEMO TODAY: www.euphoreach.com | info@euphoreach.com | +1 (919) 946 5275

SUMMER 2017

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The Benefits of Adopting a Registration Management Software

Too many Compliance Departments in the Chemical industry are still using a mix of desktop tools to manage critical regulatory projects such as registration dossiers. As Compliance teams become a strategic part of chemical organizations, software service providers develop solutions to support their activities. In this article, we list the benefits of digitalizing compliance processes and automating regulatory activities.

Regulatory Compliance has significantly evolved to become a critical aspect of the chemical industry. First and foremost, business viability and continuity depends on the ability to conform with health, safety and environmental regulations. Failure to properly register or notify substances can result in fines, clients’ dissatisfaction and the ban of a product in strategic markets.

Keeping up with these ever-changing health and environmental chemical regulations presents an ongoing challenge for companies.

Besides the complexity of the legal framework, the intricate supply chain prevailing in the industry and the limited resources intensify the difficulty for Regulatory Affairs departments to efficiently collect chemical data and fulfil compliance activities.

Despite these challenges, many companies are still using inadequate desktop tools to manage and track the multitude of tasks and data necessary to meet legal requirements.

Adopting an elaborate, configurable and robust compliance management software can empower your organization to sail smoothly across regulatory waters, improve performance, mitigate risk and ensure successful compliance.

EUPHOR, a Global Registration Management Solution, aims to provide a virtual compliance room where teams can work together seamlessly towards the completion of their registration dossiers. Let’s look at some of the key benefits you can gain from adopting such platform.

IMPROVED PROJECT MANAGEMENT EFFICIENCY

The goal of a Registration Management Solution is to standardize and automate the complex registration processes. Within EUPHOR, users follow pre-defined workflow based on the legal requirements and substances’ information. This allows you to cut the amount of time spent on fulfilling administrative tasks and be able to judiciously plan and assign resources and focus on higher-level activities.

ENHANCED DATA MANAGEMENT

The era of time-intensive, manual filing processes is over! Centralizing and automating data collection eliminates the risk of losing documents and allows you to gain more accurate, higher quality data. EUPHOR offers a central platform for all your compliance documents, permitting rapid sharing, safe storage and easy retrieval of information down the line.

HARMONIOUS TEAM COLLABORATION

You can centralize your teamwork in a virtual compliance meeting room where team members can collaborate and fulfil their duties. EUPHOR links users to a specific set of rights, tasks and individual deadlines based on their roles and responsibilities. The system will act as an additional team member, ensuring that everyone is reminded of their tasks and up-to-date with information relevant to them. This makes

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team work easier, increases accountability, and improves your team’s performance.

REDUCED REPORTING TIME

You no longer have to worry about spending hours analyzing data and building reports. By automating processes and keeping track of all relevant compliance information, EUPHOR provides you with an instant, real-time snapshot of your projects status and relevant data. With a simple click of a button, you can now build higher-quality reports and dashboards will keep you informed of the progress of your projects, its timeliness and actual costs vs. budget.

Overall, let’s not forget that the main benefit is to stay a step ahead of the regulatory environment and ensure proper compliance in regulated markets. Software solutions are here to help you achieve this goal with peace of mind and confidence. So, don’t wait any longer to make the switch from manual to streamlined registration processes!

For more information: www.euphoreach.com info@euphoreach.com

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SUMMER 2017

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Only 365 sleeps until the REACH 2018 deadline: but is it keeping you awake?

The final deadline for registration of existing substances used in low volumes (1–100 tonnes per year) as part of REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is Thursday 31st May 2018.

Although the aspiration for REACH is to create ‘the most comprehensive chemicals database in the world’1 by gathering data on chemical substances used across European markets, the task is immense for both manufacturers and regulators. There have already been two previous phases of registration under REACH, both of which have come and gone without drama. However, the May 2018 deadline is considerably different in terms of the number of registrations and the type of registrants.

ECHA (European Chemicals Agency) estimates that there will be up to 60,000 registrations for up to 25,000 substances – this is three times more than either of the previous deadlines.1 As of 27th March 2017 there have been 8,547 registrations of 4,257 unique substances for the REACH 2018 deadline, so there is still some way to go.2 The scale of this registration phase is starting to cause some concerns, as manufacturers and regulators realise that there may not be capacity within contract research organisations to support the data generation that is required.

ECHA RESPONSE TO CAPACITY ISSUES IN RESEARCH ORGANISATIONS

Recent briefings from the ECHA 12th Stakeholder meeting in Helsinki3 stated that the ECHA are considering the situation and liaising with Member States and industry to establish any capacity issues and to assess the true scale of the problem should it exist.

The ECHA have stated that if they find that capacity is a major problem limiting dossier completion, they will instigate appropriate steps to allow the submission of dossiers containing data ‘gaps’. A similar process was implemented for the previous REACH deadline.

While there was no official process in the two previous deadlines, it is likely the process will follow the best practice that was observed in those previous registration phases. If a registrant knows that they will not have complete test data in time for the deadline, they should contact the ECHA via a webform and provide detailed documentary evidence showing that they have acted in good faith and commissioned the necessary study, or studies, in good time. If the ECHA deem that this is the case, the registrant will be issued

with a token (code number) that will allow them to submit the dossier to REACH-IT with data gaps, on the express understanding that the missing data will be added at the earliest possible point. The token means that the dossier would not fail the manual verification which checks for data gaps.

WHO WILL THIS APPLY TO?

If this approach is deployed it is unlikely it will be open to all registrants – only to those who can demonstrate that their dossiers are incomplete as a direct result of delays in conducting studies due to capacity limitations in contract research organisations, rather than due to a lack of planning for these studies on the part of the registrant. Registrants will need to show that they have commissioned studies in a timely fashion and not at the last minute, for example, the commissioning of a 6-month study later than October 2017 will likely be perceived as poor planning, with any subsequent capacity issue being irrelevant.

How many registrants will be asking for this flexibility in dossier submission is, as yet, unclear.

So, if you are registering a substance for the May 2018 deadline, review your plans and timelines now and, if your data will not be

54

available until after the deadline through no fault of your own, contact the ECHA. Envigo have supported importers and manufacturers through this and previous REACH registrations, so to discuss your REACH registration, no matter what stage of the process it is at, please contact kate.newell@envigo.com.

Envigo provides essential research services, models and products for pharmaceutical, crop protection, biocides and chemical companies, as well as universities, governments, and other research organisations.

REFERENCES 1. ECHA. REACH 2018 – registration deadline for lowvolume chemicals. https://echa.europa.eu/press/ press-material/pr-for-reach-2018 2. ECHA. Registration Statistics deadline 2018: All EU countries. https://echa.europa.eu/ documents/10162/13629/reach_2018_result_stats_ en.pdf 3. Musset C. Questions and answer session. ECHA. REACH 12th Stakeholders Day, 5th April 2017. http://qsb.webcast.fi/e/echa/echa_2017_0405_ stakeholders_day_part3/#/webcast

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z REACH

SUMMER 2017

www.chemicalindustryjournal.co.uk

The European REACH Congress 2017 After the success of previous events, The European REACH Congress, organised by TSGE Forum, will return to the InterContinental Hotel in Düsseldorf, Germany on 21-22 November 2017.

REACH TODAY AND THE CHALLENGES AHEAD

With a fresh theme and programme of discussions and presentations, the Congress will move away from registration-based topics to the future challenges such as voluntary versus regulatory management of hazardous chemicals at manufacturing/formulating sites.

The two day event encourages shared learning amongst industry, service providers, authorities and policy makers; and includes pre-event workshops, panel discussions and keynote presentations.

CONGRESS PROGRAMME

A varied programme is already in place, which includes a wide range of sessions focussing on current regulatory and policy topics. The 2017 programme will look to: inform and support industry in dealing with the demands of the REACH Regulation, and envisage the requirements of the Regulation and explore how industry is undertaking voluntary measures to manage hazardous chemicals in their supply chains.

Topics include:

• Authorisation and restrictions • Supply chain challenges

• International compliance and impact of REACH • Practical advice for upstream and downstream sectors of the industry

PROGRAMME OVERVIEW

Until now, the majority of authorisation applications have been filed either by single downstream users, to cover their own uses, or by suppliers, to cover a large number of downstream users. Joint downstream users’ application for authorisation provides

new opportunities to apply cost effectively without sacrificing the quality. Through several examples, Dr. Ying Zhu (REACHLaw) aims to describe why and how to make a joint downstream users’ application for authorisation. Data representativeness will be the main focus and confidentiality issues will also be discussed.

Delegates will be able to learn about a voluntary programme to substitute hazardous chemicals in a multinational health-care company, F.Hoffmann-La Roche Ltd (Roche).

Dr. Jan Backmann from Roche will report back practical experiences from the daily life with the phase-out program which proves to be both a great chance and a tremendous challenge.

In 2015, Roche committed to phase out substances of very high concern (SVHCs) from all processes and products worldwide - where technically feasible - within ten years of the addition of a specific substance to the REACH candidate list. The challenges exist within the organisation, funding, and in the field of technological development. Most significant benefits can be achieved with courageous disruptive changes of technological processes and product design.

Another example of voluntary industry initiative is to develop alternatives to long-chain Perfluorinated Compounds.

Dr. Ronald Bock (Chemours International Operations) will focus on the assessments required to develop alternatives according to all internationally accepted regulatory standards to ensure that they are suitable for all applications and can be safely applied by downstream users.

During the conference, attendees will be able to find out more about an online B2B platform for solutions to replace hazardous chemicals. In her presentation, Dr. Anna Lennquist (ChemSec) will demonstrate how delegates can use the Marketplace to find safer

56

alternatives to hazardous chemicals and what future features will be added to the tool.

Another tool delegates may find useful has been developed by Eurometaux (an association for non-ferrous metals industry in Europe) for registration file improvement and data gap analyis.

The Risk Management Option analysis is used by authorities and industry to define the best risk management option to address a specific concern related to human health (workplace and consumers) and environment.

In the past years, Eurometaux created a system supporting this effort but also helping industry to improve its registration dossiers, reflect on the best risk management measures and help to identify the need for additional data. In her presentation, France Capon (European Precious Metals Federation) will present Eurometaux updated guidance for an Industry Risk Management Option analysis, as some examples coming from the industry and the authorities.

Other speakers include Dr. Erwin Annys (Cefic), Dr. Anne Bonhoff (UL Environment), Bruce Callow (TSGE Consulting), Igor Danilov (Dentons Europe LLP), Richard Dubourg (The Economics Interface Ltd), Marianne Hedberg (The Swedish Construction Federation), Irantzu Garmendia (FECC) and Simon Tilling (Burges Salmon LLP).

During the two-day Congress there will be plenty of networking opportunities with two drinks receptions to meet new and old colleagues, so don’t miss out.

To find out more, please visit www.reachcongress.com or contact us to discuss sponsorship, exhibition or advertising opportunities on: T: +44 (0) 1423 863 522 E: enquiries@tsgeforum.com

REGISTER NOW To receive your 10% readers discount, simply quote C08CIJ (standard price ÂŁ670 + VAT)

The two day event encourages shared learning amongst industry, service providers, authorities and policy makers; and includes pre-event workshops, panel discussions, keynote presentations and plenty of networking opportunities with two drinks receptions.

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z HEALTH AND SAFETY

SUMMER 2017

www.chemicalindustryjournal.co.uk

Making the most of hazard identification

A thorough hazard identification process is the foundation of good risk management, without which, risk may be missed, misunderstood and mis-managed. But is hazard identification becoming too boring?

There are a number of established hazard identification techniques used in industry, including checklists, HAZOP and FMEA to name a few. Operators at high hazard sites can therefore select the most appropriate process according to the lifecycle stage, the project intent and site complexity. However, as these techniques become well practised it is possible that they become routine with the same people involved using the same process over and over again.

It can be tempting to restrict creativity in HAZID. In most aspects of plant operation, such as manufacturing and quality management, we tend to strive for consistency. While consistency in most processes is beneficial, it is important to consider the potential pitfalls of this in HAZID. It could lead to the application of the wrong technique for the circumstance, and with less rigour and creativity, as the familiarity of participants means they enter the process with preconceived ideas.

There is a lot of guidance on how to select and implement the correct HAZID technique, but it should also be considered that these methods can be tweaked or supplemented, as long as the fundamental philosophy remains the same.

It is important that in preparing for a hazard identification exercise, guidewords are carefully considered and selected to reflect the conditions on the plant. Generic prompts that will have to be deliberated over on the day should be avoided. Guidewords should encourage rather than restrict the creativity of the study team.

Drawings and diagrams are useful tools and should always be used to gain a clear understanding of the plant, but it may be

beneficial to supplement this with a walkaround and talk through of the plant itself.

Drawings can fail to convey important information that a walk-around would identify. This is particularly useful when involving external participants in the exercise who might have limited knowledge of the plant and also a different perspective.

Considering past incidents, both on the establishment and elsewhere, can also stimulate an exercise. The COMAH Regulations 2015 require sites to keep a record of incidents and lessons learnt at establishments with similar processes and substances in order to inform risk management. The data can help to identify hazards previously taken for granted by bringing them to light and emphasising the potential consequences of failing to manage them.

As HAZID techniques become routine, a customary team from within the organisation may naturally develop and over time they might become the go-to group for all exercises.

Is it wise to use the same methods and same team, time and time again? While it is important for efficiency that the team is familiar with the process and indeed each other, there is a danger of complacency and over-familiarisation resulting in missed opportunities to pick up hazards.

While it might seem more efficient to use a team of in-house personnel, it is often beneficial to involve an independent participant or chair whose unfamiliarity with the process can provide a fresh perspective and stimulate creative thinking. Remember

58

the objective is to think the unthinkable, and uncover hazards so they can be controlled. In HAZID, no question is ever a stupid one.

Operators shouldn’t be afraid to start from a blank piece of paper; our experience at RAS is that this is often quicker and more productive than deliberating over the reasons for the team’s historic assumptions.

While following set methodologies for hazard identification is important, it can be valuable to take a step back and consider if they will enable you to make the most of the exercise.

Remember the ultimate purpose of the HAZID exercise, don’t let it become something you just have to do. By considering the process used, people involved and the best timing for a study, it is possible to transform a routine HAZID exercise into a rewarding, productive and worthwhile experience. The key is creativity. Why not try new visual approaches such as bowties or barrier assessments? Have fun!

Carolyn Nicholls carolyn.nicholls@ras.ltd.uk Jenny Hill jennifer.hill@ras.ltd.uk

RAS RISK & HAZARD MANAGEMENT

Understanding and facilitating the effective management of risk is our core business.

Our expertise covers the full range of risk assessment and management services across:

Safety Risk

Business Risk

Environment Risk

Only when the risk facing an organisation is well understood can it be effectively managed.

Key to the successful identification, assessment and management of risk is engagement with the right

people, using the right processes at the right time. We believe we are different to many of our competitors and our approach is distinctive, we don’t always walk the well-trodden path but look at each client’s particular risk context and develop a tailored solution, working in partnership with our client.

We work across all aspects of risk, from Quantitative Risk Assessments and Predictive &

Consequence modelling, through to the ‘softer’ risks which may affect an organisation’s reputation.

+44 (0) 1244 674 612 • enquiries@ras.ltd.uk • www.ras.ltd.uk

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Ti

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Calcium 38

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Cs

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Ta

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Rf (267)

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Mo 95.96

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W

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Db (268)

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Dubnium

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Ce

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2 8 18 32 18 10 2

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Nd

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140.90765

Cerium

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2 8 18 32 20 9 2

Thorium

231.03588

Protactinium

2 8 18 32 21 9 2

93

144.242

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107

Bh (272)

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238.02891

Uranium

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Neptunium

2 8 18 32 22 9 2

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Ir

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Pt Ds (281)

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Ag

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Au

2 8 18 18 1

48

12.0107

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Cd

Rg (280)

In

112.411

2 8 18 32 18 1

80

Hg

Si 28.0855

Roentgenium

112

Cn (285)

32

Ge

2 8 18 32 18 2

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Tl

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50

Uut (284)

Copernicium

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Gd

2 8 18 25 9 2

65

96

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97

Am Cm (247)

Curium

Tb

2 8 18 27 8 2

66

2 8 18 32 27 8 2

98

158.92535

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Berkelium

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2 8 18 32 28 8 2

99

162.5

Terbium

Bk

Dy

2 8 18 28 8 2

Sn

2 8 18 32 18 3

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Pb

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2 8 18 32 29 8 2

100

164.93032

Dysprosium

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68

167.259

Holmium

Californium

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Einsteinium

Er Erbium

Fm (257)

114

Fl (289)

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Bi

208.9804

69

2 8 18 32 30 8 2

101

Tm

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Yb

Ar 39.948

Argon 2 8 18 7

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2 8 18 18 7

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2 8 18 32 18 7

86

Kr

79.904

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Krypton

126.90447

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2 8 18 18 8

131.293

Iodine

85

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Po At Rn electrochemistry (210)

Lv (293)

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Astatine

2 8 18 32 32 18 6

117

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Livermorium

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2 8 18 32 32 18 7

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118

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173.054

Thulium

Fermium

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174.9668

Ytterbium

Mendelevium

Lutetium

No (259)

Lr (262)

Nobelium

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2 8 18 32 18 6

116

2 8 18 32 32 18 5

Ununpentium

70

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Polonium

115

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Bismuth 2 8 18 32 32 18 4

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121.76

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52

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78.96

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Selenium

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207.2

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51

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34

74.9216

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113

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114.818

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200.59

Gold

111

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14.0067

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69.723

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196.966569

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Ga

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2 8 18 2

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106.42

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151.964

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62

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