Chemical INDUSTRY JOURNAL
Making good practice, common practice
Chemical Supply Chain
The Orange Book, Minor Works
The revised edition of The Orange Book contains a number of general changes from the previous edition reflecting current best practice and bringing it in-line with the full suite. The main changes to note are that this contract is now structured to be used both within the UK and internationally. Also that the new form can be used for design and construction. Available in hard copy, PDF and editable word format.
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…in which process safety takes centre stage Ellen Rossiter Editor in chief
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Welcome to the latest edition of the Chemical Industry Journal, in this issue, we put process safety front and centre - as it always should be in our industry. We turn our attention to the work of the Process Safety Management Competence Programme Board, looking at what inspired their foundation, the progress that has been made in process safety and their hopes for the future. As we go to print, the board is set to host their third Process Safety Management summit, held in partnership with the Process Safety Forum and the COMAH Strategic Forum, with the hope of “making good practice, common practice”. The summit will bring together practitioners and executives from industry, stakeholder and regulatory bodies, to share best practice and highlight the support available to industry. We also speak to risk management consultant Carolyn Nicholls, about her approach to managing risk and why people are at the centre of all of her work. We shine a light on how Carolyn goes about finding the right people to join her team and why investing in that team is crucial to the continued success of the business. We also consider how the process safety industry is evolving and how new hazards are emerging. Central to safeguarding both human health and the environment when it comes to the production and use of chemicals is the REACH regulation for the Registration, Evaluation, Authorisation and Restriction of Chemicals.
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As you know, REACH came into effect from June 2007 – but the REACH deadline for companies to register (eligible) existing substances will soon be upon us, so we take a look at businesses registration obligations, and how REACH dossiers need to be updated and maintained. We also examine how business change from mergers and acquisitions to changes in a manufacturing process can have an impact on that registration. The UK’s exit from the
European Union is not expected to affect companies’ obligations – so they are strongly advised to register. Preparation, robust chemical management and a thorough understanding of applicable regulation, whether REACH or otherwise are, as Dr Michael Cleuvers highlights, imperative for trading chemicals worldwide. Learn more about the factors you need to take into consideration in this issue. Elsewhere, we look specifically at the US and Turkish regulations relating to importing chemical substances. As always, we cast our eye over the latest UK and international news. A team of international researchers have found evidence of Uranium and other radioactive materials in tiny particles released from the damaged Fukushima Daiichi nuclear reactors, the first time that such fallout has been explicitly revealed. These particles will provide vital information when it comes to decommissioning the Fukushima Daiichi site and obtaining a better understanding of the environmental impact of the 2011 disaster. Elsewhere, we learn how researchers at Imperial College have harnessed the natural ability of cells to process chemicals whilst protecting them from the environment, by encapsulating biological cells in artificial cells. The Prime Minister’s commitment to exploring how the UK can negotiate associate membership of the European Chemicals Agency and remain a part of other EU agencies ‘critical for the chemicals, medicines and aerospace industries’, is welcomed by the Chemical Business Association’ (CBA). The findings of the CBA’s latest Trends Survey are also revealed in this issue, providing us with a valuable insight into how the chemical industry in the UK is faring, incorporating as it does responses from 51 companies. Discover the state of affairs as it pertains to their order books, sales and sales margins, training and recruitment; and their outlook for the rest of 2018. Turn the pages to find out more…
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20-23 Chemical Supply Chain 26-27 Big Interview 36-37 Process Safety 40-41 Solvents Industry
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Artificial and biological cells work together as mini chemical factories Researchers have fused living and non-living cells for the first time in a way that allows them to work together, paving the way for new applications. The system, created by a team from Imperial College London, encapsulates biological cells within an artificial cell. Using this, researchers can harness the natural ability of biological cells to process chemicals while protecting them from the environment. This system could lead to applications such as cellular ‘batteries’ powered by photosynthesis, synthesis of drugs inside the body, and biological sensors that can withstand harsh conditions. Previous artificial cell design has involved taking parts of biological cell ‘machinery’ – such as enzymes that support chemical reactions – and putting them into artificial casings. The new study, published today in Scientific Reports, goes one step further and encapsulates entire cells in artificial casings. The artificial cells also contain enzymes that work in concert with the biological cell to produce new chemicals. In the proof-ofconcept experiment, the artificial cell systems produced a fluorescent chemical that allowed the researchers to confirm all was working as expected.
Lead researcher Professor Oscar Ces, from the Department of Chemistry at Imperial, said: “Biological cells can perform extremely complex functions, but can be difficult to control when trying to harness one aspect. Artificial cells can be programmed more easily
but we cannot yet build in much complexity. “Our new system bridges the gap between these two approaches by fusing whole biological cells with artificial ones, so that the machinery of both works in concert to produce what we need. This is a paradigm shift in thinking about the way we design artificial cells, which will help accelerate research on applications in healthcare and beyond.” To create the system, the team used microfluidics: directing liquids through small channels. Using water and oil, which do not mix, they were able to make droplets of a defined size that contained the biological cells and enzymes. They then applied an artificial coating to the droplets to provide protection, creating an artificial cell environment. They tested these artificial cells in a solution high in copper, which is usually highly toxic to biological cells. The team were still able to detect fluorescent chemicals in the majority of the artificial cells, meaning the biological cells were still alive and functioning inside. This ability would be useful in the human body, where the artificial cell casing would protect the foreign biological cells from attack by the body’s immune system.
CONTROLLABLE AND CUSTOMISABLE SYSTEM
First author of the study Dr Yuval Elani, an EPSRC Research Fellow from the Department of Chemistry, said: “The system we designed
is controllable and customisable. You can create different sizes of artificial cells in a reproducible manner, and there is the potential to add in all kinds of cell machinery, such as chloroplasts for performing photosynthesis or engineered microbes that act as sensors.” To improve the functionality of these artificial cell systems, the next step is to engineer the artificial coating to act more like a biological membrane, but with special functions. For example, if the membrane could be designed to open and release the chemicals produced within only in response to certain signals, they could be used to deliver drugs to specific areas of the body. This would be useful for example in cancer treatment to release targeted drugs only at the site of a tumour, reducing side effects. While a system like that may be a way off yet, the team say this is a promising leap in the right direction. The work is the first example of fusing living and non-living components to emerge from Imperial and King’s College’s new FABRICELL centre for artificial cell science. 'Constructing vesicle-based artificial cells with embedded living cells as organelle-like modules' by Yuval Elani, Tatiana Trantidou, Douglas Wylie, Linda Dekker, Karen Polizzi, Robert V. Law & Oscar Ces is published in Scientific Reports. www.imperial.ac.uk/news/185247/artificialbiological-cells-work-together-mini
Insight into Pharma & Cosmetics with students at Liverpool John Moores University (LJMU)
Brenntag Pharma & Cosmetics engage with students studying towards Masters in Cosmetics
Image © Museum of Brands
SIA Spring Dinner raises £1,000 for fire service charity The Solvents Industry Association Annual Spring Dinner was held on 15th March at the Museum of Brands, Packaging and Advertising, London, and proved to be another successful event for the Association. Over 60 SIA members and distinguished guests from 27 companies attended the event at this Top Ten London attraction, which included dinner and a trip down Memory Lane with the opportunity to view over 12,000 original items from the Museum’s unique Robert Opie Collection, a number of which reflected the changes in the use of chemical solvents in day-to-day products over recent decades. £1,000 was raised on the night from the traditional SIA raffle, which is to be donated
to the Firefighters Charity in recognition of the work of the service, particularly at nearby Grenfell Tower in June 2017.
Tamara Durak, Business Manager and Sonny Jagatia, Business Development Manager from the Brenntag UK & Ireland Pharmaceuticals and Cosmetics team were invited to present at a Liverpool John Moores University (LJMU) event. The event in Liverpool was organised by Imran Saleem, MSc Cosmetic Science Programme Leader, to engage with students studying toward a Masters degree in Cosmetics - the first one in the country. Tamara and Sonny talked to students about the opportunities at Brenntag within the Cosmetic Science team, and took an opportunity to highlight the technical expertise and role that Brenntag provides to the cosmetic industry. It was a chance for students to ask questions and understand what role they can play in the future and network with companies such as Brenntag, Croda, The Hut Group and representation from the Society of Cosmetics Science.
The next key event in the SIA diary is the Annual General Meeting which will be held in October at Mottram Hall in Cheshire. If you would like further information, please contact Andrew Norman, SIA General Secretary; firstname.lastname@example.org www.solvents.org.uk/contact-us
(Left to right) Sonny Jagatia, Imran Saleem, Tamara Durak
AkzoNobel to sell Specialty Chemicals to The Carlyle Group and GIC for €10.1 billion AkzoNobel has announced the sale of 100% of its Specialty Chemicals business to The Carlyle Group and GIC for an enterprise value of €10.1 billion. This transaction creates two focused and high performing businesses – Paints and Coatings, and Specialty Chemicals – as part of its strategy announced in April 2017. The transaction is expected to be completed before the end of 2018. The Board of Management and the Supervisory Board concluded that a private
sale to The Carlyle Group and GIC is in the best interests of AkzoNobel, Specialty Chemicals and its respective stakeholders, including employees, shareholders and customers. This is the outcome of a thorough dual-track process during which the Boards of AkzoNobel carefully considered both a legal demerger and a private sale. The Carlyle Group has a global presence and the financial capacity to enable the Specialty Chemicals business achieve its full potential.
Carlyle has extensive experience investing in chemicals, unlocking long-term potential and creating value in its portfolio companies. As a responsible investor Carlyle is focused on driving growth, job creation and longterm financial success. The firm also has a strong focus on Environmental, Social and Governance (ESG) aspects and building positive working relationships with wider stakeholders (employees, unions and local communities).
© Imperial College London
By finely tuning the distance between nanoparticles in a single layer, researchers have made a filter that can change between a mirror and a window The development could help scientists create special materials whose optical properties can be changed in real time. These materials could then be used for applications from tuneable optical filters to miniature chemical sensors. Creating a ‘tuneable’ material – one which can be accurately controlled – has been a challenge because of the tiny scales involved. In order to tune the optical properties of a single layer of nanoparticles – which are only tens of nanometres in size each – the space between them needs to be set precisely and uniformly. To form the layer, the team of researchers from Imperial College London created conditions for gold nanoparticles to localise at the interface between two liquids that do not mix. By applying a small voltage across the interface, the team have been able to demonstrate a tuneable nanoparticle layer that can be dense or sparse, allowing for switching between a reflective mirror and a transparent surface. The research is published today in Nature Materials. Study co-author Professor Joshua Edel, from the Department of Chemistry at Imperial, said: “It’s a really fine balance – for a long time
we could only get the nanoparticles to clump together when they assembled, rather than being accurately spaced out. But many models and experiments have brought us to the point where we can create a truly tuneable layer.” The distance between the nanoparticles determines whether the layer permits or reflects different wavelengths of light. At one extreme, all the wavelengths are reflected, and the layer acts as a mirror. At the other extreme, where the nanoparticles are dispersed, all wavelengths are permitted through the interface and it acts as a window. In contrast to previous nanoscopic systems that used chemical means to change the optical properties, the team’s electrical system is reversible. Study co-author Professor Alexei Kornyshev, from the Department of Chemistry at Imperial, said: “Finding the correct conditions to achieve reversibility required fine theory; otherwise it
would have been like searching for a needle in a haystack. It was remarkable how closely the theory matched experimental results.” Co-author Professor Anthony Kucernak, also from the Department of Chemistry, commented: “Putting theory into practice can be difficult, as one always has to be aware of material stability limits, so finding the correct electrochemical conditions under which the effect could occur was challenging.” Professor Kornyshev added: “The whole project was only made possible by the unique knowhow and abilities and enthusiasm of the young team members, including Dr Yunuen Montelongo and Dr Debarata Sikdar, amongst others who all have diverse expertise and backgrounds.” www.imperial.ac.uk/news/181908/selfassembling-nanoparticle-arrays-switchbetween-mirror
New project to support County Durham photonics companies The Centre for Process Innovation (CPI) and Durham University have joined forces in a project that will assist small and mediumsized enterprises (SMEs) in Country Durham to commercialise photonics and other emerging technologies through localised innovation infrastructure and commercialisation services. The project, called Spotlight, will run for three years, and is supported with funds from the European Regional Development Fund. Photonic technologies use light for a range of healthcare applications including therapies, diagnostics, imaging and surgical interventions. This is an exciting and rapidly growing area globally, as the demand for non-invasive, cost-effective, rapid and/or personalised care and treatment rises. There are many SMEs in County Durham with growth ambitions in the photonics area that need help with early stage proof of concept research and scaling up their technologies to accelerate commercialisation. Through HSD Safety half-page ARTWORK.pdf 1 this project, companies will get access to
experienced senior staff at Durham University and CPI with strong track records in the research, innovation and the commercialisation process of photonics and emerging technologies. In addition, the project will offer consultation services in areas such as market assessment, health economics, regulatory and legislative matters, and specialised photonics.
primary goal and key benefits of this project are to provide SMEs with support services to accelerate their technology commercialisation and into improving healthcare. This project also fits into a wider initiative benefitting County Durham by creating a healthcare photonics and medical technologies development hub in the area.”
The project is a collaboration between CPI and Durham University, and further expertise will be brought in to provide specialist services such as device approval. The project will work with local SMEs to understand their specific needs, find out what stage in the innovation process they are at and what assistance they require. A tailored package of practical laboratory-based work and/or support services will then be put together to help SMEs to realise their product concept or development quicker and at lower risk.
Tom Harvey, Strategic Programmes Manager, Head of Technology – Healthcare Photonics at CPI said: “This project will drive long-term inward innovation investment into the region, in combination with CPI’s National Centre for Healthcare Photonics development at NETPark in Sedgefield. Ultimately, this is part of a vision to create a UK hub for healthcare photonics and medical technology companies to develop technologies within this field.”
Professor John Girkin of the Department of Physics at Durham University and academic 12:08 lead for the Spotlight project said: “The
The project was launched at an event at CPI’s printable electronics facility at NETPark, Sedgefield on Thursday 22nd March. For more information: www.uk-cpi.com
Simple arsenic sensor could save lives A low-cost, easy-to-use sensor which can test drinking water for arsenic in just one minute has been developed by Imperial and UCL researchers. Worldwide, 140 million people drink water containing unsafe levels of arsenic, according to the World Health Organisation. Short-term exposure causes skin lesions, skin cancer and damage to the cognitive development of children, while long-term exposure leads to fatal internal cancers. In one region of Bangladesh, one of the worstaffected countries, around 20% of all deaths are attributable to arsenic poisoning. This sensor to detect harmful levels of water contamination will make a huge difference across developing nations, potentially saving millions of lives. Sam Gyimah Universities and Science Minister Researchers from Imperial College London and University College London (UCL) have developed a small, sensitive and accurate sensor, which produces an immediate measure of the arsenic level in water at a cost of less than $1 per test.
CREATING THE TECHNOLOGY OF TOMORROW
Commenting on this game-changing product, Universities and Science Minister Sam Gyimah said: “This sensor to detect harmful levels of water contamination will make a huge difference across developing nations, potentially saving millions of lives. “Too many people are exposed to dangerous levels of arsenic and this product is a clear demonstration of our Industrial Strategy in action, creating the technology of tomorrow and supporting the high-value, high skilled jobs that will make Britain fit for the future.” The concept for the device was developed by Dr Joanne Santini from UCL and Professor Tony Cass from the Department of Chemistry at Imperial, whose earlier work led to the development of the first electronic blood glucose monitor. Dr Santini had the idea of developing a sensor to detect arsenic in water when she discovered a microscopic organism that eats arsenic. She realised that an enzyme produced by this organism could be used to measure arsenic levels. Bio Nano Consulting, a spin-out from Imperial and UCL, has patented the sensor design and, using a Smart Award from Innovate UK, created a prototype which it can produce in batches of up to 100.
Currently available tests for arsenic need to either be carried out by scientists in a laboratory or using chemical test kits that produce toxic chemicals as byproducts and take up to half an hour to give a result. The new sensor, developed with BBSRC funding through the government’s Industrial Strategy, resembles the blood glucose meters used by diabetics. Once a drop of water hits the test strip, which is inserted into the sensor, it produces a digital reading of the arsenic level in one minute. This would enable it to be used by local people in rural areas in low and middle-income countries, where the problem of arsenic poisoning is greatest and access to healthcare and technology is limited.
SUCCESS IN THE FIELD
Professor Cass said: “It’s been a real journey to take an idea, conceived of at a London Centre for Nanotechnology research day, through proof of concept research, then into prototyping and scale up and now to field trials in Bangladesh. Now the technology has been spun out we can look forward to scale up of manufacture and ultimately deployment.” Dr David Sarphie, CEO of Bio Nano Consulting, said: “Arsenic contamination of water is a hugely important issue, and the technology hasn’t existed to enable it to be addressed properly. We feel that a user-friendly, cheap and rapid test could be extremely beneficial in terms of revolutionising how the problem might be addressed. “We were doing some early-stage field trials a few months ago in Bangladesh and a lot of the villagers were actually pleading with us to come and measure their well, because they had no idea how much arsenic was in their water.” The researchers expect it to be on the market within three years. www.imperial.ac.uk/news/185132/simplearsenic-sensor-could-save-lives
The merge to Dura-ID Solutions As of the 1st of February 2018 – IML Labels & Systems, Longcombe Labels and Leedmarque Concepts merged to become Dura-ID Solutions. The deal created a combined company with just over 100 members of staff, 5 sites and annual revenues of £14m+. As experts in the field of specialist labelling, tagging, plastic mouldings and printing solutions, the merger follows a highly successful year of sales for the 3 businesses involved. All of which have been owned as separate entities by Goonvean Holdings. Together, Dura-ID Solutions aims to further revolutionise identification solutions across all its key sectors and will continue to focus on supplying high quality products and services to its client base. Dura-ID are happy to announce that the full workforce has been retained and everyone is
excited for the opportunities to continue the good work started over 80 years ago! Now with sites in Sheffield, Paignton, Mansfield, Cambridge and Aycliffe, Dura-ID will be able to offer a larger selection of products, have a larger customer reach and greater capacity to help keep lead-times down. Shaun Higgins, Managing Director at IML Labels & Systems said “We are very enthusiastic about the new opportunities that this merger brings to our company. The staff at both businesses are passionate about what they do, and it felt right to go through this change. Becoming Dura-ID Solutions means that we will be able to offer a more extensive product range to every industry we specialise within. We are all looking forward to our unified future as Dura-ID Solutions.”
Paul Harris, General Manager of Longcombe Labels says “This news comes from a keen interest in wanting to provide complete identification solutions for every industry, and as Dura-ID Solutions we can achieve that. Here at Longcombe Labels, all staff are proud to be joining forces and we look forward to what the future has in store for Dura-ID Solutions.” Dura-ID offer a wide range of GHS and BS5609 approved labelling and printing solutions for the chemicals industry and our specialist team of chemical experts can offer advice and guide you to the right solution for your application. From exclusive deals with American printer manufacturer Neuralog to partnerships with well-known chemical compliance company, UL Safeware Quasar – Dura-ID are here to solve your labelling problems.
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Early disease diagnosis could be dramatically improved with new detection system By attaching specialised molecules to the backbone of DNA, researchers have made it easier to detect rare molecules associated with early disease.
However, current methods of detection are often not sufficiently sensitive and require costly and time-consuming sample pretreatment.
The presence of, or changes in the concentration of, certain proteins in biological fluids can be indicators of disease. However, in the early stages of disease these ‘biomarkers’ can be difficult to detect, as they are relatively rare.
The system represents a significant innovation, as it is more sensitive to specific biomarkers and does not require clinical sample preparation. The method is published in Nature Communications.
Detecting important biomarkers in lower concentrations will allow patients to be treated earlier for diseases such as some cancers and neurological disorders, which could increase the chance of survival rate.
Now, researchers from the Department of Chemistry at Imperial College London have come up with a system that is specific, flexible, and can detect single protein biomarkers directly in human serum (a pool of fluid separated from blood).
Dr Alex Ivanov, co-leader of this study from the Department of Chemistry at Imperial, said: “The detection of single molecules of biomarkers represents the ultimate in sensitivity for early diagnosis. We have now shown that this is possible to perform such measurements in real human samples, opening up the potential for meaningful early diagnosis.”
BINDING TO BIOMARKERS
With the rapid growth in nanotechnology and nanopore technology, this innovative platform could pave the way for the next wave of clinical applications. Dr Jasmine Sze
The method the team developed uses the ‘backbone’ of DNA, the structure it is built around. They grafted ‘aptamers’ – synthetic DNA molecules that bind to specific target biomarkers – to DNA backbones. When added to human serum, the aptamers bind to biomarkers before being analysed by passing through a nanopore detector. Nanopores are miniscule holes (often as small as a few billionths of a meter) that measure a change in electrical current as molecules pass through them. Each biomarker has a unique current signature, so the presence and concentration of target biomarkers can be analysed in this way.
The team demonstrated that their system can work by testing three aptamers on one DNA backbone. They found that the nanopores can detect the specific biomarkers that the aptamers were designed to pick up. They say that the system can be constructed with more than five different aptamers, allowing detection of multiple biomarkers at once. In addition, the biomarkers were detected in human serum, meaning far less preparation time and cost were needed. Based on the preliminary findings of this study, research efforts are now focused on several types of cancer and neurological disorders, which can benefit from the detection of biomarkers that are in low abundance in clinical samples. The team have filed a patent for the technology, and are currently exploring routes towards commercialisation so that it can be used to ultimately improve quality of life. Dr Jasmine Sze, who completed this study as part of her PhD in the Department of Chemistry and has recently moved to the IMED Biotech at AstraZeneca said “Looking forward, with the rapid growth in nanotechnology and nanopore technology, this innovative platform could pave the way for the next wave of clinical applications. “It has great potential for biomarker discovery, development of companion diagnostics as well as clinical endeavours, such as direct diagnosis, prognosis and sub-type classification with single-molecule sensitivity.” ‘Single Molecule Multiplexed Nanopore Protein Screening in Human Serum using Aptamer modified DNA Carriers’ by Jasmine Y. Y. Sze, Aleksandar P. Ivanov, Anthony E. G. Cass, and Joshua B. Edel is published in Nature Communications. www.imperial.ac.uk/news/183793/earlydisease-diagnosis-could-dramaticallyimproved/
New evidence of nuclear fuel releases found at Fukushima Uranium and other radioactive materials, such as caesium and technetium, have been found in tiny particles released from the damaged Fukushima Daiichi nuclear reactors. This could mean the environmental impact from the fallout may last much longer than previously expected according to a new study by a team of international researchers, including scientists from The University of Manchester. The team says that, for the first time, the fallout of Fukushima Daiichi nuclear reactor fuel debris into the surrounding environment has been “explicitly revealed” by the study. The scientists have been looking at extremely small pieces of debris, known as microparticles, which were released into the environment during the initial disaster in 2011. The researchers discovered uranium
from nuclear fuel embedded in or associated with caesium-rich micro particles that were emitted from the plant’s reactors during the meltdowns. The particles found measure just five micrometres or less; approximately 20 times smaller than the width of a human hair. The size of the particles means humans could inhale them. The reactor debris fragments were found inside the nuclear exclusion zone, in paddy soils and at an abandoned aquaculture centre, located several kilometres from the nuclear plant. It was previously thought that only volatile, gaseous radionuclides such as caesium and iodine were released from the damaged reactors. Now it is becoming clear that small, solid particles were also emitted, and that some of these particles contain very long-lived radionuclides; for example, uranium has a halflife of billions of years. Dr Gareth Law, Senior Lecturer in Analytical Radiochemistry at The University of Manchester and an author on the paper, says: “Our research strongly suggests there is a need for further detailed investigation on Fukushima fuel debris, inside, and potentially outside the nuclear exclusion zone. Whilst
it is extremely difficult to get samples from such an inhospitable environment, further work will enhance our understanding of the long-term behaviour of the fuel debris nanoparticles and their impact.” The Tokyo Electric Power Company (TEPCO) is currently responsible for the clean-up and decommissioning process at the Fukushima Daiichi site and in the surrounding exclusion zone. Dr Satoshi Utsunomiya, Associate Professor at Kyushu University (Japan) led the study. He highlights that: “Having better knowledge of the released microparticles is also vitally important as it provides much needed data on the status of the melted nuclear fuels in the damaged reactors. This will provide extremely useful information for TEPCO’s decommissioning strategy.” At present, chemical data on the fuel debris located within the damaged nuclear reactors is impossible to get due to the high levels of radiation. The microparticles found by the international team of researchers will provide vital clues on the decommissioning challenges that lie ahead. www.manchester.ac.uk/discover/news/newevidence-of-nuclear-fuel-releases-found-atfukushima
EcoVadis rates Croda’s environmental practices as outstanding Croda, who create, make and sell innovative, sustainable, high performance speciality chemicals that are relied on by industries and consumers everywhere has this month been awarded EcoVadis Gold Status for the fourth time. Improving its score year on year, 2018 sees Croda again placed in the top 1% of all chemical companies assessed by EcoVadis and the top 1% of all companies assessed by the sustainability platform, with a score of 83/100. EcoVadis’ assessment methodology scores Croda as ‘outstanding’ in environmental and labour practices, together with ‘advanced’ in its sustainable procurement practices. The continuing score improvement reflects Croda’s evolution of policies and procedures toward best practice, as well as making these more readily accessible externally. This has improved its 2017 labour practices score from ‘advanced’ to ‘outstanding’. Commenting on the assessment Chris Sayner, Vice President of Customer Alliances at Croda
said: “EcoVadis is recognised as an increasingly important guide for customers across many industries in judging suppliers’ sustainability credentials.” “At Croda, we use EcoVadis as one of the leading external references for continual improvement, achieving Gold Status with the first of our four filings we have increased our score by 21 points from 62 to 83. Whilst a score of 83/100 is the highest amongst our peers, we are determined to progress further.” Currently, around two thirds of Croda’s raw materials come from renewable sources and this is set to increase in 2018 with the commissioning of a new pioneering facility in North America producing 100% bio-based surfactants. The plant will give Croda’s customers access to the new ‘ECO’ range, enabling them to meet consumer demands for increasingly environmentally friendly products. For more information on Croda’s commitment to sustainability, visit www.croda.com/ sustainability
Two prestigious research grants awarded to University of St Andrews More than half a million pounds for work in chemistry and Scottish history Two top research grants worth more than half a million pounds have been awarded to academics at the University of St Andrews by a major national funding body. Professor Colin Kidd of the School of History and Professor Philip Lightfoot of the School of Chemistry have received the prestigious research grants from the Leverhulme Trust to fund their future work. Professor Kidd, left, Head of the School of History, has been awarded a research grant of up to £470,556 over 36 months for his research project entitled ‘After the Enlightenment: Scottish Intellectual Life, 1790-1843’. In addition, Professor Philip Lightfoot, Director of Teaching in the School of
Chemistry, has been awarded a grant of up to £118, 374 over 24 months for his work entitled ‘A new family of layered perovskite materials with diverse functionality’. Perovskites are a diverse class of chemical compounds which display a range of important properties such as electrical conductivity, magnetism and energy storage properties. They are used in a wide range of everyday devices such as mobile phones, computer memories and solar cells. Professor Lightfoot, left, said: “Our work seeks to understand the remarkable properties of perovskites by analysing their atomic scale composition and structure. This new grant from the Leverhulme Trust offers exciting opportunities to expand on our previous work in this field and use new chemistry to design and prepare original examples of perovskites with improved properties for a variety of applications.” Professor Kidd’s project will be a collaborative enterprise with three colleagues in the Institute of Intellectual History at the University: Professors
Aileen Fyfe, Knud Haakonssen and Richard Whatmore, and three post-doctoral fellows. They will focus on three particular strands of post-Enlightenment Scottish life. Professor Fyfe will examine Scottish scientific culture between the French Revolution and the Disruption of 1843, focusing on the career of David Brewster. Professors Haakonssen and Whatmore will investigate Scottish moral philosophy and political economy in an era dominated by Dugald Stewart; and Professor Kidd will look at unbelief, freethinking and the legacy of David Hume in a period normally associated with evangelicalism and denominational rivalries. The Leverhulme Trust was established by the Will of William Hesketh Lever, the founder of Lever Brothers. Since 1925 the Trust has provided grants and scholarships for research and education. Today, it is one of the largest all-subject providers of research funding in the UK, distributing approximately £80m a year. For more information about the Trust, please visit www.leverhulme.ac.uk
z BRITISH AEROSOL MANUFACTURERS’ ASSOCIATION
Legislation for aerosols In addition to providing technical advice and a wide range of business support services for companies operating in every part of the aerosol supply chain, an integral part of the work undertaken by the British Aerosol Manufacturers’ Association (BAMA) is lobbying industry views to legislators and regulators.
Chief Executive of BAMA The majority of legislation which is relevant to the aerosol sector is of course pan European. The European Commission proposes a Directive (implemented by national legislation) or Regulation, (directly implemented into each Member State). This is then considered by representatives of the governments of the EU and ultimately, recommendations are agreed by the Council of Ministers, composed of the national ministers from the 28 Member States. Before these recommendations can be enacted however, they must be agreed by the elected representatives of each Member State which comprise the European Parliament. It is a challenging and lengthy process but by working with civil servants and lobbying MEPs, there are real opportunities to influence legislation at a local level.
A SPECIAL CASE
Almost without exception, aerosols present a special case in terms of legislation specifically. As well as the management of environment, and health and safety issues aerosols require specific expertise and in-depth knowledge of the technology, the industry and the issues themselves. And for many businesses, the challenge is that aerosols represent a major part of their profitability but are at the same time, the area which is the most vulnerable to adverse legislation or public opinion.
It is BAMA’s job is to manage that environment on behalf of its members co-ordinating and conveying the requirements and opinions of our industry to the UK Government, the European Commission and European Parliament. And as negotiations between the UK Government and the European Commission for the UK to leave the European Union get underway, it is something which is at the forefront of many business’ minds. Certainly it remains hard to discern what progress is being made and while we know that trade negotiations cannot start until the ‘divorce settlement’ has been agreed, there are many pieces of legislation where the possible changes that result will affect the aerosol industry to a greater or lesser degree.
A DOUBLE EDGED SWORD
Aerosols are an incredibly versatile product. It is a factor which underpins the success and growth of the industry but can be seen to present something of a double edged sword. Indeed there are many sector specific regulations which impact upon the aerosol industry, affecting the production of cosmetics, biocides, soaps and detergents and paints to name a few. The vast range of applications to which aerosols are suited means that BAMA works closely with a number of other trade associations including for example, the British Coatings Federation (BCF) and British Plastic Federation (BPF) as both seek to influence the European Commission regarding the reclassification of Titanium Dioxide (Ti02) which is a major ingredient in paints and plastics. Indeed the recent changes in classification of both Bisphenol A (BPA) and Titanium Dioxide are of widespread significance. BPA is a key component in the manufacture of
epoxy-phenolic coatings which are the most common and important class of aerosol cans and valve cup coatings. As long as the lacquer is cured correctly however, only trace residues of BPA ever remain in the coating. The European Food Safety Authority (EFSA) has evaluated BPA on many occasions in response to the various alleged negative health effects and has concluded that in current food contact applications it is entirely safe for consumers. The change to the classification of BPA however was anticipated and both can and valve makers have been working to find alternative materials for their coatings which are BPA non-intent. The reclassification of Titanium Dioxide prompted BAMA and the Alliance of Chemical Associations (ACA) to write to the Department for Business, Energy and Industrial Strategy (BEIS) to stress the vital importance of this material and work continues to influence the European Commission. The versatility of aerosols also means that they fall within the scope of the Aerosol Dispensers Directive which has recently been evaluated by the European Commission. Setting out the primary safety requirements for the aerosol package and the tests which must be made during production to protect consumer safety, it is believed that the directive will be left in its current format.
FOCUSING ON WASTE
Waste regulations are set to remain a major focus for BAMA. Hazardous waste in particular is a subject which BAMA has devoted considerable attention to in recent months – waste from factories specifically being classified as hazardous, depending on the contents of the can, means that it must be handled and disposed of in accordance with the relevant regulations. Following the new set of waste management regulations issued by DEFRA, namely WM3, BAMA has again worked closely with its colleagues at the ACA, to ensure all companies which dispose of aerosols as part of their operation, are aware of and have access to the appropriate guidance.
While aerosol dispensers have an excellent safety record both in transport and in use, they are pressurised containers and ‘dangerous’ for transport. As a general rule, ‘dangerous goods’ should be transported in UN approved packaging and be accompanied by detailed documentation. The UN allocates a unique number and name to each substance or article to aid identification. e.g. UN1950 Aerosols. Fortunately most aerosols are eligible for exemption from the full regulations applicable to one or more of the modes of transport and are subject only to the more relaxed
requirements and transported as ‘dangerous goods in limited quantities’. In these circumstances the outer packaging does not need to be UN approved.
A further, major piece of legislation which affects the aerosol industry is REACH. REACH is an EU regulation concerning the Registration, Evaluation, Authorisation and restriction of Chemicals. It came into force in 2007 and replaced a number of European Directives and Regulations with a single system. It exists to provide a high level of consumer health protection and safeguard the environment as well as driving innovation in the EU chemicals industry. Significantly, one of the key aims of REACH is also to make the people who place chemicals on the market including manufacturers and importers, responsible for understanding and managing the risks associated with the use of those chemicals. In practice this means that the registration of chemicals intended for use in consumer products must be made by a company which is a member of the EU. And the reality today is that at this juncture, it is simply not possible to say how this will affect the UK, following our departure from the union.
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WORKING WITH THE FEA
As a member of the FEA (European Aerosol Federation), BAMA is actively involved in FEA Committees, working in partnership to lobby for Amendments to Technical Progress (ATPs). Both the FEA and BAMA are committed to fostering innovation and driving improved performance across a broad range of products and to this end, lobbying activity in recent years resulted in agreement from the EC to allow aerosols with non-flammable and dissolved gases to be filled to a higher pressure. The challenge now is to get through an ATP on plastic aerosols which will mean that they are considered in a similar way to metal aerosols in terms of pack size.
A SUSTAINABLE FUTURE
Of course there are many more pieces of legislation where change is possible or indeed likely, the impact however being of less significance generally than the areas highlighted here. Ultimately, BAMA will continue its work to support the its members’ interests in the drive for a sustainable aerosol industry, helping to deliver clear and accurately timed lobbying to influence developments on key legislation. For more information: www.bama.co.uk
Two-billion-year-old salt rock reveals rise of oxygen in ancient atmosphere A 2-billion-year-old chunk of sea salt provides new evidence for the transformation of Earth's atmosphere into an oxygenated environment capable of supporting life as we know it. The new study by an international team of researchers, led by the Universities of St Andrews and Princeton, finds that salts left over from ancient seawater reveal new information about the oxygenation of the Earth's atmosphere more than 2 billion years ago. The findings, published in Science (22 March), found that the rise in oxygen that occurred about 2.3 billion years ago, known as the Great Oxidation Event, was much more substantial than previously indicated. "Instead of a trickle, it was more like a firehose," said Dr Clara Blättler, a postdoctoral research fellow in the Department of Geosciences at Princeton and first author on the study, "It was a major change in the production of oxygen." The evidence for the profound upswing in oxygen comes from crystalized salt rocks extracted from a 1.2-mile-deep hole in the region of Karelia in northwest Russia. These salt crystals were left behind when ancient seawater evaporated, and they give geologists unprecedented clues to the composition of the oceans and atmosphere on Earth more than 2 billion years ago. The key indication of the increase in oxygen production came from finding that the mineral deposits contained a surprisingly large amount of a component of seawater known as sulfate, which was created when sulfur reacted with oxygen. "The story is the salts," said Dr Mark Claire, School of Earth and Environmental Sciences at The University of St Andrews. "Decades of geologic observation by researchers at St Andrews (in collaboration with colleagues in Norway and Russia) lead to the discovery of a 600 metre thick pile of evaporated 2-billionyear-old seawater, in a drill core 2.5 km below the surface in Russia's Karelia basin. These are by far the oldest salt deposits ever discovered, and the well-preserved sulfate salts archive the aftermath of Earth's most dramatic transition ever – the ‘Great Oxidation Event." After demonstrating that the sulfate salts had not been re-dissolved since they were originally deposited, researchers at St Andrews
and Princeton University used state of the art geochemical measurements and modelling to show that the chemistry of the ancient seawater was similar to modern seawater. Dr Claire added: "We've documented that 2 billion years ago, microbes and the Earth System were acting quite a bit like they do today. Cyanobacteria were making oxygen and this O2 was reacting with continental sulfides to make sulfate, which washed down rivers and into the oceans where concentrations built up. Tectonic forces restricted some portion of that ancient ocean into a basin something like the modern-day Mediterranean, and sealevel changes allowed for repeated cycles of evaporation to build up the giant piles of salt. These data and observations prove that what has long been called the ‘Great Oxidation Event’ was in fact great, and profoundly changed the chemistry of the atmosphere and oceans." "This is the strongest ever evidence that the ancient seawater from which those minerals precipitated had high sulfate concentrations reaching at least 30 percent of present-day oceanic sulfate as our estimations indicate," said Professor Aivo Lepland, a researcher at the Geological Survey of Norway, a geology specialist at Tallinn University of Technology, and senior author on the study. "This is much higher than previously thought and will require considerable rethinking of the magnitude of oxygenation of Earth’s 2-billionyear-old atmosphere-ocean system." Oxygen makes up about 20 percent of air and is essential for life as we know it. According to geological evidence, oxygen began to show up in the Earth’s atmosphere between 2.4 and 2.3 billion years ago. Until the new study, however, geologists were uncertain whether this build up in oxygen –
caused by the growth of cyanobacteria capable of photosynthesis, which involves taking in carbon dioxide and giving off oxygen — was a slow event that took millions of years or a more rapid event. "It has been hard to test these ideas because we didn't have evidence from that era to tell us about the composition of the atmosphere," Blättler said. The recently discovered crystals provide that evidence. The salt crystals collected in Russia are over a billion years older than any previously discovered salt deposits. The deposits contain halite, which is called rock salt and is chemically identical to table salt or sodium chloride, as well as other salts of calcium, magnesium and potassium. Normally these minerals dissolve easily and would be washed away over time, but in this case they were exceptionally well preserved deep within the Earth. Geologists from the Geological Survey of Norway in collaboration with the Karelian Research Center in Petrozavodsk, Russia, recovered the salts from a drilling site called the Onega Parametric Hole (OPH) on the western shores of Lake Onega. The unique qualities of the sample make them very valuable in piecing together the history of what happened after the Great Oxidation Event. There has been a lot of debate as to whether the Great Oxidation Event, which is tied to increase and decrease in various chemical signals, represents a big change in oxygen production, or just a threshold that was crossed. The bottom line is that this paper provides evidence that the oxygenation of the Earth across this time period involved a lot of oxygen production. http://science.sciencemag.org/content/ early/2018/03/21/science.aar2687
consulting Safety Sustainability Profitability
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People Plant Process Productivity
z CHEMICAL SUPPLY CHAIN
Order books and sales turn positive margins under pressure Order books, current sales, and sales margins have all turned positive since the last CBA Trends Survey in November 2017 – but there is little momentum behind the outlook for sales during the next three months and sales margins continue to be under pressure. The CBA’s latest on-line Trends Survey was conducted during the two weeks, 26 February - 12 March 2018, and is based on responses from 51 member companies. Current order books and sales seem to be gathering some momentum, but the positive balance of responses is still only half the level reported in June 2017. Though still representing a positive trend, member companies are less optimistic in respect of sales over the next three months. Current and future sales margins, the most volatile aspect of these surveys, remain under pressure. The trends for industry employment and training levels are firmly positive.
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 – GATHER MOMENTUM
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 +27%, almost double the level (14%) reported in November 2017 – but this figure remains low by the standards of previous surveys.
SALES VOLUMES – IMPROVING
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 continue to show a positive balance of +29%, an improvement to the positive balance of +11% reported by CBA’s last survey. Future sales remain in positive territory at +18%, marginally higher than reported in November 2017 (+14%).
SALES MARGINS – POSITIVE, BUT WEAK AND UNDER PRESSURE
Companies are asked to compare their current sales margins with the preceding three months and forecast their trend over the coming three months. Current sales margins have turned positive, recovering from the negative balances reported in the last survey, but only to the extent of a positive response of +6%. Little improvement is expected over the next three months with member companies reporting a positive balance of just +4%.
EMPLOYMENT AND TRAINING – POSITIVE TREND MAINTAINED
Member companies were asked if their employment levels and investment in training would be higher, lower, or remain the same over the next three months. Trends for both employment (+27%) and training (+48%) remain firmly positive.
CHEMICAL SUPPLY CHAIN z
Current order books and sales seem to be gathering some momentum, but the positive balance of responses is still only half the level reported in June 2017. Though still representing a positive trend, member companies are less optimistic in respect of sales over the next three months. Current and future sales margins, the most volatile aspect of these surveys, remain under pressure. The trends for industry employment and training levels are firmly positive.
z CHEMICAL SUPPLY CHAIN
Building strength through a strong supply chain Small and medium businesses have significant impacts on value chain performance, taking the roles of suppliers, producers, distributors, and customers. The backbone of the UK economy, they drive growth, open new markets and create jobs. They are seedbeds for innovation, encouraging competition and bringing fresh ideas that challenge the norm – and in turn, incentivise others to adapt. Put simply, the contribution of small businesses is vital, and we should encourage them to thrive. And many are. Confidence in an improving and positive economic outlook sees flourishing ambitions for growth. The road to recovery is most certainly paved with opportunity. At NEPIC, we understand the importance of SMEs and the vital role they play in the longterm success of the region’s chemical industry. That is why the success of these businesses remains at the fore of our interest. A very large and extensive supply chain supports the Process Industry in North East England and essentially underpins the sector. The key strengths of North East supply chain companies are their long-term competency and knowledge, combined with a real understanding of the chemical industry’s needs. As a true supply chain cluster, NEPIC actively engages with the entire value chain and has recently witnessed an increased desire from the major manufacturing companies within the region to spend more of their budgets locally. In 2012, the cluster set upon a path to further develop the SME community by providing the incentive to advance their businesses, in turn bringing about economic benefit and reinforcing the North East as a region of excellence and innovation. The Business Acceleration for SMEs programme was subsequently rolled out and, via the mentoring of 500 companies, generated £50 million in new sales and over 1,000 new jobs for North East small businesses. Never happy to rest on our laurels, NEPIC is continuing this work via two further
programmes – Innovate Tees Valley and SME Growth. Through Innovate Tees Valley, we are assisting companies to innovate by improving their goods and services and sharpening their business processes. And through SME Growth, we are working to give firms a competitive edge, strengthen their pitch, support exporting efforts and obtain new customers in the sector.
ACCELERATING GROWTH FROM IDEAS
More specifically, Innovate Tees Valley has been established to help Teesside’s vibrant small business community achieve growth through service and product innovation. Assisted by the programme’s network of experts, NEPIC and our programme partners, are helping businesses to take their ideas forward, whilst also overcoming growth barriers to achieve success here and overseas. Innovation remains a long-standing debate within the SME sector, however, one thing is definite – innovation is a crucial element within the SME ecosystem that is here to stay. Every SME needs to create an innovative environment to foster growth and success. “Our knowledge of the process industry will allow us to provide intelligence and introduce companies to markets both in the Tees Valley and outside the region. The world is changing and NEPIC can help SMEs understand global challenges and opportunities in the process industry and across other sectors,” said programme lead, Joanne Rout. Joanne, a former ICI research scientist and product development manager, added: “So far more than 50 companies have signed up with NEPIC for innovation support. Over the project’s three-year duration, NEPIC will help many SMEs with ambitions to develop new products and processes, along with these seeking better ways of doing business.
Joanne concluded: “If change is afoot in your organisation or market environment, no matter how big or small, we can support you on the way.”
HELPING SMALL BUSINESSES ACHIEVE GREAT THINGS
In addition to this innovation focus, NEPIC is also continuing its generic growth support via the SME Growth Programme. The programme, launched in spring 2017, supports businesses in Durham, Tyne and Wear and Northumberland to become established suppliers within the region’s chemical processing industry. The programme, which is a direct spin-off from NEPIC’s highly successful Business Acceleration for SMEs project, utilises the cluster’s extensive knowledge and network to mentor companies into new business. The NEPIC project team is assisting a diverse range of SMEs operating in areas such as engineering, biotechnology, environmental, chemical, consultancies and support services, all of which can be sold into the NEPIC network of businesses.
Our knowledge of the process industry will allow us to provide intelligence and introduce companies to markets both in the Tees Valley and outside the region. The world is changing and NEPIC can help SMEs understand global challenges and opportunities in the process industry and across other sectors Joanne Rout, Programme Lead
However, this support extends beyond NEPIC’s experienced team and includes senior managers from within the Cluster’s extensive membership base, whom have all pledged their time to support the programme and mentor businesses into growth. Furthermore, our participating SMEs also benefit from a full sales and marketing training programme. SME Growth programme manager, Philip Aldridge, said: “Industry’s message is loud and clear. They want to buy locally from a strong regional supply chain that can support a growing sector long into the future - and they are prepared to put the leg work in to achieve it. Through their support of this programme we offer invaluable knowledge and advice, coupled with direct access to an established network. He continued: “The model is simple, yet highly effective. We work with companies to understand their business and offering. An access approach is agreed and industry mentors assigned. Once in place, companies then work with their mentors and the team at NEPIC to develop everything from positioning and pitch, right through to product placement
CHEMICAL SUPPLY CHAIN z
and exporting. Companies also gain access to the Cluster’s established network of businesses and likeminded contacts. Philip concluded: “There are no catches. This is a fully funded programme designed to arm local suppliers with the skills, approach and contacts that will enable them to play a strong role in the success of the sector and ultimately help them achieve business growth. “We urge businesses to get in touch today, find out more and tap into this vital free support.” For further information regarding supply chain and SME support provided by the NEPIC core team and that of the Innovate Tees Valley and SME Growth programme, please contact the office directly via 01642 442560 or visit www.nepic.co.uk/smes
innovate TEES VALLEY and SME Growth via Facilitated Market Access & Energy Management are both threeyear, part-funded European Regional Development Fund projects.
CHEMICAL COMPANIES FROM OAMPS Our more than 30 years of experience with fuel distributors made the addition of chemical companies in the last decade a natural transition. Over the last few years we have been developing our offering and we now provide specialist insurance services to the full range of chemical industries. We wonâ€™t just arrange standard commercial insurance for you, our core package includes cover for risks unique to the chemicals sector: - Crisis-management and media protection - Cost of Stock Debris Removal - Clean-up of Own Land (following a sudden & unforeseen spillage of product) up to ÂŁ250K as standard - Stock Cost Fluctuation (to manage product cost variations) 15% uplift - High Public Liability limits of indemnity available - Statutory Environmental Protection up to the Public Liability limit of indemnity - Rehabilitation Services Clients of OAMPS will automatically benefit from Level 2 & 3 Environmental Response Service in the event of a spillage 24/7; we offer Level 1 Environmental Response Service at a discounted rate. We can also offer specialist driver training in ADR and CPC at a discounted rate via our parent company.
WHAT TYPE OF BUSINESSES DO WE WORK WITH
Companies who manufacture, blend, wholesale, import/export, store and/or haul chemicals across a diverse range of industry sectors
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OAMPS is a trading name of Pen Underwriting Limited, which is authorised and regulated by the Financial Conduct Authority (FCA 314493) Registered Office: The Walbrook Building, 25 Walbrook, London, EC4N 8AW, Registered in England and Wales. Company Number: 5172311
Croda acquires marine biotechnology Specialists Nautilus Croda International Plc, who create, make and sell speciality chemicals for some of the biggest, most successful brands in the world, have announced that it has acquired Nautilus Biosciences Canada Inc (‘Nautilus’), a technology-rich marine biotechnology company based in Charlottetown, Prince Edward Island, Canada. Nautilus was founded in 2007 by Professor Russell Kerr and, together with its world class scientists, focuses on using marine microbial biodiversity to discover novel actives and materials. Through this acquisition and the associated patents, Croda will utilise this innovative science for applications across all its market sectors.
Brenntag Colours completed REACh registration dossiers Comprehensive support for our customers The final deadline for REACH registration is only a few months away... are you prepared? Will you still be able to source the pigments and dyestuffs that your business needs? We are fast approaching the final REACH registration deadline of the 31st May 2018 which will affect all companies that manufacture or import substances into the EU including pigments and dyes in volumes exceeding 1 MT /annum. In order that our customer-base can continue to purchase their on-going demand from Brenntag Colours, we have been busy completing and submitting our registration dossiers to the European Chemicals Agency (ECHA) so that we will be compliant with this regulation. This exercise has involved significant expenditure for the Brenntag Colours business and underscores the commitment of the Brenntag organisation to continue to supply and service customers across a number of our key industries including the plastics, coatings and construction and cleaning market sectors. Richard Heeley - Business Manager of Brenntag Colours commented, "Brenntag has invested heavily in the Brenntag Colours laboratory based in Halifax and we have
technical teams in place to be able to produce and colour match paint and plastics samples for our customers. Indeed, we aim to create long term relationships with our customerbase by providing them with extensive technical support for both existing and new products. The investment in REACH represents a considerable and necessary cost to ensure that we can continue to meet our customers’ needs. Clearly, we will need to continue to ensure that all REACH dossiers are kept up to date whilst looking at bringing on new and innovative grades on to the range for future product development." Dr Maura Jolliffe - Head of Material Science, Brenntag UK & Ireland, added, "We are delighted that the Brenntag Colours Business will continue to be REACH compliant beyond the end of May 2018. Our experienced technical teams, encompassing Brenntag Colours, Brenntag Material Science and Brenntag Technical Marketing, are ready to support our customer-base and address any REACH concerns that our customers might have. Indeed we would welcome discussions with any companies that would like to talk about their future sourcing needs for colours products." www.brenntag.com/uk-ireland/en/brenntaguk-and-ireland/media/brenntag-colourscompleted-reach-registration-dossiers.jsp
Croda and Nautilus already have a proven history of successful collaboration, having worked closely together for the past six years developing specific applications for skin care and hair care, as well as crop care. Croda intends to establish Nautilus as a Croda Centre of Innovation for Marine Biotechnology at Nautilus’ existing base at the University of Prince Edward Island. This location is ideal for biotechnology research and has already attracted and facilitated partnerships with many other biotechnology-based companies. Nautilus has exclusive global access to the Marine Microbial Library which is based at the University of Prince Edward Island. Steve Foots, Chief Executive of Croda, said: “This is another clear example of how sustainable innovation is underpinning our growth plans. With Nautilus as part of the Croda Group, we further expand our expertise in biotechnology; the Nautilus team that will join us have extensive knowledge and expertise in marine biotechnology, also known as “blue biotechnology”. We will be able to bring new, patented products to market, alongside our already well-known green and white biotechnology ingredients, giving us the full spectrum of capabilities within this field of science.”
z BIG INTERVIEW
RAS Ltd - building on 25 years’ experience From its headquarters in Chester, RAS Ltd provides risk management consultancy services to COMAH and high hazard establishments across the UK and further afield, delivering practical and sustainable solutions for safety, business and environmental risk management. The Chemical Industry Journal talks to Carolyn Nicholls, Operations Director of RAS Ltd about how they approach their work, and their plans for the future. UNDERSTANDING RISK
“Risk management begins with understanding, you can’t manage what you don’t understand,” says Carolyn. “What we are about is risk, helping our clients to understand risk. “One of the greatest challenges we face is the assumption that red tape and regulation stifle innovation, but in fact, they can be very good for business. In essence, complying with regulation is good for a company’s bottom line. We help clients to understand why regulation is there in the first place, what it is trying to achieve and to recognise the benefits.”
PEOPLE AT THE HEART
As our discussion continues, it becomes apparent that RAS Ltd is a very peopleorientated business. “When you work in risk it is all about people,” continues Carolyn. “As a business, people are central to everything we do, both in delivering a service to our clients and as employers.”
them the training needed to develop their competencies,” continues Carolyn.
This approach to recruitment can be traced back to co-founder Andy Stanley, who quickly found that his nuclear physics background was useless unless he could communicate well with people. In looking for employees then, Carolyn focuses on finding a candidate with the right attitude and who is the right fit for their team – then trains them up. Employing candidates from a wide variety of backgrounds is advantageous both to the company, and their clients, as issues are examined from many different perspectives. As Carolyn explains “in asking questions and in looking for answers we can cast our net wide.”
CONTINUED PROFESSIONAL DEVELOPMENT
As employers, RAS Ltd takes a distinctive approach to their recruitment, “we see the potential in people from a wide variety of backgrounds and have graduates within our team from many different disciplines including engineering, mathematics, chemistry and geography – to name but a few.
Carolyn is committed to growing her team, giving them the opportunity to develop their skills in-house. As Operations Director, this is very much the path that Carolyn has followed, joining the business soon after she graduated and staying there ever since. Carolyn has now been with the business for twelve years, becoming a director after nine, now she is inspiring the next generation.
“Traditionally those working in the process safety industry have been chemical engineers, we take a different approach looking for the right person to join our team, then giving
Overall, Carolyn is responsible for making sure the company runs smoothly and that the work coming in is allocated to the right people. Part of that is ensuring her team have
the training and tools they need to do the job. “From the moment they start, new employees are encouraged to build their experience and develop their skills,” comments Carolyn.
A number of the team are now working towards Professional Process Safety Engineer registration with The Institution of Chemical Engineers (IChemE) - the global professional membership organisation for those working in the chemical, process and bioprocess industries. “When we invest in our people it is brilliant on so many levels, benefitting them, benefitting us and our clients,” continues Carolyn. “We are immensely proud of the team, they have put in so much effort, and it is great to see the fruits of their labour.” The faith the company shows in their team is repaid in loyalty and long service, with a high retention rate amongst their employees – the difficulty across the industry in finding and holding onto skilled personnel is not reflected at RAS Ltd.
WORKING AS A TEAM
When it comes to working with their clients, people again, are at the heart of everything they do. As Carolyn says “When we begin working with clients, we become part of the furniture, we work as one team, it is not a case of us and them.” The high regard in which the company is held by their clients is indicated by the fact that some of their clients have been with the company since the early days – 25 years ago. Another indicator is that most of their work comes via word of mouth and personal recommendations. “We do things because we believe in them,” comments Carolyn, “we always ask why? We don’t simply do what we are being asked to do, we will always question if what we are being asked to do is what is needed to solve the client’s problem. “You need to really question what you are doing and why – look at the issue from
BIG INTERVIEW z
When we invest in our people it is brilliant on so many levels, benefitting them, benefitting us and our clients,” continues Carolyn. “We are immensely proud of the team, they have put in so much effort, and it is great to see the fruits of their labour. Carolyn Nicholls, Operations Director, RAS Ltd
different angles. This is the first thing we do when we are asked to work with an organisation.”
BUILDING A LASTING RELATIONSHIP WITH CLIENTS
It is this ethical approach to business that has led to such lasting relationships with their clients over the years. “We make sure we strongly believe what we are doing is right” says Carolyn, if the team feels that a client’s request is not in their best interests, they will always offer the most efficient and practical solutions - it is an approach that keeps clients coming back, such is their level of trust. The RAS Ltd team is growing steadily, still nimble enough to adapt swiftly to clients’ needs, but established enough that they can deliver their services across the UK and internationally. In the 25 years since their
foundation, the company has built up an impressive roll call of clients including oil companies, oil refineries, oil storage facilities, pharmaceutical companies, speciality chemical companies, the food and drink industry and major airports – helping them all to identify, assess and manage risk.
AN EVOLVING INDUSTRY
Carolyn and her colleagues now stand at the forefront of the industry, taking part in working groups and presenting papers at international conferences, always developing their specialist knowledge. Traditional hazards may remain, but new hazards are emerging, the process safety industry is constantly evolving and there are always new things to learn. When asked about the secret of their success Carolyn is decisive: “It is all about
keeping people at the centre of all we do, understanding our clients’ needs and why they are asking for help. As a company, we are also nimble, and if something needs doing, we do it, on time and in budget. Knowing we will do so builds trust with our clients and gives them certainty.” To Carolyn and her team it is clear, do not offer a one-size-fits-all solution, but instead keep things personal, delivering a solution tailored to the needs of each individual client.
LOOKING TO THE FUTURE
Moving forward, 2018 is looking to be an exciting year for RAS Ltd, not only is the company celebrating their quarter century, but they are just about to present two papers at the world’s leading process safety conference Hazard28 – a rare accolade indeed. Whilst the search is on to find the next bright spark or two to join the company.
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:
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 • firstname.lastname@example.org • www.ras.ltd.uk
Increasing environmental penalties – a loss of momentum? Environmental sentencing guidelines which came into force in 2014 have increased the level of fines imposed by the courts in some pollution cases. The judicial message has been that fines should be at a level that will ensure directors and shareholders understand the need for environmental compliance, most notably in a 2015 Court of Appeal judgement involving Thames Water: the court indicated that fines up to 100% of pre-tax net profits could be appropriate for serious offences committed by very large organisations, even if that means fines of £100 million. Despite this, the upward trajectory of fines may be slowing and is perhaps becoming more intermittent. On recent form, one might have expected an escape of raw sewage that led to the death of hundreds of fish to be dealt with harshly, especially when the offender is
a very large, well-resourced company with a history of water pollution incidents. However, Yorkshire Water received a £45,000 fine (with costs of almost £25,000) from Sheffield Crown Court last December for its permit breach at a Doncaster pumping station. The Environment Agency (prosecuting) could presumably have appealed the level of fine if it considered it too low, but no such appeal was brought.
regulator and offender includes several household name companies. Thames Water, Northumbrian Water, Anglian Water and United Utilities make up the water industry’s contingent with 8 undertakings between them, involving in total payments of £862,000. Such payments are probably lower than a fine would be for serial offenders, and certainly carry less reputational damage.
Not all environmental offences are prosecuted, and the Agency’s scope for enforcement options other than prosecution has broadened in recent years to include the imposition of civil sanctions. The intention is that these are not to be a soft option. A recent list of the enforcement undertakings agreed between
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Challenges to comply with global chemical regulations Dr. Michael Cleuvers, Dr. Knoell Consult GmbH, Germany The consumption of chemicals by many industries and modern society’s reliance on chemicals for countless manufacturing processes make chemicals production, formulation and trading one of the major and most globalized sectors of the world economy. At the same time, there are potential adverse impacts of chemicals on the environment and human health. The diversity and possible severity of such impacts makes sound chemicals management a key issue for sustainable development. Thus, many countries are currently revising their existing chemical regulations, or introduce completely new ones, to cope with the aim of the UN/WHO initiative on a “Strategic Approach to International Chemicals Management (SAICM)”. This framework includes the commitment to achieve that by 2020, chemicals are used and produced in ways leading to minimization of significant adverse effects on human health and the environment. However, whereas classification & labelling criteria are moving towards global harmonization via GHS (although this is currently not yet global nor completely harmonized), the different approaches for the notification of chemicals are far from harmonization. There are considerable differences e.g. in the overall scope, the affected substances, information requirements, risk assessment and the question how to deal with substances of very high concern (SVHCs). To cope with these regulatory requirements is challenging and delay or even disruption of market access is a potential, but realistic risk. Many countries introduced chemical inventories, which list the chemicals manufactured or imported into a country, like the USA (TSCA), Canada (DSL), Australia (AICS), China (IECSC), Japan (ENCS), Republic of Korea (KECL), the Philippines (PICCS), Turkey (CICR), or Taiwan (NECI). It is crucial to check all relevant inventories, in particular because manufacturers and/or importers of new substances have to submit
notifications before they can start their business. In some countries there is not even a tonnage trigger, i.e. all new substances, although in very low amounts need to be notified. A substance may be an existing one in country „A” and “B“ but a new one in country „C” and “D“, which may trigger unexpected requirements.
There are also clear differences globally in accepting alternative approaches to fulfill the data requirements without generating new tests, e.g. read-across, QSARs, or the use of expert statements in general. The fact that ECHA has accepted your justifications to avoid testing under EU REACH has no meaning for other authorities, particularly in Asia.
In addition to new substances, some regulations also demand the notification of existing substances. Sometimes, like within EU REACH, all existing substances above a certain tonnage trigger (1 t/a) have to be notified, while e.g. in Taiwanese TCSCA this is applicable only to a list of prioritized existing substances. This is still also the case in Korea, but the current amendment which will enter into force in January 2019 will change the scope in alignment with EU REACH to all existing chemicals above 1 t/a.
In summary, there are many important factors to consider when you are trading chemical products on a global level. An in-depth knowledge about applicable regulations in your target markets and a thorough preparation are essential to avoid any incompliance.
Other legislations, like China´s Decree 591, or the EHSNR in Malaysia focus on hazardous substances (i.e. do not distinguish between existing and new substances), incl. a prioritization scheme. However, the criteria for classification as hazardous are not fully harmonized and the criteria for prioritization might differ. Several countries have different notification schemes in place, e.g. simplified notifications for low tonnages and/or polymers of low concern. There might also some exemptions valid for the one country, but not for the other. Thus, check this carefully. An important factor to determine the costs of a notification are the (often tonnage dependent) data requirements, which differ considerably. Even if you have many data at hand, you might not be able to use them in all countries relevant to you. The OECD agreement on mutual acceptance of data fulfilling quality criteria like GLP has not been globally introduced. China for example wants applicants to do the majority of the ecotoxicity testing in China, incl. biodegradation testing. The latter is also true for Japan. Thus, when determining the data requirements, it may come out that you have to perform even more than one test per endpoint (e.g. fish, biodegradation) or additional studies compared to EU REACH.
Solutions for Global Chemical Compliance Handling chemical products in a way that minimizes the risk to man and the environment is not an isolated local task. Companies selling their products internationally, will often face speciﬁc regulations for the safe use of chemicals in their target markets. Considerations need to take into account global initiatives and frame works like GHS, SAICM or TDG but also numerous country speciﬁc approaches for the risk management of chemical products. Knoell with its global network of aﬃliates and partners keeps track of the developments concerning global chemicals management and supports its clients with the most suitable strategy for their products and target markets. Our services include, but are not limited to: » Strategic advice on how to comply with global regulatory duties » Identiﬁcation of components that require special attention due to their hazard and risk proﬁle » Complete registration services for EU, Switzerland, Turkey, China, Taiwan, Korea, Japan, ASEAN countries, USA, Canada, Australia and others incl. local representation » Complete Global Safety Data Sheet management
We have been an independent service provider for the chemical and pharmaceutical industries since 1996, with currently over 550 employees at sites within the Europe, Asia and the USA. For further information visit www.knoell.com or call us.
Dr. Knoell Consult Ltd. Dr. Iain A. MacKinnon Managing Director Tel +44 29 2034 9880 imacKinnon@knoell.com www.knoell.com
Dr. Knoell Consult GmbH Dr. Thomas Berbner Regional Director Business Development EMEA - Industrial Chemicals Tel +49 621 718858-126 email@example.com www.knoell.com
Dust Explosions – Are You At Risk? The explosion that claimed four lives at Bosley Mill, Macclesfield in July 2015 acted as an unwanted reminder of the hazards that can be posed by combustible dust. Risk assessments are a valuable tool in identifying and preventing or mitigating combustible dust fire and explosion hazards. In the UK, a ‘suitable and sufficient’ assessment of risk is required to comply with the Dangerous Substances and Explosive Atmospheres (DSEAR) Regulations. DSEAR enacts European Directive 1999/92/EC (ATEX 137) on minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres. There are many approaches to conducting a risk assessment with respect to combustible dust hazards. The recently published CCPS “Guidelines for Combustible Dust Hazard Analysis”1, for which BakerRisk® experts were contributing authors, provides perhaps the most current and comprehensive overview of the different dust hazard analysis (DHA) approaches available to a facility.
The most common issues identified during the hundreds of risk assessments performed by BakerRisk
over the last several years are as follows:
1. Lack of a defined inspection and cleaning plan to meet housekeeping requirements 2. Lack of data on the explosion potential for specific dusts 3. Lack of rated deflagration isolation device (e.g., fast-acting gate valve, chemical suppression, etc.) as required by EN 15089:2009 4. Lack of restricted access zones around equipment equipped with deflagration vents 5. Lack of design basis information to support explosion protection design (see Figure 1 below). 6. Lack of design basis system flow velocities 7. Lack of duct inspection hatches 8. Spark suppression system nozzles located too far from spark source
Figure 1. Analysis of Baghouse Failure under Suppression Injection Pressure. BakerRisk assessed the capacity of a rectangular baghouse with an explosion suppression system and determined that the baghouse would fail at the roof-to-shell seam without additional structural reinforcement. It was found that activation of the suppression system, even inadvertently, posed a significant hazard to the operators.
Center for Chemical Process Safety (2017) Guidelines for Combustible Dust Hazard Analysis, ISBN 978-1-119-01016-6, CCPS, New York, NY (Dave Kirby and Phil Parsons of BakerRisk both contributed to this guideline).
These common issues have all been causal factors in actual combustible dust fire or explosion incidents
that resulted in the loss of life or severe injury as well as asset damage and business interruption. Performing a robust risk assessment should identify such problem areas and, using the guidance provided in relevant standards and literature, identify prevention and mitigation strategies than can be implemented to manage the risk associated with combustible dust fire and explosion hazards.
BakerRisk Engineers have over 20 years of experience assisting clients with dust hazard evaluations and have conducted hundreds of incident investigations.
BakerRiskâ€™s strategic positions on the relevant international committees provide a confident assurance that evaluations are performed correctly.
To learn more about BakerRiskâ€™s combustible dust hazards analysis (DHA) services, and how we can help you be prepared, please contact us BakerRisk Europe Limited Thornton Science Park Ince, CH2 4NU, United Kingdom Tel: +44 (0) 1244 405960 or visit us at www.BakerRisk.com
Exwold Technology is celebrating 25 years of business
In 2018 Exwold Technology is celebrating 25 years of business. With record breaking sales in 2017, Exwold has continued to grow and develop while continuing to specialise in contract formulation and solids processing. STEP 3: GRANULATION
Extrusion is a core technology for Exwold and the company name originated from the use of this technology. Exwold is an expert in the formulation of granules for the Crop Protection market with 3 sites dedicated to the production of granules using both extrusion and more recently pan granulation technologies. 1000’s of tonnes of granules per annum are produced at these sites.
Exwold employs the industry standard technology for extruding granules based largely on radial extrusion. Low pressure extrusion techniques offer a versatile approach to a variety of granulation requirements including non crop applications. The granules range in diameter from 0.5-2.0mm.
A typical process is:
The range of benefits offered by granules includes:
STEP 1: BLENDING AND MILLING
• Improved flow characteristics
Based on the clients formulation, product is blended and millled using an Air Classifier Mill or Jet Mill to obtain particle sizes of <30 micron to produce a Feedstock.We can process sensitive materials with an explosion rating up to KST2 with the system equipped with Explosion Suppression system.
• Improved efficiency
STEP 2: FORMATION OF DOUGH
• Controlled particle hardness
Under controlled conditions, water is added to form a dough.
• Controlled dust • Uniform particle size range • Controlled Bulk density • Uniform blends Exwold have also introduced Pan Granulation technology at the Haverton Hill site.
STEP 4: DRYING
Using Fluid Bed Drying technology.
We have a facility dedicated to Highly Active herbicides. A combination of a stand alone facility and stringent clean-down processes Exwold provides our clients with confidence in meeting the industry’s strict requirements on cross contamination levels. This facility is scaled to produce 500kg a day depending on the formulation and also to pack on site. Exwold’s 4th site based at Brenda Road, Hartlepool offers wide ranging solids processing capabilities including: Compaction: Producing thousands of tonnes of granules using roll compaction technology which can be used to improve flow of powder products or for applications such as de-icers. This technology uses very high pressure, passing powder through two rollers compressing it to form a flat “ribbon” which is then milled to the desired granule size. Granule size ranges from 0.5-10mm. 2017 saw significant investment in the compactor unit to improving the operation and environmental control.
Exwold Blending Case Study CUSTOMER PROBLEM:
Our customer had formulated a laboratory scale blend of various components to reproduce the physical properties of a waste product to be removed from a hazardous environment. They required scale up to multi tonne bulk material to enable trials to be carried out in 5 weeks of enquiry being received to test their waste removal process. Key issues Milling: Capabilities to mill solid products, technologies offered include:
and Laboratory Supply sectors plus Crop Protection markets
Kibbling is often referred to as crushing, de-compacting or granulating and uses cheese-grater type screens or rotating knives to provide a coarse product with particle diameters of between 3mm and 25mm.
Packing: 5 packing lines are available at Brenda Road for packing of bulk granules and powders produced across the business. Packing ranges from 1kg packs upwards providing an in-house packing solution for customers. Exwold opened an additional packing unit in 2017 due to increased Crop Protection demands and have made further investments in 2D matrix printing capabilities.
Milling: • Using hammer/pin mills we can produce a coarse material with a particle diameter of 2000 microns or below. • Using our Baumeister Turbo mill we can achieve smaller particle sizes down to 75 microns. The Micronisation capabilities Exwold can offer you include: • Air Classifier Milling (ACM) and Jet Milling • Milling to approximately 10 microns in diameter Blending , Impregnation and Coating : 8 blenders ranging up to 10,000L are available for charging and blending of solid ingredients combined with liquid addition capabilities. Exwold currently contract blend for the Biocide, Metal Working, Plastics, Fine Chemical,
Exwold continue to re-invest in their core business and this year investments planned in the first 6 months include:
• Complex blend of components of varying particle sizes • Maintaining the various particle sizes essential to the product in use • Homogeneous blend required of components, some present in trace quantities • Short timescale • New customer with tightly regulated internal processes
• New 2,000L Drum Blender planned for installation and commissioning Q2 with capabilities to dual pack increasing potential capacity upwards of 10,000mtpa. • Up-grade of Packing Lines to improve operational efficiency. • Up-grade of ERP system in the first 6 months to support the continued business growth Take a look at the Exwold website for up-dates on completion of these investments as they complete along with more information about Exwold’s capabilities. www.exwold.com
Through close cooperation with the customer we were able to perform the required COSHH assessment, develop a suitable production process, provide a quotation, identify suitable packaging and reserve a suitable production slot to allow manufacture and delivery within the required timescale. By initiating vendor approvals and customer account set up ahead of receipt of order we were able to ensure all necessary documentation was in place before the raw materials were received. This allowed production to proceed and finished product to be tested and delivered to customer in good time for their planned trial.
z PROCESS SAFETY
Making good practic In this edition of the Chemical Industry Journal, we speak to Richard Roff and Neil Smith about their work with the Process Safety Management (PSM) Competence Programme Board, discussing the progress that’s been made and their hopes for the future. We last spoke to Richard, chair of the board last summer, and it has been a busy few months. The board will soon be hosting their third Process Safety Management summit in Manchester, held in partnership with the Process Safety Forum and the COMAH Strategic Forum. Entitled “Making good practice, common practice” the summit will bring together practitioners and executives from industry, stakeholder and regulatory bodies to illuminate best practice guidance and highlight the support available to industry from the various forums. In his day job as Group Process Safety Manager at Costain Group PLC, Richard advises on the strategic implementation of process safety management techniques across all of their businesses – making him well placed to chair the board. The PSM Competence Programme Board is composed of senior industry representatives and stakeholders from trade associations such as the Chemical Industry Association, trade unions including Unite, professional bodies and the Health & Safety Executive (HSE). “We try to attract as wide a range of voices on the board as possible,” says Richard, “we want the board to be representative of industry so that the resulting training programmes are looked after by a group interested in their use.” The PSM Competence Programme Board was set up in 2010, in the light of major incidents
such as the Texas city BP disaster and the Buncefield fire at the Hertfordshire Oil Storage Terminal. The motivation for establishing the board was a desire to make business leaders in the hazardous industries aware of their critical role in establishing a safe culture and processes within their organisation. Senior leaders needed to better understand what process safety was, and their role in establishing those safe processes. These concerns were backed-up by the findings of the HSE in their investigations, which found a lack of knowledge and understanding amongst leadership teams. “In essence, we are trying to make sure that the lessons we have learned the hard way in the process industries are widely understood, and that information is easy for organisations to access, in the hope that they won’t have to learn the same way,” continues Richard. “The vision of the PSM Competence Programme Board is that people understand what might happen, understand their part in preventing catastrophic incidents through education, competence and knowledge.” The leadership standard was the first in a series of industry standards subsequently written by the board, after that first standard was developed came the first course delivered in 2011, aimed at providing the knowledge, competency and skill needed to ensure safe working practices.
The underlying principles of process safety can be applied to the management of hazards and risks in many sectors, and in companies of all sizes. Businesses need to understand that a catastrophic event is possible, to understand what preventative processes they have in place and whether those measures are working.
Since those early days, the programme’s scope has broadened to encompass not only leaders but also operators and managers working in hazardous industries and those working in other sectors entirely. As Richard explains, “some industries may feel that process safety has nothing to do with them, but if you detach the details and look at the concepts, these are not only relevant to high hazard industries like the chemical industry but to others too. “The underlying principles of process safety can be applied to the management of hazards and risks in many sectors, and in companies of all sizes. Businesses need to understand that a catastrophic event is possible, to understand what preventative processes they have in place and whether those measures are working.” The board has its roots in the work of the National Skills Academy Process Industries (part of the Cogent Skills Group), and these organisations share a common desire to develop the specialist skills required to manage businesses. The board has set about transforming the way knowledge and training needs are met, publishing their first UK Strategy for Competence in Process Safety Management in 2012, updated in 2015 – with feedback from the imminent summit informing the next three-year strategy period. The PSM Competence Programme Board is in effect run by volunteers, supported by their employers, who allow them the time to carry forward their important safety work. The secretariat of the board is Cogent Skills, part of the Cogent Group, who are themselves a not-for-profit organisation with charitable status, which has a number of charitable objectives around the education, training and development needs of employers and employees. Cogent has long been the custodian of the national occupational standards in the process safety arena, and don’t simply deliver the training themselves, but work with partner organisations to provide the training - all of whom are put through a stringent approval process. This robust approach to the recruitment of trainers maintains the high quality and effectiveness of the training. Moreover, Cogent and their partners can tailor the courses to the specific needs of individual businesses, as they have done so for British Steel, Centrica, Costain, GSK, Johnson Matthey,
PROCESS SAFETY z
ce, common practice National Grid, Tata Steel and Unilever. Taking the training in-house, and adapting it accordingly, means the training will reflect the terminology and hazards specific to that business – making it all the more useful and relevant. Taking the lead in this bespoke training is Neil Smith, Head of Workforce Development at Cogent Skills and a founder member of the PSM Competence Programme Board. In addition to over 20 years’ experience leading and delivering skills and competence development programmes, Neil is no stranger to hazardous operations. Neil’s early career as an aircraft engineering artificer and flying maintainer in the Royal Navy on ASW and Commando Helicopter Squadrons means he is uniquely placed to understand the value of robust process safety. His early career saw him spend two winters inside the Arctic Circle, with deployments in the European theatre of operations, the Mediterranean, the Far East and the Gulf,
primarily supporting mountain flying and desert operations. Right from the start Neil has been involved in the development of the PSM training standards and ensuring that the standards are supported by appropriate training provision. Highlighting the progress that has been made since the board was established in 2010, Neil says, “It has been great to see participating employers reporting that their number of small-scale incidents has halved and this is particularly significant given the pattern that has emerged historically of small incidents being the precursors to more serious incidents.” Where some initiatives cause initial excitement and then fizzle away shortly afterwards, the board has now been meeting monthly for over seven years, and their industry standards and training have provided a lasting legacy. The work of the board says Neil has brought about a whole new cultural awareness and understanding. “Previously,
industry training tended to focus on the technical aspects of a job and not set these in the context of process safety. Now there is a much greater understanding of the efficacy of process safety, of what processes should be in place and why.” The growth in participant numbers since the first course was established has been huge. To date, around 10,000 people have attended the PSM Competence Programme Board’s training programmes, including 180 companies that run COMAH facilities and around 100 companies that sit outside the COMAH regulatory framework. Moving forward the board is focused on engaging more organisations in their industrycreated, industry-approved training, with the hope of making good practice, common practice, in the chemical industry and beyond, and vastly reducing the likelihood of any further serious incidents.
Skin sensitisation testing: how the industry reached the holy grail Dr Carol Treasure is Co-Founder and Managing Director of animal-free testing laboratory XCellR8.
For a long time, sensitisation was considered the elusive “holy grail” of regulatory in vitro safety testing. Why? Because sensitisation is usually a much more serious effect than, for example, irritation. While irritation tends to be a short-term, reversible, local reaction in the skin, sensitisation follows a more complex pathway involving an immune response. Once a consumer is sensitised to a particular cleaning chemical or cosmetic ingredient, they will typically be sensitised for life – so it’s an extremely important part of safety assessment.
ARE WE REALLY AT A SCIENTIFIC IMPASSE?
By its very nature, the complex pathway of skin sensitisation was considered notoriously difficult to model in vitro: how could such an intricate, multi-step, physiological pathway be accurately represented in a single test? The critics of in vitro testing would cite this as a perfect example of why animal experiments were needed – a whole animal, they said, could never be replaced effectively. This argument became so entrenched in discussions across the chemical industry that, surprisingly, (and as recently as 2017), it was being stated at industry meetings that we are still stuck at this scientific impasse, and that no in vitro skin sensitisation tests were available. Happily, this is simply not the case.
THREE IN VITRO SKIN SENSITISATION TESTS NOW AVAILABLE Thanks to the significant efforts of multiple scientific groups over the past decade, we now have a portfolio of three in vitro skin sensitisation tests with direct relevance to humans. Together, they model the key events in the sensitisation pathway – and they have been fully adopted at a regulatory level in the form of OECD Test Guidelines.
NEW METHODS FOR POTENCY PREDICTION
It’s so important to highlight that this testing strategy is now available as a regulatory option, while being mindful that, like any approach to safety assessment, limitations must be realistically considered. For example, potency predictions are currently not possible in a regulatory context using in vitro methods, which only address a “yes / no” classification for hazard identification purposes (is the chemical a sensitiser or not?) Efforts are underway to ensure that in vitro methods for potency assessment are available ASAP, and new methods – such as the human genomic screen GARD – are already being validated for potency prediction. Meanwhile, in cases where the in vitro tests have yielded an inconclusive result, or where potency data is specifically required, regulators may insist on the Local Lymph Node Assay (LLNA) as a follow up. The LLNA (TG429) is a mouse-based test in which sensitisers produce a proliferation of lymphocytes (“T cells”) in the lymph nodes of the ear, draining the site of chemical application. It has been widely used for skin sensitisation assessment and has become the “gold standard” against which new in vitro methods have been validated. However, this approach is flawed in the sense that the LLNA itself is not always an accurate predictor of human skin sensitisation potential. So, if the new, human-relevant in vitro test states a different result from the traditional mouse-based method – which one is correct? Traditional animal tests were never validated in the same rigorous fashion as today’s in vitro methodologies. Therefore, does using a flawed system as a benchmark give us a skewed picture? As an industry, we need to come up with better validation approaches that compare directly to human data wherever possible.
THE THREE REGULATORY IN VITRO TESTS FOR SKIN SENSITISATION EXPLAINED
The three tests measure human responses to a chemical at three points in the AOP, described as key events. Direct Peptide Reactivity Assay (DPRA) (OECD Test Guideline 442c) Represents Key Event 1 – the “molecular initiating event” of binding to skin proteins KeratinoSens™ (OECD Test Guideline 442d) Represents Key Event 2 – activation of skin cells (keratinocytes) in the epidermis h-CLAT (OECD Test Guideline 442e) Represents Key Event 3 – activation of the local immune response via dendritic cells in the epidermis For REACH compliance, these in vitro methods must now be used as the default strategy. Current guidance recommends a “2 out of 3” approach, whereby 2 positive results would result in classification of a chemical as a skin sensitiser. XCellR8 have published a guide to in vitro safety testing. To download your free copy, visit https://x-cellr8.com/regulatory-invitro-safety-testing/
z SOLVENTS INDUSTRY ASSOCIATION
The Solvents Industry Association's range of information films drives home the health & safety message
It is almost 12 years since the Solvents Industry Association produced the first of four information films relating to the safe handling of solvents in the workplace. Originally released on DVD and online in 5 different languages (English, French, German, Spanish and Italian), ‘Safe Handling of Solvents’ remains as relevant today as it was when first released in 2006. In association with the European Solvents Industry Group (ESIG) the release of further films in the series, ‘Solvents and Static Electricity’, ‘Solvents and IBCs’ and ‘Safe Loading and Transportation of Solvents’ followed. The films have been developed and produced by members of the SIA Technical Committee, which is made up of representatives from a number of companies within the Association’s
membership with specialist knowledge in the field of solvents. Supported by written Guidance Notes relating to a number of safety aspects affecting the industry, the films offer an overview of safe handling procedures and filling operations, personal protective equipment, transportation and vehicle loading, and procedures to avoid the discharge of static electricity.
The safety films are at the heart of what the SIA is all about. In our view, there is no better way of portraying an important message than by doing so by visual media. In partnership with our colleagues in the European Solvents Industry Group we have distributed more than 10,000 copies of our safety films across Europe and beyond, with much larger numbers of people viewing online.’ Andrew Norman, General Secretary of the Solvents Industry Association
SOLVENTS INDUSTRY ASSOCIATION z
SAFE LOADING AND TRANSPORTATION OF BULK SOLVENTS BY ROAD
The most recent of the SIA and ESIG films, ‘Safe Loading and Transportation of Bulk Solvents by Road’, is designed to support hauliers, drivers and site operators who routinely handle solvents on the move.
SAFE HANDLING OF SOLVENTS
Although solvents are inherently safe when handled correctly, they do possess the potential to present hazards to health, safety and the environment. The short film, ‘Safe Handling of Solvents’ identifies the hazards and outlines best practice required to ensure safe handling. As many solvents are flammable liquids, the principle hazard is of course their ability to ignite and have the potential to cause explosion under certain conditions. However, the film also covers other hazards such as exposure through contact with the skin, ingestion or inhalation, and the effects upon the environment if not handled correctly. The film offers suggestions on simple preventative measures to minimise the risks from these hazards. ‘Safe Handling of Solvents’ is available to view or download via the SIA website, or USB copies are available free of charge from the SIA www.solvents.org.uk/safe-handling-ofsolvents-video
SOLVENTS AND STATIC ELECTRICITY
The film ‘Solvents and Static Electricity’ deals with the sources and potential consequences of solvents coming into contact with static electricity. Static electricity is always present in filling and off-loading processes and the potential for build-up and discharge to spark explosions, fires, and the potential for injury to operators is a constant hazard. The film deals with good operating practice to minimise charge buildup, effective earthing and bonding, technical support available, legislation and codes of practice, with the principal aim to increase awareness among solvent users. 'Solvents and Static Electricity' is also available to view or download via the SIA website www.solvents.org.uk/solvents-staticelectricity-video
The film encourages best practice in the safe transportation and bulk transfer of solvents between vehicles and storage vessels Topics covered in the film include: • The hazards associated with solvents and solvent-based materials • Pre-delivery inspection • Arrival on site and induction • Adherence to site rules and understanding emergency procedures • Using the correct Personal Protective Equipment (PPE) • Safe connection to loading gantries and storage vessels • Communication between site operators and drivers • Safeguards against static discharge and spills • ADR requirements for vehicles and drivers The English version of the film was launched at the SIA Annual General Meeting in October. The French, German, Italian and Spanish versions of the film were also released in March 2018.. This latest film can viewed via the link below; www.solvents.org.uk/sia-releasesnew-transport-safety-film-at-annualgeneral-meeting
SOLVENTS AND IBCS
Due to their convenient method of use and their ability to store greater volumes over a single pallet footprint, Intermediate Bulk Containers (IBCs) have for many users become a preferred choice of container over traditional 205 litre metal drums in the storage and transportation of solvents and solventbased products in packages in recent years. The SIA film ‘Solvents and IBCs’ deals with the hazards associated with the use of IBCs with solvent-based materials, covering the selection of the correct type of IBC for particular solvents, operational and transport legislation, best practice in filling and decanting operations and routine inspection and maintenance. ‘Solvents and IBCs’ was produced by the Solvents Industry Association in 2010, and compliments the supporting publication, SIA Guidance Note GN51 - Selection of IBCs for Handling Hydrocarbon and Oxygenated Solvents. 'Solvents and IBCs' is also available to view or download via the SIA website www.solvents.org.uk/solvents-andibcs-video SIA Guidance Notes, including Guidance Note 51, can also be viewed via the website www.solvents.org.uk/sia-guidancenotes
All of the safety films produced by the SIA and ESIG are available for download free of charge via the above SIA website links, or can be obtained on a free USB memory device. Some of the films are also still available on DVD format if required. To order a free copy containing all of the films in the series, or if you would like to receive further information, please contact Andrew Norman, SIA General Secretary; firstname.lastname@example.org
www.solvents.org.uk/contact-us Established in 1973, the Solvents Industry Association has sought from its inception to support the UK solvents industry and consumers by promoting the safe and responsible use of solvent materials. It currently has 26 members, covering all areas of the solvents industry, including manufacturers, distributors, hauliers, chemical storage companies, packaging manufacturers, electrostatic control manufacturers, solvent recycling and distillers.
The SIA’s mission is to work to ensure that the UK’s regulatory framework relevant to the manufacture, storage, distribution and use of solvents is based on sound science and best practice.
An Outline of the US Regulations for the Import of Chemical Substances Introduction to US regulations The Environmental Protection Agency (EPA) was established in 1970, with the objective to protect human health and the environment. Regulation of both the safety of chemicals and the extent of chemical exposures to humans and the environment is a major aspect of this objective. The Clean Air Act was enacted by the US Congress that same year for the purpose of setting air quality standards. The Agency’s work in regulating the production and importation of chemical substances is authorised under the Toxic Substances Control Act (TSCA) which was originally passed in 1976. In June 2016, President Obama sanctioned its update by ‘The Frank R. Lautenberg Chemical Safety for the 21st Century Act’, which has increased EPA’s authority to implement chemical safety under TSCA. EPA progresses safety in this field by conducting federal research, setting standards, evaluating risks of new and existing chemicals, investigating pollution prevention/ reduction strategies, and writing regulations. These regulations clarify the technical and operational requirements of manufacturers and importers to ensure compliance with TSCA. TSCA defines the term ‘manufacture’ to encompass ‘import’, indicating that importers and manufacturers of chemical substances have the same responsibilities to TSCA. Key duties are outlined below to provide insight for EU industries planning to enter the US market. Pre-Manufacture Notification (PMN) for new chemical substances (TSCA, Section 5) TSCA requires any chemical substance planned to be manufactured/imported for the first time in US, to be notified to EPA. EPA undertakes hazard and exposure assessments to inform any exclusions or exemptions applicable to a chemical substance or its use. The more information submitted, the faster and more accurate the assessment. EPA also encourages manufacturers/importers to meet with them, to discuss specific requirements, before PMN preparation. Significant New Use Rules (SNURs) (TSCA, Section 5) If, following assessment of relevant factors (such as the manufacture process, or duration of human and environmental exposure), EPA concludes that a use of a chemical substance is a ‘significant new use’ (SNU), importers/ manufacturers are required to submit a notice (SNUN) at least 90 days before its manufacture/import. EPA then investigates possible risks which may be associated with the new use. If necessary, it makes appropriate adjustments, for example, prohibitions of use, amendments to labelling and Safety Data Sheet (SDS), restrictions on quantity
manufactured/imported. Such limits are frequently triggers for testing requirements. Testing of chemicals (TSCA, Section 4) EPA may, under the authority of TSCA, request manufacturers/importers to test chemical substances, to investigate toxicity to health or the environment, chemical fate, or characteristics of certain substances. On 7th March 2018 EPA released its draft strategy to reduce animal testing and move to alternative methods and strategies; this is another requirement of the Lautenberg Act. Record-keeping, information provision and inventory update (TSCA, Section 8) The TSCA Inventory is updated with new chemicals following receipt of notice (Notice of Commencement (NOC)). The NOC needs to be submitted by manufacturers/importers, after completion of the PMN, and within 30 days of the first manufacture/import date. This triggers the addition of the new product onto the Inventory as an ‘existing chemical’. TSCA directs manufacturers/importers to maintain records throughout the commercialisation of a product, and report to EPA any information indicative of risk to health or the environment. Certification for import (TSCA, Section 13) Importers of chemical substances into US
are required to confirm that their shipment either complies with, or is not subject to, TSCA. Each import of chemicals subject to TSCA requires the signed statement, ‘I certify that all chemical substances in this shipment comply with all applicable rules or orders under TSCA and that I am not offering a chemical substance for entry in violation of TSCA or any applicable rule or order under TSCA’. EPA expects the importer to have the knowledge and documentation to support the certification and reduce risk of violation. Substances in breach of compliance with TSCA are denied entry into the customs territory of US. Chemicals not subject to TSCA, for example, pesticides, foods, food additives, drugs, cosmetics or devices require signed ‘negative certification’ that ‘…… all chemicals in this shipment are not subject to TSCA’. Certification is not necessary for chemicals that are a part of articles (unless subject to a specific rule under TSCA). Exceptions and specific requirements are applicable to several aspects of TSCA, but are outside the sphere of this general and introductory article. A company intending to access the US market would be advised to discuss their specific product(s) with a US regulatory representative, to ensure precision compliance with TSCA.
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CBA welcomes post-Bre commitment on Chemical Regulation The Chemical Business Association (CBA) welcomes the Prime Minister’s commitment ‘to explore the terms on which the UK could remain part of EU agencies such as those that are critical for the chemicals, medicines and aerospace industries.’ The Prime Minister said that the UK would negotiate ‘associate membership’ of the European Chemicals Agency (ECHA). “CBA and other industry associations have been calling for this type of approach since the referendum, so we welcome this commitment on the part of the UK Government,” said CBA’s Chief Executive, Peter Newport. “The term ‘associate membership’ of ECHA requires further clarity before the industry can begin to make commercial and investment decisions based on a settled regulatory framework,” he added. The CBA has consistently called for continued regulatory equivalence or alignment with the EU – covering REACH, the Biocides Regulations, and Classification, Labelling and Packaging Regulations as well as their related technical support systems. “The industry has already invested many millions of pounds in complying with these regulations which form a central contractual term in commercial agreements for the supply of chemicals to EU markets. Regulatory compliance is the key to market access. Without it there can be no trade,” said Peter Newport.
In her Mansion House speech, the Prime Minister accepted that this would mean abiding by the rules of ECHA and making an appropriate financial contribution. The uncertainty caused by Brexit has already had an impact on the chemical supply chain. Companies are planning and in a number of cases have already taken matters into their own hands to protect the future of their businesses. CBA has provided direct anecdotal evidence that EU distributors and manufacturers are repatriating chemicals to a member state to avoid potential postBrexit regulatory conflict with the UK. In some cases, this involves a substance manufactured in the UK; in others it involves a substance imported into the UK from a third country and exported to the EU. In either case, EU companies understandably wish to ensure continuity of supply. CBA is also aware of examples of member firms establishing new subsidiary companies in EU member states. These firms are not simply creating a ‘post box’ presence, but establishing substantive operations involving investment in premises and employees.
"The industry has already invested many millions of pounds in complying with these regulations which form a central contractual term in commercial agreements for the supply of chemicals to EU markets. Regulatory compliance is the key to market access. Without it there can be no trade."
Turkish REACH(KKDIK) on the path of EU’s 10 years REACH experience Companies are going through a critical period for compliance with EU REACH as the deadline of 1 June 2018 is getting closer and closer. Lead Registrants are rushing to submit registration dossiers on time, and many co-registrants are under pressure as many have already signed SIEF/Consortia Agreements and purchased Letter of Access (LOA) for their substances. Failure to register on time or a rejection from ECHA may cost Lead Registrants and coregistrants incommensurable business loss. Moreover, as Lead Registrants are carrying liabilities towards co-registrants, legal actions may be launched to solve conflicts. Companies planning to submit their registration dossiers to ECHA after March 2018 may need to wait up to 3 months for a registration number assigned to their substance by ECHA. This is a consequence due to high number of submissions expected during the last 2 months before the deadline, and ECHA’s delicate process for checking the full completeness of the submissions. There are several outcomes of these obstacles in the supply chain for downstream users and EU importers. Despite two successful previous registration deadlines and 10 years of REACH&IT experience of ECHA regarding, this last registration deadline and the amount of dossiers predicted to be submitted at the last minute worries the industry. Meanwhile, just like several other “REACHlike” countries, Turkey is also implementing its national chemicals regulation, KKDIK, which is almost a copy paste of REACH. The fact that single registration deadline applies to all chemicals put on the Turkish market regardless of the hazard classification and tonnage band is the major difference of KKDIK compared to EU REACH Regulation.
The registration dossier must be in Turkish submitted via the KKS (Chemicals Registration System), an online system implemented by the Ministry of Environment and Urbanization (MoEU) as a hybrid of REACH-IT and an older version of IUCLID. KKS is being used for CL Notifications by the industry according to the SEA regulation in Turkey since 2015. MoEU is planning to upgrade KKS system content to the latest version of IUCLID before registrations starts. However, considering the overall EU REACH experience, one can worry how MoEU IT system will cope with high number of online submissions taking into account several companies prefer last minute compliance actions in Turkey. The good news is that KKDIK came into effect on 23 December 2017 and companies have already started to join the pre-SIEFs of their substances which means initial preparations for compliance has already started. This should bring to mind that if companies placing chemicals on the Turkish market are planning to work with a local Only Representative to accomplish this tricky piece of compliance work, then the decision has to be taken very carefully. It is highly recommendable for the manufacturers to make a thorough assessment of the capacity, experience and references of the OR they consider to appoint. It is important to keep in mind that KKDIK obligations resulting with Chemical Safety Reports (CSR) to be prepared and signed by a certified expert triggers the necessity that your local OR has a proven experience and a qualified team of experts who can help your company to comply without any hassle.
RGS acts as an OR and Responsible Person (RP) for hundreds of non-EU manufacturers regarding EU REACH and EU Cosmetics Regulations. In addition, RGS-Turkey branch offices are representing numerous manufacturers from all over the world enabling these companies to comply with Turkish chemicals regulations which are in force and gradually brought in line with the EU Regulations for the last 7 years. RGS celebrates 10 years of success and experience with its experts of high qualification. Do not hesitate to contact RGS, if you need compliance with Turkish Chemicals Regulations or more details on our services and the status of your substances. Dr. Yaprak Yuzak Kucukvar RGS Turkey Branch Manager
EUROPEAN UNION • TURKEY • JAPAN • CHINA • KOREA • TAIWAN RGS S.A. - Belgium Head Office + 32 (2) 234 77 77
RGS A.Ş. - Turkey Subsidiary + 90 (212) 454 09 93
REACH obligations post - May 2018 dedicated at the end to chemicals regulatory obligations in the UK post-Brexit.
Dr Marina Fuentes REACHReady Technical Advisor 31 May 2018 will see the end of the last REACH registration deadline. This deadline signifies the expiration of the phase-in period for registering ‘existing’ substances. In other words, it brings an end to the transitional arrangements that allowed companies who pre-registered to continue import and manufacture of substances and register at a later stage. Furthermore, the phase-in period only applies to those substances listed in EINECS and those which were manufactured, imported or placed in the EU market and notified under the Dangerous Substances Directive prior to the entry into force of the REACH regulation in 2006. Therefore, any substances not meeting the phase-in criteria, and those ones which weren’t pre-registered could not benefit from the transitional arrangements mentioned above. These so called non-phase-in substances need to be fully registered before manufacture or import activities begin in the EU in quantities equal or above 1 tonne per calendar year. The same applies to any phasein substances that aren’t registered by the May 2018 deadline. Hence, the REACH 2018 deadline does not mean, by any means, the end of REACH. This article will look into further obligations related to registration, as well as other provisions of REACH, post-May 2018, as these should not be underestimated. A short paragraph is
REGISTRATION OBLIGATIONS OUTSIDE THE 2010, 2013 AND 2018 DEADLINES
Changes of legal entity: mergers, acquisitions, transfer of assets Registration obligations affect business changes such as mergers and acquisitions. Any business change that results in a legal entity change will require updates of existing registrations in order to allow for continuity of manufacturing and importing operations. Even a small acquisition can bring a significant workload as well as costs. Let’s look at the following example where a legal entity is split into two or more entities: Company A merges with company B to form company C. Company C has too much capacity so they must sell part of the assets of company A to gain permission from the EU competition authority. Hence, the former Company A splits into Companies A1, A2 and A3, with A2 and A3 put up for sale. If A1, A2 and A3 make the same substance then there is only one registration and three legal entities needing it: hence A2 and A3 need to submit inquiries to ECHA, after first establishing themselves with a VAT number, a REACH-IT account and IUCLID account. This scenario would cost around €50,000 in new registration fees even though there was already a registration in place. Furthermore, the process would require confirmation of the identity of the substance, which is a resource intensive activity for companies submitting inquiries to the Agency.
Changes in manufacturing processes REACH registrations are specific to a legal entity and limited to a specific tonnage band. Examples of scenarios where additional registration obligations might arise include commercialisation of new products, changes of manufacturing site from one legal entity to another, changes in raw material or raw material supplier, changes in product composition or manufacturing process as well as changes of tonnage band which would lead to higher tier testing being required. Therefore, it’s important for companies to monitor business changes and to allocate the necessary resources so that compliance systems are maintained and the necessary REACH registrations are in place. Beyond registration - Dossier maintenance and evaluation REACH registration dossiers are live documents which need to be updated by registrants when new information emerges. Also, if new hazard information or information that may affect the risk management measures becomes available through and/or following registration, companies need to update all relevant Safety Data Sheets (SDSs), so that customers are made aware and can continue to use the substances safely. Following the latest REACH Review published in March 2018 further measures are expected to be put forward in order to improve the quality of registration dossiers submitted by the companies. Additionally, companies need to check their REACH IT and SIEF mail boxes regularly and be ready to react promptly to any correspondence following registration. The workload is somewhat heavier from companies acting as Lead Registrants as they are required to deal with all enquiries from prospective co-
registrants and in the case of large SIEFs there are significant and unpredictable resource implications.
may therefore face the need to apply for authorisation. Seeking authorisation a time-consuming and expensive process for companies and experience from applications so far suggests an average total cost of €230,000.
Furthermore, registration dossiers could be selected by ECHA for evaluation. ECHA has an on-going screening program targeting specific endpoints for dossier evaluation; therefore dossiers could be selected on more than one occasion. Appropriate level of resources within companies is needed to cope with short response times for commenting and short timelines for testing defined by ECHA. When compliance checks apply to the joint part of the dossier, efforts need to be done by the lead registrant to communicate with the other registrants, get their input and coordinate the response to the Agency. Moreover, substances are subject to an ongoing review program (Community Rolling Action Plan) and therefore they could be selected for evaluation so as to clarify whether their use poses a risk to human health or the environment. Substance evaluation is conducted by Member States and can lead to requirements for additional testing above and beyond the initial requirements of REACH. This usually affects all registrants of the same substance but it is a particular burden on Lead Registrants. Candidate List, Authorisation and Restriction As part of the EU commitment for having all Substances of Very High Concern (SVHC) identified by 2020 (known as the SVHC roadmap), the Candidate List undergoes regular updates, generally in December and June every year. The inclusion of a substance in the Candidate List triggers certain legal obligations related to the communication of information on substances in their own, in mixtures or in articles; and notification requirements for suppliers of articles containing SVHCs. Companies are advised to actively monitor these substances, assess their impacts within products and supply chains and to communicate such issues both internally and externally. Proactive participation needs to be managed within the relevant fora and consortia to defend and support the
Aside from the Candidate and Authorisation lists, substances can be added to Annex XVII also known as the Restriction List. Restrictions may apply to any substance on its own, in a mixture or in an article, and they are normally used to limit or ban the manufacture, placing on the market (including imports) or use of a substance, but can impose any relevant condition, such as requiring technical measures or specific labels. Hence they constitute an important aspect of REACH compliance. Further remarks - Brexit and REACH registration obligations key chemistry and to understand future developments where the chemistry is on the path to further regulatory control. Companies can detect possible regulatory actions on their substances at an early stage by monitoring ECHA’s screening process via ECHA’s dissemination web pages. The screening process identifies substances that have the greatest potential for adverse impacts on human health and the environment, and is separated into an IT screening phase and a manual screening phase, after which the shortlisted substances might be selected for further regulatory action or not. Additionally, when a substance is added to the Candidate List, it becomes a candidate for possible inclusion in the Authorisation List (Annex XIV). Once a substance is added to the Authorisation List, it cannot be placed in the market after a sunset date, unless an authorisation is granted. The REACH Authorisation process, aiming at substitution of SVHCs by safer and more sustainable chemicals, is one the REACH mechanisms that was designed to stimulate eco-innovation. Once we leave the last registration deadline behind us, we may see further efforts in identifying SVHCs and substances for Annex XIV. Companies
Neither the end of the 2018 deadline, nor the UK’s exit from the European Union is expected to put an end to registration obligations for UK-based companies. The European Union (EU) Withdrawal Bill (also called Repeal Bill), which was published in July 2017, is currently being progressed through the UK Parliament and will allow the UK Government to convert EU legislation into UK law once the UK leaves the EU, including EU regulations such as REACH, CLP and the BPR. Therefore, companies are expected to have the same regulatory obligations under UK law immediately after exit as they do now under EU regulations. While there is significant uncertainty as to the future relationship between the UK and the EU, companies should bear in mind that, even in the scenario of a future shift in chemicals policy aiming at divergence from REACH, this would take a long time to be delivered. Furthermore, failure to register substances subject to REACH regulation would constitute a criminal offence under current law. From REACHReady we strongly encourage companies to continue with their registration efforts. Contact us at enquiries@reachready. co.uk if you need guidance and support regarding REACH, CLP or BPR regulations.
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Nigel Perry giving the keynote speech
CPI’s National Formulation Centre opens The Centre for Process Innovation (CPI), part of the UK’s High Value Manufacturing Catapult has opened its new, state-of-the-art National Formulation Centre. Formulation involves the creation of multicomponent, often multi-phase products, which are abundant across markets such as healthcare, food and drink and personal care. For companies developing formulated products, challenges such as up-scaling, advancing technical knowledge and optimising downstream processing can be difficult to overcome and slow down the innovation process. CPI will guide companies through the steps needed to take their next-generation formulated products to market with reduced risk on their decisions or capital investment plans. This unique centre will create an environment for innovation that will allow businesses and academic partners to collaborate to develop, prove and commercialise innovative products and processes in formulation science, and be more efficient in the use of resources to generate further value for the UK formulation industry. The centre is home to world-class laboratories and accompanying expertise focusing on measurement, high-throughput formulation, process chemistry, process technology, complex particles, nanomaterials, composites, and chemistry and dispersions. The new
centre is based at NETPark in County Durham and is funded by the North East Local Enterprise Partnership as part of the North East Growth Deal from the UK Government and the Department for Business, Energy and Industrial Strategy. The National Formulation Centre was first announced by former Chancellor of the Exchequer George Osbourne in 2014, and broke ground in November 2016. Today it was officially opened at a launch event featuring leading industrial specialists in the field of formulation science. In attendance were representatives from global companies including Pfizer, GlaxoSmithKleine (GSK), Procter & Gamble (P&G), Unilever, Croda, BASF and BP, alongside many other formulationsbased organisations. Emma McLeod, Research Principal at Mondelez International, said: “The food and drink sector is the largest remaining manufacturing sector in the UK - it is bigger than the aerospace and automotive industries combined, and contributes over £28.8bn a year to the UK economy. As 97% of companies in the sector are SMEs, the biggest challenge is getting the scale of formulations we need. CPI’s National Formulation Centre is integral to enabling
the cross-sector collaboration and access to facilities required help get future food and drink formulations to scale.” Rebecca Yates, Formulated Products Research Manager for Fuels and Lubricants at BP, said: “The potential to participate in cross-industry solutions for formulated products through CPI enables transformation in finding future practical solutions and ways of working. Bringing together the formulation industry and the applications of formulation products will increase the profile of the industry as a whole. It is exciting that CPI enables collaborations across sectors to drive delivery of projects which result in transferable formulation solutions.” Nigel Perry, Chief Executive Officer of CPI, said: “This new national innovation centre builds on CPI’s substantial capabilities which support the UK’s processes industries and will play an important role in anchoring R&D for formulation and stimulating manufacturingbased growth. It will provide companies and academia with leading technical expertise combined with open access facilities for the development and optimisation of their formulated products across a wide range of applications.”
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