Think your fridge’s mouldy onion can’t become isopropanol?
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| foreword |
Welcome LOOKING TO THE FUTURE… Helen Compson Editor
Editor Helen Compson firstname.lastname@example.org
Design Distinctive Publishing, 3rd Floor, Tru Knit House, 9-11 Carliol Square, Newcastle, NE1 6UF Tel: 0191 580 5990 www.distinctivepublishing.co.uk
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The industry couldn’t be more clear about what it needs from Brexit: continued frictionless access to EU markets, as well as a coherent and affordable UK regulatory regime. It’s a no brainer. The EU is by far the largest trading partner for the UK chemical sector. It is the destination for 60% of the UK’s chemical exports and the source of 70% of the UK’s chemical imports. And the sting in the tail is the fact the testing data needed to produce an effective UK regulatory regime is actually owned by a consortia of European companies. Despite previous assurances to the contrary though, the UK Government has now made it clear that it has no intention of maintaining regulatory alignment with the EU in relation to chemicals, says Peter Newport, chief executive of the Chemical Business Association. So, how are you going to avoid the problems barrelling down the road towards us? In his latest column, Peter enlarges on the advice the CBA is now giving its members. Chris Hughes, principal consultant at the National Chemical Emergency Centre, also shares his thoughts on the state of play regarding REACH.
Distinctive Publishing or BioScience Today cannot be held responsible for any inaccuracies that may occur, individual products or services advertised or late entries. No part of this publication may be reproduced or scanned without prior written permission of the publishers and BioScience Today.
Many companies have their work cut out if they are to move forward, it seems. After a report published in 2018 revealed that only one-third of 3,800 REACH registered dossiers investigated in Germany met the information requirements, the European Chemicals Agency and the European Commission produced a Joint Action Plan to address the problem. Chris takes a look at the key issues we all need to be aware of. As far as Sarah Hickingbottom is concerned, the future isn’t a straight line, it is a circle. Every year, around a third of the food produced across the globe is never eaten. It withers on the vine or it doesn’t make the final cut on the production line or it rots in the kitchen. But imagine what we could do with it if, instead of waste, we saw chemical opportunity? What if, instead of a fast-track to the incinerator, we had a circular economy? In this edition, Sarah explores how today’s waste could be tomorrow’s raw material.
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Think your fridgeâ€™s mouldy onion canâ€™t become isopropanol? Or ethanol? Or acetone? Think again.
18 12 The Chemical Industry must act now to benefit from Smart Instrumentation data for comprehensive diagnostics and monitoring What the industry needs from Brexit
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| contents |
Nearly 90 per cent of field device information remains unused; Chemical Industry must act now to benefit from Smart Instrumentation data for comprehensive diagnostics and monitoring says Ian Elsby, Head of Chemical Industry, Siemens Digital Industries.
brexit Peter Newport, Chief Executive, Chemical Business Association, highlights the industry’s post-Brexit commercial and regulatory priorities.
flow measurement and control Vacuum plays essential role in chemical and pharmaceutical processes.
health and safety The ‘how’ and ‘when’ of risk assessment is widely known and well described, but the ‘so what’ part seems to be applied with much less consistency.
circular economy Food is big business in the UK. Yet globally about 1/3rd of food production is never eaten. Talk about waste. Some of it rots in our fridges but much is lost on the farm or at the food manufacturer.
reach With tighter regulations coming in and compliance under scrutiny, it is time to take a closer look at your REACH dossiers. Chris Hughes, Principal Consultant at the National Chemical Emergency Centre (NCEC), shares his thoughts based on many years’ experience supporting organisations with their REACH regulations.
REACH dossiers – compliance matters
supply chain Order books and sales have bounced back since the last Supply Chain Trends Survey by the Chemical Business Association (CBA) in June 2020.
| contributors biodigestables | |
| CHEMICAL INDUSTRY | CHEMICAL JOURNAL INDUSTRY SUMMER JOURNAL 2018 |
Chief Executive of the Chemical Business Association (CBA)
Operations Director of RAS Ltd
CBA is a not-for-profit business organisation representing the independent chemical supply chain in the UK. Its member companies distribute, pack, and blend over four million tonnes of chemicals each year with a market value of almost three billion euros.
A director of RAS Limited, Carolyn leads a team of risk and hazard management consultants and has been instrumental in creating the company’s assessment methodologies. Carolyn has experience of working with a large number of UK COMAH sites to develop safety reports and provide support in all aspects of risk management.
Peter is a key industry advocate to governmental and regulatory authorities in the UK and Europe. He is also a board member and current Treasurer of the European Association for Chemical Distributors (Fecc) and a board member of the International Chemical Trade Association (ICTA).
Ian Elsby Head of Chemicals, Siemens UK & Ireland
Dr Sarah Hickingbottom CEO, BioVale
With almost 20 years’ experience gained within the process sector & automation business, Ian holds a wealth of chemical industry-specific knowledge. As Head of Chemical Industry, Siemens UK & Ireland, Ian’s current role sees him responsible for liaising directly with the Global Chemical Sector HQ advising on the industry challenges faced by UK manufacturers, OEMs and engineering businesses to ensure Siemens develops value-based solutions and technologies for its clients.
BioVale appointed Dr Sarah Hickingbottom as CEO in 2018. A PhD organic chemist, Sarah has spent over a decade advising the global bioeconomy on the economics of feedstocks, biofuels, oleochemicals and bio-based chemical commercialisation. The ideal background from which to build today’s bioeconomy as it tackles the world’s challenges.
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| news |
Government consults on use of fertilisers to clean up our air Consultation launched on how to cut ammonia emissions from the use of solid urea fertilisers Ammonia pollutants can be toxic to the environment, especially for sensitive habitats Reducing ammonia emissions will also help reduce levels of fine particulate matter – the pollutant of greatest harm to human health The government has launched a consultation seeking views on reducing ammonia emissions from solid urea fertilisers used for growing plants and crops. Ammonia emissions are harmful to natural habitats and our rivers and lakes, as well as to human health, with 87% of the UK’s ammonia emissions coming from farming. The Government has committed to reducing ammonia emissions by 8% of 2005 levels by 2020, and a 16% reduction by 2030. Taking action on solid urea fertilisers has the potential to reduce pollution caused by:
Ammonia reacting with other pollutants – nitrogen oxides and sulphur dioxide – to form particulate matter (PM2.5) which is harmful to cardiovascular and respiratory health. Nitrogen deposited on sensitive habitats such as peat bogs. This leads to excess nitrogen in soils that damages the growth of certain plant species. Nitrogen leaching through the soil and surface run-off which pollutes water courses, causing harm to plants and animals and impacting on water quality.
The consultation presents three cost effective options:
A total ban on solid urea fertilisers
A requirement to restrict the spreading of solid urea fertilisers so they can only be used from 15 January to 31 March
A requirement to stabilise solid urea fertilisers with the addition of a urease inhibitor - a chemical that helps slow the conversion of urea to ammonium
While each of these options will support the Government’s commitment to reducing ammonia emissions, a ban on solid urea fertilisers would achieve around 31% of the ammonia reduction target by 2030. Reducing ammonia emissions will significantly reduce nitrogen deposition to land and in turn help reduce damage
to peat bogs, which are an important carbon sink, thereby helping to tackle climate change. Environment Secretary George Eustice said: “Ammonia emissions from agriculture are causing harm to sensitive and important habitats by making soils more acidic which damages the growth of some plant species, impacting on biodiversity. They are also harmful to human health, and we welcome views on how we can address their use in agriculture so that we can all breathe cleaner air. “Any changes will need to be made in a way that is realistic and achievable for farmers, but which help us to achieve our ambitious targets for better air quality. We are committed to working with farmers to help them do this. “This will build on the comprehensive action we are already taking to tackle air pollution – with emissions of fine particulate matter down by 9% since 2010 and £3.8 billion invested in ensuring our air is the cleanest in decades.” As well as this consultation, the government is also continuing work to tackle ammonia emissions from other agricultural practices through a range of measures including the use of low emission agricultural spreading techniques by 2025, requiring slurry stores to be covered by 2027, and setting standards for new livestock housing. Efforts to reduce ammonia emissions are just one part of the government’s Clean Air Strategy, introduced in January 2019. This sets out an ambitious package of legislation and support that will be needed to meet our ambitious targets on air quality, while the 25 Year Environment Plan commits to restoring 75% of protected habitats to favourable condition. Air pollution has reduced significantly since 2010, with emissions of fine particulate matter - the pollutant of most harm to human health - down by 9%. But tackling ammonia emissions will help to bring the levels of this pollutant down even further, as ammonia reacts with other pollutants to form fine particulate matter. The consultation is open until 26 January 2021.
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Mars turns to plastic Mars, Incorporated has announced plans to incorporate recycled polypropylene plastic into the primary packaging for some of its popular pet food brands by 2021. In collaboration with global packaging supplier, Huhtamaki, Mars has opted for a PP grade from Sabic’s Trucircle portfolio of resins featuring a reduced carbon footprint, as the company strives to reduce virgin plastics use across its packaging portfolio. Among the ambitions set down in its $1billion Sustainable Packaging Plan, Mars aims to use 100% reusable, recyclable or compostable packaging by 2025. For now, the company will use recycled plastic produced through an advanced recycling process for some of its pet food packs. Thanks to this process, the packs will not feel or be different from those made with traditional virgin plastic but will have the added benefits that they include recycled material coming from previously used plastic products. The company has plans to expand to other brands in the next year as it works towards its goal of achieving 30% recycled content and 25% less virgin plastic by 2025 “Through our partnership with Huhtamaki and SABIC, we will test-and-learn, progressively scale up recycled plastic content in our packs, and ultimately help drive circular packaging systems,” said Barry Parkin, Chief Procurement and Sustainability Officer at Mars, Incorporated.
The recycled material is certified under the ISCC PLUS (Institute of Sustainability & Carbon Certification) scheme that uses a “mass balance” approach. This widely recognised international sustainability certification scheme verifies the quality and authenticity of the recycled material along the supply chain from feedstock to final product. According to the company, Sabic’s certified circular products from its Trucircle portfolio offer a carbon footprint reduction of 2kgs of CO2 for every kilogram of polymer produced diverted from incineration. For Huhtamaki, the new flexible packaging structure with recycled food-grade plastic is an ‘important milestone on our journey towards achieving more than 80% of raw materials we use to be either renewable or recycled’, said the company’s president and CEO, Charles Héaulmé. “Our strategic partnership with Mars and SABIC is a great example of how collaboration can result in breakthroughs that deliver significant progress in our journey to designing 100% of our products to be recyclable, compostable or reusable by 2030.”
“Through our partnership with Huhtamaki and SABIC, we will test-and-learn, progressively scale up recycled plastic content in our packs, and ultimately help drive circular packaging systems.” Barry Parkin, Chief Procurement and Sustainability Officer at Mars, Incorporated.
We provide individual and tailor-made vacuum solutions to our customers.
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New study reinforces hygiene credentials of wooden pallets Wooden pallets have inherently better hygiene properties than plastic equivalents, making them a more suitable choice for food, drink and pharmaceutical supply chains, according to new research from the Institute for Wood Technology Dresden. The study, commissioned by EPAL Germany, carried out between February 2018 and December 2019, compared the microbial properties of standard EPAL Euro pallets and H1 plastic pallets.
The tests also proved that with the correct cleaning bacteria and fungi on wooden pallets can be removed effectively – contrary to claims that have been made by plastic pallet producers.
It found that wooden pallets have an antibacterial activity that is more than thirteen times higher than that of the H1 plastics and bacteria had a lower survival rate on the wooden surface compared with plastic. It showed clearly that the rough sections caused by wear on the surface of plastic pallets provide ideal conditions for the growth of bacteria. Meanwhile, the natural antibacterial properties in wood prevent microorganisms from spreading.
The findings of this latest study add to previous research, including the 2016 report by Aviat et al, which reviewed 86 publications to ascertain whether contact between wood and food is safe. This concluded that wood is suitable because its often-rough surface and porous structure often creates conditions that are unfavourable to microorganisms.
The research concluded that wooden pallets are suitable for use in hygiene-sensitive areas – which could include chemicals, food processing and transport. The pallets in the study were sourced from a dealer in the load carrier sector and had all been used at least once. They were not cleaned before testing and were tested according to certified methods using the germs escherichia coli and staphylococcus aureus. The conclusion of the tests stated: “Bacteria on wood do not survive as well as on plastic. It can therefore be assumed that in the critical foodstuffs sector, wooden pallets can be used. However, this does still require – as it does for plastic pallets - strict compliance with hygiene regulations during the production, transport and storage of foodstuffs and continuous monitoring of the pallet quality as well as regular cleaning.”
Other studies carried out on behalf of EPAL include intensive practical trials on its CP pallets at the Dortmundbased Material Flow and Logistics IML packaging lab, the Fraunhofer Institute. The tests demonstrated these pallets’ suitability for use with bagged goods and drums and conformity to complex requirements of the chemical industry for high-quality wooden load carriers. EPAL wooden pallets specifically are kiln dried so they are ISPM15 compliant as standard – and can therefore be used whatever Brexit scenario occurs at the end of this year. Other benefits of using EPAL pallets are that they are safe for loads of up to 1.25 tonnes; the kiln drying gives them extra strength and durability; and they are specified ‘as new’ whenever they are repaired. To see the results of the study, go to: https://www.epalpallets.org/fileadmin/user_upload/ntg_package/images/ Hygienestudy/EPAL_Germany_Hygiene_Study_GB.pdf
MAXIMUM SAFETY FOR TRANSPORTING CHEMICAL PRODUCTS
EPAL CP1-CP9 pallets: strength and security for chemical supply chains. ISPM15-compliant as standard. uk-irl.epal-pallets.org
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Smart Instrumentation Nearly 90 per cent of field device information remains unused; Chemical Industry must act now to benefit from Smart Instrumentation data for comprehensive diagnostics and monitoring says Ian Elsby.
â€œIn the current scenario where industrial plants only use 10 per cent of smart instrumentation data sets, there remains a valuable unused resource. The fact remains that many plants do have capability within their installed base to extract this data but they choose not to use it to its full potential.â€?
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enabling it to move from reactive to condition-based and predictive maintenance. The company, which produces a polymer used in the manufacturing of solar panels, needed additional process insights due to them operating two plants with just 35 employees. It was imperative they stayed ahead of the maintenance curve that could slow down or stop production.
Siemens Digital Industries Head of Chemical Industry
It has been almost four decades since â€˜Smart Instrumentationâ€™ was introduced in chemical plants and the process industry in general. There have been remarkable advancements since then across industries: the internet technology (IT) and operation technology (OT) are converging and AI is making inroads into every field. Smart instrumentation itself has changed dramatically, providing highly valuable intelligent and timely data for operation and safety in production processes. As a result, data generation has increased significantly over the years. However, it is also a fact that up to 90 per cent of field device information remains unused. Plants are therefore challenged to take optimum benefit of this readily available data source with comprehensive diagnostics and monitoring. Some of these steps are: Preventing device failure by monitoring the health of field instruments. Reducing maintenance costs through outcome predictive analytics. Validation of device measurements, with specific insight for process values. Comparison of actual and expected measurement ranges Detection of unauthorised device or configuration changes. Tracking of device replacements and configuration updates over the device lifecycle. All this data can be aggregated, viewed and managed via dashboards within the distributed control system (DCS). In the current scenario where industrial plants only use 10 per cent of smart instrumentation data sets, there remains a valuable unused resource. The fact remains that many plants do have capability within their installed base to extract this data but they choose not to use it to its full potential.
Usually in a plant of this type, the valve manufacturers recommend checking the valves at every 100,000 changes. Since the plant size is small it was difficult for the operational team to assess whether the valves need replacing or repair. Using the valve monitoring app enabled them to pinpoint the exact problem and resolve it. It is now an acknowledged fact that many plants do not fully use the diagnostic data provided by the protocol. This means that the valves are not being routinely maintained according to operating data. In such cases maintenance of the valves is reactive and valves are repaired or replaced only when issues arise. The app was able to extract the data using the interlinked DCS to monitor the process solutions installed in the plant. These AI driven technologies allow users to monitor smart instrumentation to ensure preventive maintenance, service due dates, location and criticality. These technologies empowered the industry with new and effective capabilities. For instance, the client was able to drill down into the valve to see trends and anomalies and add notes for future referencing. Profibus and more so now Profinet communications are helping advance smart instrumentation capabilities even further. Profinet allows users to access added value information of multivariable devices. For example, mass flow, density, temperature, totaliser settings as well as diagnostics, can be delivered over a single cable. The connectivity to the DCS, use of analytics and other technologies have proved that up to 40 per cent savings can be made through reduced commissioning time. The time spent on loop identification, device integration and process-loop tuning can also be reduced by 25 per cent in plants. For now we see some plants and companies are benefitting and operating reasonably well due to reduced production outages and through proactive maintenance. Use of dashboards in a plant to monitor its processes and performance should become second nature to effectively capture diagnostic information.
Vendors are working with clients to rectify this situation. Several projects have been carried out to enable companies to gain more from the extracted data and the results have given the industry tools for generating palpable customer savings.
Smart instruments have the innate ability to monitor their own performance they are primed to capture and measure variable functions they control. While the control systems depend on smart instruments so can the production and maintenance teams to support in preventive maintenance.
An example of this is a project that was delivered using a Valve Monitoring app which was featured in an automation summit in 2019. The app allowed the plant to optimise its valve maintenance procedures,
Finally, the question is, will the chemical and wider process industry adopt these technologies and use these rich data sources to their true potential?
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The Rotronic Universal Monitoring System â€“ RMS
rotronic FP Monitoring environmental conditions in any industry requires a fully integrated continuous monitoring system. The modular Rotronic Monitoring System â€“ RMS is the perfect solution. It provides installation flexibility and full data availability, anywhere, and on a variety of devices. Rotronic can meet all your requirements, incorporating multiple sensors for parameters on a secure network. We can service the entire system. www.rotronic.co.uk/rms ROTRONIC Instruments (UK) Ltd, Crompton Fields, Crawley, West Sussex RH10 9EE T: 01293 571000, firstname.lastname@example.org
A PST Company (www.processsensing.com)
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CLOUD BASED ENVIRONMENTAL MONITORING AT ITS BEST When it comes to the environmental monitoring of laboratories, cleanrooms, production lines and storage facilities, quick and easy access to crucial data is key. Whether they are assets within the pharmaceutical, biotechnology, cosmetic, food industries or R&D facilities the basic prerequisites are the same – the need for a flexible and accessible system that can be completely trusted. And reliability is the cornerstone of the Rotronic Monitoring System (RMS). A modular system of hardware and web-based software, it affords tailor-made solutions - it can either be supplied as a complete package or selected elements integrated with clients’ existing hardware or software. RMS is FDA 21CFR part 11 compliant, GAMP 5 and the software is rated category 4. RMS is arguably one of the most flexible monitoring systems available on the market today, its configuration possibilities range from a small application with a single measurement point to the most comprehensive of systems with hundreds of measurement points. The latest RMS loggers are used to monitor temperature, humidity, CO2, a wide range of other gases and differential pressure. Any parameter devices with an analogue output can be integrated. RMS is suited to many applications, including: Storage monitoring
As such, it provides the building blocks for a simple, unified system light years ahead of the fragmented monitoring approaches so often found in many companies. In contrast to the latter, which can lead to piecemeal monitoring and gaps in data, the Rotronic Monitoring System is extremely reliable and provides alarms when users’ defined limits are breached.
Indoor air quality in buildings, hospitals and work places
Alerts are sent out via email, SMS and recorded message, ensuring staff react to critical events.
Environmental chamber and product stability monitoring
The data they are presented with is clear and immutable, and therefore a reliable record of activity.
Cleanrooms in R&D and production
The system will also dispatch full reports autonomously to the appropriate personnel.
Calibration laboratory monitoring Data integrity is of paramount importance, of course, and loggers have a two to three-year battery life. On battery replacement, any offline data will be automatically backfilled as soon as a connection is re-established. The data transmitted (either wirelessly or via LAN/local area network) is then held very securely, while at the same time being readily available to authorised users, regardless of whether they access it via a PC, Mac, tablet or smartphone. Manufactured by Rotronic AG in Switzerland, the cloud -based monitoring system has been designed, in the company’s own words, to be as “hassle-free” as possible.
At the heart of the system is a cloud-based software managed by Rotronic, thereby ensuring complete data integrity. End users access their particular system via a secure website. The Rotronic Monitoring System is already used by some of the biggest pharmaceutical companies in the world, vouchsafing production lines and storage facilities in which clear and consistent data is critical. The modular design means it can be tailored to fit businesses of any size, big or small. Indeed, the simplicity of the solution can come as a godsend to the smallest of enterprises, helping it to protect its professional standing and hard-won reputation. Now, with its latest pre-configured RMS product bundles, Rotronic has made it even easier still. With what might be described as a solution in a box, the hardware is configured to the client’s needs pre-delivery, so that upon receipt, all they have to do is connect the Rotronic Ethernet gateway to their own network and allow the data loggers to do the rest. For further information about the Rotronic Monitoring System and the different packages available, please contact: email@example.com
The pallet stacked with commercial and environmental benefits.
Proven to increase pallet lifespan by 300+%
Upall: the longer lasting, more efficient, sustainable pallet. Upall pallets reduce downtime and stay in circulation longer, making you more money from your pallet. They deliver substantial cost and time savings by minimising the need for inspections and repairs, also reducing transport and CO2 production at almost all parts of the supply chain.
The results of rigorous independent testing at the world-renowned Virginia Tech and Napier University show that Upall protected pallets have an average lifespan that is more than 300% greater than that of the traditional conventional wooden pallet. The Upall system guards the most frequently damaged areas of the pallet, including blocks and base boards
upallpallets.com UPALL Ltd, Bank Street, Golborne, England WA3 3RN 01942 713 501 | firstname.lastname@example.org
A joint venture with James Jones & Sons Limited
to make them highly resistant to impact. This results in substantially less damage and fewer wood chippings, extending pallet lifespan and improving health and safety in transit, in storage, and on shop floors. They also look good and can be customised with corporate colours and branding.
| environmental health and safety |
| CHEMICAL INDUSTRY JOURNAL |
UK-based Wilson Bio-Chemical opens autoclave waste plant UK-based autoclave waste specialist Wilson Bio-Chemical has opened its micro autoclave fibre production plant for turning municipal solid waste (MSW) into biomass fibre that can be converted into chemicals or fuels. The facility has been developed with the help of the University of York subsidiary, the Biorenewables Development Centre (BDC) and is based at the BDC’s site just outside York. This new technology aims to divert substantial amounts of mixed waste from landfill and produce a range of chemicals and fuels to replace the use of fossil-resource-based products. An estimated 47 million tonnes of municipal solid waste (MSW) is produced in the UK every year, around 40% of which is sent to landfill. Wilson Bio-Chemical has developed and installed a specialised, rotating autoclave which can treat the biological portion of MSW (mainly food waste, garden waste, paper and cardboard) with steam and high pressure and convert it into a sterile fibre (Wilson Fibre). Biorefinery specialists, the BDC, have provided support and expertise in the development of the new production plant, which at full commercial scale can process 150,000 tonnes of waste per year.
EU-FUNDED RESEARCH Wilson is now working with the BDC and with the Centre for Novel Agricultural Products (CNAP) at the University of York on a variety of projects to test the fermentation process as well as the feasibility for use in bioenergy. It is
also collaborating on an EU-funded research project aiming to effectively turn this fibre into biofuel as well as high-value chemicals (e.g. butanol, hydrogen, acetone and ethanol). “The Micro Autoclave Fibre Production Plant is an important step in the continuing development of what we believe is a game-changing technology, diverting unsorted MSW from landfill and producing valuable feedstock from a renewable source for the biofuel and biochemical markets,” said Tom Wilson, managing director and principal engineer of Wilson Bio-Chemical. “We are pleased to be working with Wilson Bio-Chemical on their innovative technology and also pleased that they have chosen to site their new pilot-scale plant at the BDC, in order to benefit from our biorefining expertise and facilities,” said Joe Ross, director of the BDC. The plant was formally opened by Barry Dodd, chair of the York, North York and East Riding Local Enterprise Partnership. The BDC receives funding from the European Regional Development Fund (ERDF) and the Higher Education Funding Council for England (HEFCE). Wilson Bio-Chemical has won a series of competitivelyfunded projects to develop applications for their product, including ERDF funding for the Micro Autoclave; Innovate UK and BESTF funding for the development of the technology.
“The Micro Autoclave Fibre Production Plant is an important step in the continuing development of what we believe is a game-changing technology, diverting unsorted MSW from landfill and producing valuable feedstock from a renewable source for the biofuel and biochemical markets.” Tom Wilson, managing director and principal engineer of Wilson Bio-Chemical.
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DEAL OR NO DEAL – WHAT THE INDUSTRY NEEDS FROM BREXIT Peter Newport, Chief Executive, Chemical Business Association, highlights the industry’s post-Brexit commercial and regulatory priorities.
| brexit |
| CHEMICAL INDUSTRY JOURNAL |
ith the final outcome of Brexit still in the balance, the industry is clear about what it needs from Brexit – continued frictionless access to EU markets as well as a coherent and affordable UK regulatory regime.
Both are crucial for the future growth and profitability of the UK chemical sector and its ability to supply manufacturing and process industries with the key chemical components on which they rely. Let’s look at the issues and why achieving a satisfactory outcome is so important for the UK chemical sector.
EU MARKET ACCESS The EU is by far the largest trading partner for the UK chemical sector. It is the destination for 60% of the UK’s chemical exports and the source of 70% of the UK’s chemical imports. Continued market access and frictionless trade are essential. For almost all worldwide markets, access depends on regulatory compliance. It represents a legislated standard for consumer protection, human safety, and environmental protection. The level of that compliance is set by the authorities in the specific destination market and is non-negotiable. Failure to comply is a barrier to market access. Without market access there can be no trade. If it is to maintain market access, the UK chemical sector has no alternative but to be a ‘rule taker’ – not just from the EU but also from many other jurisdictions around the world. This will remain the case until such time, in the distant future, when regulations are completely harmonised on a global basis. It is unsurprising that, since 2016, in order to maintain access to EU markets, a significant number of UK chemical firms have created subsidiaries in EU member states. Other companies have transferred EU REACH registrations to EU-based companies for the same reason. Similarly, we are aware of European-owned chemical companies repatriating products. Despite previous assurances to the contrary, the UK Government has now made it clear that it has no intention of maintaining regulatory alignment with the EU in relation to chemicals.
Peter Newport, Chief Executive, Chemical Business Association,
CBA has therefore advised its distributor member companies to protect their corporate interests and pursue the following options – before the end of the transition period – to secure continued access to EU markets. Transfer any current EU REACH registrations to an existing, or new, EU27 subsidiary. Establish a partnership with an EU-based company and transfer any current EU REACH registrations to that company. To put the current situation in a real-world context, the chemical sector has integrated and sophisticated supply chains often involving a significant number of substances sourced from worldwide suppliers. These ingredients are frequently subject to different processes undertaken by different companies in different locations before the end product is delivered to the customer. Even then, this intermediate product may only represent one component in the final product delivered to the end customer or placed on the downstream market.
The industry has three key issues with the Government’s new regulatory framework for chemicals in the UK: the availability of testing data to support UK REACH registrations; the fees proposed to fund this process; and the implementation timescale for UK REACH. All three factors are already acting as a disincentive for companies to register substances under the UK’s new regime. 20
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These factors place a premium on regulatory coherence across global chemical markets in order to protect consumers and the environment whilst maintaining high levels of chemical safety – and avoiding exponential increases in the regulatory burden on business. These are the arguments that CBA has consistently deployed to Ministers, officials, and Select Committees of the House of Commons and the House of Lords. We have also pointed to the potential long-term damage to the UK economy resulting from failing to secure continued access to EU markets.
UK REACH - A WORK IN PROGRESS The industry has three key issues with the Government’s new regulatory framework for chemicals in the UK: the availability of testing data to support UK REACH registrations; the fees proposed to fund this process; and the implementation timescale for UK REACH. All three factors are already acting as a disincentive for companies to register substances under the UK’s new regime. The timescale issue has been mitigated by a recent Defra announcement introducing a phased implementation of UK REACH based on tonnage bands. CBA initially proposed this approach some years ago.
THE EU IS BY FAR THE LARGEST TRADING PARTNER FOR THE UK CHEMICAL SECTOR. IT IS THE DESTINATION FOR 60% OF THE UK’S CHEMICAL EXPORTS AND THE SOURCE OF 70% OF THE UK’S CHEMICAL IMPORTS.
However, UK REACH remains a work in progress. Key issues remain unresolved. Solutions must be found before the UK has a workable, cost-effective regulatory regime for chemicals.
The alternative is to impose either unknown data acquisition costs or a major duplicative testing regime on UK REACH registrants with all the associated costs and increased animal testing this implies. Without negotiated access to the ECHA database, the industry estimates that UK REACH will cost an additional £1.2 billion to duplicate existing registrations. A single registration could cost up to €300,000 simply to gain access to the testing data owned by European companies. It is worth noting that the data-sharing rules operating under EU REACH do not extend to UK REACH. The decision to sell, or not to sell, and at what price, is a commercial decision for the data owner(s). The DEFRA fee structure proposed for UK REACH is identical (a simple exchange rate conversion) to that charged by ECHA for access to the whole of the EU market. This is unsustainable on cost-benefit terms given the relative size of the UK market for chemicals which represents around 12% of the size of EU markets. It is a disproportionate and unsustainable cost on an industry emerging from the Covid-19 pandemic and its recessionary impacts. This level of fees plus the potential tariff increases on raw materials post-Brexit will force many companies to review the commercial viability of substances sold into the UK market. CBA believes this represents a serious risk for the UK economy that could weaken its competitiveness, stifle innovation, and retard an economic recovery.
A recent industry-wide survey shows that one in five UK chemical companies plan to move their operations out of the country because of Brexit and the same proportion of non-UK companies are planning to reduce their UK operations. The same survey showed that a significant proportion of UK (7%) and non-UK companies (27%) have already made a decision not to register substances under UK REACH.
This scenario will play out at a time when UK SMEs, making up the majority of the chemical supply chain, are struggling to survive the severe recessionary conditions resulting from the Covid-19 pandemic with depleted financial resources.
Since the proposals for UK REACH were first announced, the chemical sector has expressed its collective concern that its implementation timescale was unrealistic. The extended timescale is therefore welcome but without the data and fee issues also being resolved, it merely delays decisions and adds to business uncertainty.
We also have doubts that the HSE has the experience or competence to assume virtually complete control over the operation of the UK’s new regulatory regime.
The key point is that UK firms do not own the testing data needed to ensure an effective UK regulatory regime. The majority of this data is owned by consortia of European companies. CBA surveys indicate that the figure for non-UK ownership could be as high as 75%. The Letters of Access purchased by UK companies are only valid for EU markets, not for third countries which the UK becomes at the end of transition. We believe that the only pragmatic solution to guarantee the availability of this data is for the Government to negotiate access to the database of the European Chemicals Agency (ECHA). This will help ensure consistent continuing safety, health, and environmental standards, avoid multiple registrations for the same product and the duplication of databases. We have pointed out that a ready-made solution already exists. Article 120 of EU REACH envisages such a co-operative third country relationship with the objective of achieving a wider and improved regulatory framework for chemicals.
The emerging situation will oblige UK downstream users of chemicals to become importers for the first time – a role for which they have no shared history or experience.
This concern is compounded by the fact that, unlike EU REACH, no independent oversight arrangements have been put in place - leaving HSE in the position of being judge and jury in its own court. Industry understands that HSE is in the process of a major recruitment exercise to provide the resources it needs to support UK REACH. Some 600 applications have led to a shortlist of 200 people from which some 150 appointments will be made largely made up of recent graduates. This provides a further reason for industry’s scepticism that HSE will not have the level of experienced regulatory management it requires to oversee UK REACH implementation effectively.
CONCLUSION For the chemical sector and the downstream users of chemicals these issues are both urgent and important. Time is running out. The price of failing to find workable solutions in the last few weeks before the end of the transition period will be paid by companies struggling to emerge from the aftermath of the Covid-19 pandemic. www.chemical.org.uk
BREXIT and (UK) REACH: avoid supply chain disruption! Impact for EU & UK companies using chemicals As a result of BREXIT, the UK officially left the EU on January 31st of this year, leaving us until the end of this year in a transition period (TP). During the TP the majority of EU regulations remain in place in the UK, included the EU ‘REACH’ regulation (EC 1907/2006). After December 31st of this year, EU REACH will no longer apply in the UK; UK companies will be ‘non-EU companies’. Furthermore, there is increasing certainty that the UK government will implement their own regulatory system inside the UK which is essentially a duplicate of REACH. Companies wishing to continue UK business involving chemicals from 2021 onwards will need to comply with this new ‘UK REACH’ system, and only UK established companies (legal entities) will be able to perform this.
Dossier Preparation & Submission
Follow-up On Regulatory Actions
able to fulfill the EU REACH obligations themselves directly. The EU customers will no longer be able to buy from the UK companies until this is addressed. In this situation they urgently need to decide whether to appoint an EU-based Only Representative to represent them inside the EU post-2020, or to support their EU-based customers to be the EU importers of the products / substances. EU companies that are currently exporting to the UK also need to review their options to continue supply after 2021. UK companies that are currently using chemical substances, that originate from other EU states, are ‘downstream users’ under EU REACH. As such, they benefit from their upstream suppliers handling the EU REACH obligations. As of January 1st 2021, the sourcing of substances into the UK will be an ‘import’. At least one actor in the supply chain will need to assume the obligations to ensure that the substances comply with the new UK REACH system. As an initial step in 2021, a notification submission will be required in the UK IT system (by the 27th of October 2021), again followed by a full registration within 2-6 years. Depending on the complexity and importance of the business, there are several options available to deal with this issue. These include, among others, that the UK company assumes the obligations as Importer, or that the EU supplier (or manufacturer) appoints an Only Representative or Importer inside the UK. Careful consideration will be required across all the available options, involving open dialogue between the various actors in the supply chain. From that, to ensure continuation of supply, a decision will need to be made by early 2021, as to by which supply chain actor and through which UK legal entity the compliance will be performed.
Take action NOW! Given the current clarity and certainty towards how companies working within EU REACH will be impacted by BREXIT, and the many imminent deadlines, Apeiron-Team urges all companies doing business across the future UK/EU border to assess their product and substance supply chain and the available options for continued compliance in both the UK and the EU.
Mitigate your risk of supply chain disruption UK Companies that currently manufacture in, or import chemical substances into, the UK will need to quickly comply with the new UK REACH system. The UK HSE will have a new IT system available at the start of next year, through which the necessary initial data submission by means of downstream user notifications can be performed. After that, within 2-6 years, a full registration, analogous to the EU registration, will be required in the UK system. UK companies that currently export chemical substances into the other EU states, and that wish to continue that business from 2021, have no time to lose. In contrast to the UK, there are no transitional measures after 2020 for these companies. Since the UK companies will no longer be inside the EU, they will not be
Apeiron-Team is available to support any company in all aspects associated with this, including for example; substance/supply chain mapping, compliance strategy development, and/or preparation and submissions to necessary agencies. For more information contact our experts: email@example.com
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Due Dili ge nc e
ARY N I L SCIP I D I T MUL
Apeiron drives sustainable chemicals management to create value for business and society Berten Pilstraat 4 2640 Mortsel â€“ Belgium BE 0819.566.460
+32 03 808 20 67 Info@apeiron-team.eu www.apeiron-team.eu
| news |
| CHEMICAL INDUSTRY JOURNAL |
INDUSTRY SEEKS URGENT GOVERNMENT SUPPORT FOLLOWING ‘UNACCEPTABLE’ OFGEM INACTION
Five major North East industrial companies have written to the UK Minister for Business, Energy and Clean Growth warning they may be forced to bypass the national gas transmission system unless amendments are made to “crippling” new charges introduced by Ofgem. The firms – global leader Huntsman Polyurethanes, leading UK fertiliser manufacturer CF Fertilisers, international gases group BOC, global acrylics leader Lucite International and integrated energy provider Sembcorp Energy UK – have told Kwasi Kwarteng the changes will cause “serious damage to key UK manufacturers”. All significant employers in the Tees Valley, where much of Britain’s gas from the North Sea comes ashore, they use of only a tiny fraction of the national network and have enjoyed shorthaul exemptions for the past 20 years. They are predicting that the new charges for transmission will cost them a combined total of £30 million a year, money they say could be spend on improving the efficiency of their own assets.
Philip Aldridge, Chief Executive of NEPIC, the industry body representing the vital chemical-processing sector in the North East of England, led the firms’ appeal to Government. Philip said: “The new charging structure is absolutely crippling to some of the biggest employers in the UK’s leading manufacturing area and risks serious damage to the competitiveness of their businesses and operations, as well as the future of people employed in the hundreds of firms that supply them.” NEPIC argues that Ofgem did not carry out impact assessments on the industries directly affected by the charging changes – and states that the regulator’s “inaction” to stand by its commitment to industry to make swift decisions that would afford the affected companies the time needed to look at mitigation options as “unacceptable”. The letter to Mr Kwarteng states: “As a significant chemical producing region, we ask that you make urgent representations to Ofgem on the introduction of a replacement for short haul to keep affected energy intensive industries on Teesside, and in the UK, on the national gas grid.
DECENTRALISED WATER TREATMENT:
OPTIMISE COOLING TOWER EFFICIENCY WITH WATER CONDITIONING
PREVENT HEALTH RISKS
AVOID RISK OF NON-COMPLIANCE
Trademarks displayed in this material, including but not limited to Grundfos, the Grundfos logo and “be think innovate” are registered trademarks owned by The Grundfos Group. All rights reserved. © 2020 Grundfos Holding A/S, all rights reserved.
INTELLIGENT WATER CONDITIONING AND BLOWDOWN CONTROL Avoiding biological contamination and maintaining proper water quality optimises cooling water’s operational efficiency. Water conditioning for this purpose requires extremely accurate dosing of chemicals. Grundfos iSOLUTIONS offers a smart dosing solution that reliably manages chemicals, surveillance and reporting. The solution combines our DID measuring and control system with our SMART Digital dosing pump technology, our chemical management app and cloud-based monitoring system. Not only does the solution reduce chemical, water and energy consumption but it also eases compliance reporting when required. Read more about the benefits of Grundfos iSOLUTIONS in decentralised water treatment at www.grundfos.co.uk
Introducing Global Consumer Solutions No matter where you are in the world, todayâ€™s fast-paced and competitive landscape requires consistency, reliability, and agility to get to market faster with innovative, leading beauty care nutrition and pharmaceutical products. Customers and suppliers need an experienced and responsive partner who has the capability and reach to provide the latest comprehensive technical, regulatory, and market trend support for both speciality and commodity products across multiple segments. You need a partner who understands your unique business nuances and challenges and is built to drive success in your market. Wherever you are in the world our dedicated industry experts are here to help you. Find out more at UnivarSolutions.com
| flow measurement and control |
| CHEMICAL INDUSTRY JOURNAL |
VACUUM PLAYS ESSENTIAL ROLE IN CHEMICAL AND PHARMACEUTICAL PROCESSES “Intelligent use of vacuum is essential in tackling the challenges of our future.” Vacuum is used to make the most of our surroundings and in many parts of our lives, from the packaging of our food to the treatment of our sewage, from the screens and batteries for our cell phones and computer to the drugs used in saving lives. Vacuum plays an essential role in chemical and pharmaceutical processes. Whether in vacuum conveying, inertization, distilling or drying processes, vacuum is used everywhere to make processes safer, faster and more economical or to make them possible in the first place. By removing air from the installation, explosions and leaks are prevented. In addition, oxidation of the value compound is reduced. For all applications requiring a vaporisation such as drying, evaporation or distillation, operating under vacuum allows to lower the boiling point thus reducing the required sensible heat and the degradation of the compounds. Vacuum is also used in pneumatic conveying (no leaks of chemicals are they are under reduced pressure), filtration and packaging. Vacuum technology has evolved greatly over the last 30 years with the development of dry technologies. Liquid ring vacuum pumps and steam ejectors have
been the robust workhorses for many decades when it comes to generating vacuum. However, like rotary vane vacuum pumps with recirculating oil lubrication, they have one disadvantage: they require an operating fluid that comes into contact with the process gas. The major diference to the vacuum pumps known at that time was that screw vacuum pumps did not require any operating fluid to compress the process gas. This is why they are called “dry” screw vacuum pumps. Dry screw vacuum technology is now also widely used in the chemical and pharmaceutical industries. The dry screw vacuum pumps allow energy and utility saving compared to the well-known liquid ring vacuum pump and the steam ejectors. Moving from a liquid ring vacuum pump to a dry solution allows us to reduce the energy consumption by around 20% on the motor. Replacing steam ejectors allows users to make savings on the energy that would have been consumed to create and condense the steam in addition to reducing the amount of contaminated water. This is non-existent with dry screw vacuum pumps. These savings in terms of energy, utility consumption and waste management are key to develop a greener industry. “Busch provides leading edge vacuum and overpressure technology, from packaging food, sterilizing medical equipment, lifting massive steel tubes to thousands of other applications.” Busch is a solution provider. Our extensive portfolio draws on the widest range of vacuum and overpressure technologies. It allows us to cover the 14 decades of vacuum from rough to ultra-high vacuum. It is now completed by overpressure generation of up to 10 bar(g). To name just a few technologies: rotary vane, claw, screw, liquid ring vacuum technology. And many more.
Vacuum system consisting of several pumps
Based on our experience, the ingredients for the perfect vacuum solution can be summarised in three ways. Vacuum pumps: We shape vacuum. With the widest range of vacuum technologies.
| CHEMICAL INDUSTRY JOURNAL |
| flow measurement and control |
Dry screw vacuum pump for chemical and pharmaceutical processes
acuum systems: We tailor your system. With our vacuum V pumps at the heart. And vacuum service: We help you. With the most extensive global service network. Our goal is to free our customers of unnecessary constraints related to vacuum. Our vacuum experts can offer you stand alone pumps, standard systems, or tailored made solutions to fit your process and requirements. We can support you as early as your first idea of modification or new constructionusing vacuum to the design of the most suited solution, on site commissioning, training of your engineer, operator and maintenance teams. Part of our offer are vacuum audits to identify the opportunities of optimization of your complete vacuum installation. Last but not least, thanks to our extensive global service network, we make sure your solution runs trouble free whenever you need it. “One team around the world: we employ the best people and challenge them.”
Busch Vacuum Solutions was founded in 1963 by Dr.-Ing. Karl and his wife Ayhan Busch and was further expanded together with the second generation, Ayla, Sami and Kaya Busch. The managementof the company is entirely in the hands of the Busch family. With the HUCKEPACK, Dr. Ing. Karl Busch developed the first vacuum pump for food packaging. Busch founded his first overseas company in the UK in 1971. Busch is now represented worldwide with 3,500 employees in 44 countries and 66 own companies. Today, the comprehensive product portfolio includes solutions for vacuum and overpressure applications in all industrial sectors, including the chemical, semiconductor, medical technology, plastics, and food sectors. The founders, their daughter and sons all work in our company every day. www.buschvacuum.com/uk/en/
Busch provides leading edge vacuum and overpressure technology, from packaging food, sterilizing medical equipment, lifting massive steel tubes to thousands of other applications. 29
— Safe, reliable, efficient delivery, for your chemical projects With over 5 decades of experience in the delivery of complex projects within the chemical and refining industry, ABB provides products, solutions and services that enhance the productivity and energy efficiency of a broad range of chemical processes. Our work has covered the smallest batch plant to the world’s largest continuous petrochemical complex Sadara in Saudi Arabia. Whether you need chemical process consultants, batch control, modular systems, automation, electrical or telecommunication experts, ABB will support you and address your needs. Our integrated solutions offer the industry’s best availability, quality, risk reduction and information flow. For further information please visit: abb.com/chemicals
| CHEMICAL INDUSTRY JOURNAL |
| novaflex |
Novaflex – Process Flow Like many organisations in the chemical industry, Novaflex responded quickly to the COVID crisis. After recognising increased uncertainty at the end of 2019, Novaflex had already started to build stocks of hose before the increase in demand for cleaning products and hand gels, then food products, before supporting a variety of oil refinery maintenance projects around the world. When consumers created sudden spikes of product demand, Novaflex supplied hoses to food manufacturers to get their lines up and running. As the hospitality sector began to reopen, brewers and distillers turned to Novaflex hose to restart production. Thankfully, manufacturers across all sectors quickly learned to cope with the uncertainty surrounding COVID itself. Gradually, the focus shifted to the wider economic impact. Novaflex have supported a variety of oil refinery maintenance projects with composite hoses for clearing and cleaning, and the supply of mining and material handling hose to new mineral extraction projects around the world. As autumn and winter approach in the northern hemisphere, Novaflex is busy gearing up for seasonal challenges facing the economy. These include the construction of ‘pumpflex’ hoses for the movement of flood water, and sweeper hoses for leaf and debris collection. The Novaflex Group™ was founded in 1977, and is the largest privately-owned North American designer and manufacturer of hose, duct, connectors, venting, and chimney products.
COMPREHENSIVE RANGE OF HOSE AND FITTINGS Novaflex makes and supplies a wide range of rubber, extruded thermoplastic, and marine hose products in their North American facilities and supplies them around the world through the UK facility. Products cover the complete range of material handling, air, chemical, petroleum, food grade, material handling, mining, steam and water, sweeper and vacuum hoses, as well as a wide range of expansion joints, fittings and connectors. The UK factory manufactures, distributes and holds hose stock for customers around the rest of the world.
hoses, expansion joints and connectors with custom end configurations from built-in lined flanges to beaded ends. Hoses are manufactured to a variety of standards including FDA, 3A, USDA, and REACH.
EXTRUDED THERMOPLASTIC DUCTING Extruded thermoplastic duct and hose products manufactured for use in material handling, clean room environments, fume control, welding, exhaust, agriculture, cable conduit and custom OEM applications. Novaflex ducting has been designed to offer superior flexibility; high temperature, chemical resistance and abrasion resistance using advanced plastics technology. Extruded Thermoplastic Ducting
MARINE HOSE PRODUCTS Marine hose products for ship-to-shore transfer, ship-toship transfer, wellhead material supply, rig gas exchange, ship manifold exchange and marine refueling, and are constructed to marine service specifications in accordance with I.M.O., U.S. Coast Guard and ABYC Regulations.
COMPOSITE HOSE Factories in the UK and North America produce flexible, lightweight composite hose for liquid transfer. Composite hoses offer resistance to a wide variety of chemicals and aggressive media and are available in a complete range of advanced films and fabrics to meet a variety of applications. All composite hoses are manufactured and tested to meet customer specifications for standard and special chemical, petroleum, oil, water, and for vapour recovery, and are available in a wide variety of externally crimped dry seal fittings. Composite hoses are manufactured to different British, European and International standards, including BS EN 13765, BS 5842, and BS 3492, depending on their application, and are designed to fit a comprehensive range of stems, seals, and fittings, to provide safe and reliable performance in application.
Marine Hose Products
HOSE FITTINGS Novaflex offer a wide range of hose fittings tailor made to fit perfectly with our own range of hoses, and for a range of applications from simple ASA150s to specialist HDC Hiflow dry release couplings conforming to the dimensional requirements of STANAG 3756PHE.
TECHNICAL SUPPORT AND ADVICE Whatever the application, Novaflex provide technical support and advice to help users specify the right product for the right application. Behind the scenes, research and development is backed by investment to ensure Novaflex products continue to meet evolving customer demands.
RUBBER HOSES All products are available in a complete range of tube compounds, including EPDM, UHMWP, Teflon, Nitrile, and Viton (amongst others), for added resistance to abrasion, heat and corrosive conditions, and in a wide variety of diameters. The Novaflex range includes material handling, petroleum, food grade, chemical and mining
| health and safety |
| CHEMICAL INDUSTRY JOURNAL |
Confusion over Risk Criteria The ‘how’ and ‘when’ of risk assessment is widely known and well described, but the ‘so what’ part seems to be applied with much less consistency. To determine if the level of risk is acceptable or where additional control measures should be implemented, some sort of criteria is used, often embedded in a risk matrix. Where do those boundaries come from though? And how often do we step back and consider if they are appropriate? These might sound like odd questions, but when you consider that a lot hinges on these seemingly simple things, they are quite important. Risk criteria are used in all sorts of ways, but ultimately they inform the amount of effort we put into analysis and the amount of resource we expend on risk management, so there is a lot of weight put on them. They are the lynch pin of risk management, yet so often we find that their origins are long forgotten. Quite often we find that a single set of criteria is being used for a whole myriad of situations, perhaps not helped by the loss of original intentions. Certainly, if you don’t know where they came from, you won’t be in a position to defend their use as appropriate for your assessment. There are many types of assessment, and depending on the type of risk being calculated, we need to be sure that we are comparing the result to appropriate criteria, or we won’t be comparing apples and apples. This could undermine our whole risk management decision making process. The most widely talked about risk criteria is the Tolerability of Risk ‘TOR carrot’ from R2P2. This defines criteria for Individual Risk. However, Individual Risk is probably not the type of risk you have calculated. Especially if you have: Risk ranked an event in a HAZOP Estimated the risk of a scenario in a LOPA Focused on the risk from a specific piece of equipment Used a risk matrix In fact, only if you have understood all of the hazards impacting an individual, will you have calculated individual Risk. It is quite likely that you have calculated a form of
Individual Risk Hazard(s) One person exposed to multiple hazards
Scenario Risk Hazard(s)
Many people exposed to one or more hazards
societal risk or group risk, for ease of communication we will call it ‘Scenario Risk’. The concept of Individual Risk versus Scenario Risk is illustrated in the diagram above. Scenario Risk cannot be compared to Individual Risk tolerability criteria, and tolerability criteria for Scenario Risk cannot be derived from the Individual Risk criteria. For these reasons it is incorrect to look at a risk matrix or LOPA target and expect to see the one fatality box align with the tolerability limits shown in R2P2 for Individual Risk. Yet so often this is what even experienced practitioners and the regulator trip up over. If we want to use our Scenario Risk as calculated: We must define our scenario risk criteria We must ensure it is calibrated to account for other events on the site If we want to use Individual Risk criteria: We must adjust our Scenario Risk to account for the number of individuals ‘sharing’ the risk We must adjust our criteria to account for other events that may impact that individual Either route is acceptable, so long as we know what we have done and why.
There are many types of assessment, and depending on the type of risk being calculated, we need to be sure that we are comparing the result to appropriate criteria, or we won’t be comparing apples and apples. This could undermine our whole risk management decision making process.
If we are using corporate criteria that we have been handed, we need to understand how these adjustments have been made in order to match the correct criteria to the correct situation. We need to be confident in our criteria. It is important that we challenge the status quo, and truly understand. There is so much that hinges on it Carolyn Nicholls firstname.lastname@example.org
RAS RISK & HAZARD MANAGEMENT
“No problem can stand the assault of sustained thinking.” Voltaire
Safety Risk Our safety risk assessment and management expertise covers risk identification techniques such as HAZIDs and HAZOP, predictive modelling advice and the facilitation of risk management techniques, particularly in the demonstration of ‘ALARP’. The area of Control of Major Accident Hazards (COMAH) is a particular specialism within the company. We support over 70 of the Upper Tier and Lower Tier sites in the UK, and have developed the Pre Construction Safety Reports for the majority of the new large industrial developments in the UK over the last 10 years. We have the full range of expertise to develop Safety Reports for new developments or revisions for existing sites. We also provide training and development in process safety and COMAH, which is tailored to suit individual organisations’ needs.
+44 (0) 1244 674 612 • email@example.com • www.ras.ltd.uk
consulting Safety Sustainability Profitability
Supporting sustainably safe and profitable operations. Most would agree that good business performance is linked to good operational and process safety performance, built on sound practices and procedures. At HFL Consulting, we provide a unique blend of leadership, management, consulting, engineering and training services, that makes us the natural partner of choice for many of the UKâ€™s most prominent chemical manufacturing and chemical using companies. Find out more about how we can help improve your performance. T 0161 304 5902 E firstname.lastname@example.org W hflconsulting.uk
People Plant Process Productivity HFL Consulting is now part of SLR; a global leader in environmental and advisory solutions. Together, we provide world-class solutions and advice to our clients.
| CHEMICAL INDUSTRY JOURNAL |
| news |
ABB to deliver 10 million euros of production improvements MOL Group and ABB embark on a threeyear collaborative project to transform Asset Integrity Management (AIM) across four key chemical and refinery sites in Europe. ABB has been awarded the contract to improve asset integrity across MOL’s downstream assets, through changing mindset, standardizing processes and software and ensuring integrity management is focused on the right equipment. The project spanning MOL DS Production plants in Hungary, Slovakia, and Croatia, will implement standardized asset integrity procedures in a move to drive production efficiency, improve safety and reduce risk. Leveraging technology and process data, ABB together with Metegrity Visions, will integrate a common digital platform at the Danube, Slovnaft, MOL Petrochemicals plants and INA chemical unit. The new solution, with the adoption of improved integrity management processes being rolled out by ABB will provide advanced risk analysis of assets with a key aim of reducing unplanned outages and lowering maintenance costs. It is estimated that by controlling all its static equipment though the Asset Integrity Management (AIM) procedures, processes and systems, MOL will increase availability and reduce turnaround duration (TAR) leading to savings and production improvements of approximately 10 million euros a year across MOL’s downstream assets.
“Asset safety and reliability have the highest priority in MOL Downstream production. To ensure continuous value creation and focusing on the safety of our colleagues and communities around us, we are fully committed to executing and supporting group-level programs such as AIM. We have full trust in the professionalism and expertise of ABB’s technical delivery team, as well as on our own colleagues commitment to the successful delivery of the project,” said Zsolt Huff, SVP Downstream, Production, MOL Group. Zied Ouertani, Global Technology Manager for Chemicals & Refining, ABB Energy Industries said: “The adoption of AIM will increase efficiency and transparency, identifying the critical assets and focusing inspection and remediation of risk with respect to safety and production. This will enable MOL to base asset integrity investment decisions on the equipment’s current condition, and to make the switch from reactive to proactive maintenance.” The new project builds on a longstanding collaboration between MOL Group and ABB. The ABB team has worked closely with the MOL team over the past two years to develop a business case and ensure it could deliver the right solution. The company will provide a bespoke team to deliver the project across three distinct phases with a key objective of transferring knowledge, upskilling MOL’s employees to use the software with a view to self-sufficiency by 2023.
“The adoption of AIM will increase efficiency and transparency, identifying the critical assets and focusing inspection and remediation of risk with respect to safety and production.” Zied Ouertani, Global Technology Manager for Chemicals & Refining, ABB Energy Industries
| circular economy |
| CHEMICAL INDUSTRY JOURNAL |
| circular economy |
| CHEMICAL INDUSTRY JOURNAL |
Think your fridge’s mouldy onion can’t become isopropanol? Or ethanol? Or acetone? Think again. Dr Sarah Hickingbottom CEO, BioVale
Food is big business in the UK. Yet globally about 1/3rd of food production is never eaten. Talk about waste. Some of it rots in our fridges but much is lost on the farm or at the food manufacturer. Imagine what we could do if instead of waste, we saw chemical opportunity? Instead of straight lines with landfill and incinerators, we saw circles. A Circular Economy. The UK and world’s chemicals industry achieving net-zero and minimising the use of virgin raw materials. We may think we’re being future-thinking, but for centuries people have said (to paraphrase) “today’s waste is tomorrow’s raw material”. In fact, soap was first produced at industrial scales to make money from waste vegetable oils and animal fats. An industry which morphed into today’s oleochemical sector supplying the chemicals industry with millions of tonnes of fatty acids, fatty alcohols, glycerine and biofuels. Even today virgin, agricultural oleochemical raw materials are supplemented with used cooking oil, waste animal fats and the fractions of vegetable oil rejected by the food industry for their undesirable technical properties.
– are working in Yorkshire to capture carbon dioxide; to convert the captured carbon dioxide into animal feed; to remove colour from plastics to facilitate their recycling; to convert difficult to handle MSW into usable fermentable pellets; to take potato peelings and manufacture polymers. Those are a few examples and our Anaerobic Digestion (AD) ambition is not yet sated as we consider opportunities to use AD beyond generation of gas for power industrially, but to see it as a technology to produce any number of chemicals from a biomethane platform. The possibilities created by technologies being developed seem to be endless, such as LanzaTech’s use of waste industrial gases for fermentation to produce platform chemicals from otherwise unusable sources. Or the chemical engineering being pioneered to convert difficult to handle MSW into syngas suitable for fermentation into fuels or chemicals, such as that of the University of Birmingham and their FletJet project which recently was selected from over 300 bioeconomy projects across the EU as having the ‘most potential for commercial scale’. Emerging opportunities include the large-scale recycling of plastics; incorporating circular principles and biotechnology with the chemicals industry; renewable energy; and green hydrogen supply chains. Arguably, to optimise the value of our waste-streams, the renewable energy sector should enable us to use renewables to supply our energy, heat and power demands whilst reserving waste-streams for the production of ‘stuff’ i.e. chemicals, plastics and other materials.
Indeed, while we’re talking waste, it’s useful to highlight that waste-as-a-feedstock includes waste from a myriad of sources, such as agricultural production, water treatment, textiles/fashion, plastics, industrial gases, municipal solid waste (known as MSW which is household waste) as well as industrial processes.
There are challenges and risks but first let’s take a moment to recognise the strength of the possibility as the chemicals industry enters a new age. The age of chemurgy (an old word, all but forgotten now, but the technical name for the branch of chemistry focused on converting agricultural products into chemicals). At BioVale, we’re working with the scientists, agriculturists, chemists and entrepreneurs creating the technologies and businesses best placed to realise these possibilities. For example, BioVale’s Significant Interest Group in Anaerobic Digestion, regularly brings together scientific research, industry and farmers to swap best practice, share ambition and work to increase productivity, including downstream chemicals. And our sister organisation – the Biorenewables Development Centre (BDC) – is an openaccess, scale-up centre with the equipment and experts needed to make using waste as a feedstock possible. The BDC has proven the concept of using pasta-cooking water to produce anti-fungal drugs; bread waste to produce antibiotics; and even ice-cream by-products to produce bioethanol.
What can be done with these waste-streams? Combined with chemistry, biology and engineering, the development of the industrial biotechnology toolkit means, broadly, we are constrained only by our imaginations. For example, businesses – multinational, national, small and start-ups
Now we need to work together to develop these concepts into industrial best practice. Interested? Get in touch at www.biovale.org, or better yet, work with us to build a circular chemicals industry with net-zero and sustainability as core drivers.
Whilst our first step should always be to eliminate the production of waste wherever and whenever possible, the second step is to view waste as a feedstock. It is not a problem to dispose of, but an asset to exploit. But despite such opportunity, we still live a world full of waste. If we want to feed everyone affordably, tackle climate emergency, achieve net-zero and face water/ resource challenges head-on, we must maximise the value we extract from our precious land. And that includes making chemicals, materials or even pharmaceuticals from food waste and thereby minimising the use of virgin petrochemicals (or virgin biobased feedstocks).
| dachser |
| CHEMICAL INDUSTRY JOURNAL |
A strong partnership is crucial for safe chemical transport Dachser is one of Europe’s largest specialist logistics providers to have developed a bespoke industry solution specifically designed for the chemical industry - Dachser Chem-Logistics. During the entire Covid-19 crisis, Dachser has remained fully operational throughout its network and has been supporting the NHS with transportation of vital supplies, including chemicals, pharmaceuticals and medical equipment. With decades of experience in handling dangerous goods, each year almost 15,000 employees are trained across its network in the safe movement of chemicals. Dachser has the capability to transport sensitive goods reliably, quickly and flexibly throughout Europe. Utilising its extensive European road network, Dachser manages the chemical product’s complete supply chain from procurement via interim storage, packaging and handling to final distribution. This approach optimises the logistics balance sheets of chemical manufacturers, providing them with a partnership which grants them a competitive advantage when it comes to pricing their products. Dachser operates from four key locations in the UK, at Northampton, Dartford, Bristol and its newest investment in Rochdale. Becoming fully operational in October 2019, the Rochdale facility is on a 3.7 hectares (9.2 acres) site and represents a £14.4 million investment by the company; evidence of Dachser’s commitment to the UK market. In particular, it strengthens the company’s presence in the northern UK region and will further improve its transport
CHEMUK 2021 Dachser UK will be exhibiting at the UK Chemical Industries Supply Chain Expo which will take place on 12-13 May 2021 at a new location, NEC Birmingham. A team of specialists will be available on the Dachser stand (J45) to welcome new and existing clients. www.chemicalukexpo.com
and distribution services in one of the British industry’s heartlands. It has helped the operator solidify its working partnership with many of the UK Northwest’s chemical exporters. Key to these partnerships is Dachser’s standardised data processing, which enables exporters and importers alike to access real-time status information, allowing the tracking of both progress and condition of valuable and sensitive shipments throughout the supply chain. www.dachser.co.uk
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| reach |
| CHEMICAL INDUSTRY JOURNAL |
REACH dossiers – compliance matters With tighter regulations coming in and compliance under scrutiny, it is time to take a closer look at your REACH dossiers. Chris Hughes, Principal Consultant at the National Chemical Emergency Centre (NCEC), shares his thoughts based on many years’ experience supporting organisations with their REACH regulations. REACH requires the manufacturers or importers of substances to submit a dossier documenting the identity and properties of a substance, and how it is used safely. It is a legal requirement of REACH Article 22 for registrants to maintain compliant dossiers and update them in the light of new relevant information. In 2018, the German Federal Institute for Risk Assessment (BfR) and the German environment Agency (UBA) published a report claiming that only one-third of the approximately 3,800 REACH registered dossiers that were investigated met the information requirements. The remaining two-thirds were split 50/50 between those that were non-compliant and those where more investigation was required to confirm compliance. The European Chemicals Agency (ECHA) and the European Commission (EC) have since created a Joint Action Plan
to address the lack of compliance with the information requirements in dossiers. Industry associations, such as the European Chemicals Industry Council (Cefic) and Eurometaux, have also launched initiatives to promote the improvement of dossier quality among their members. ECHA conducts automated and manual completeness checks on both new and updated dossiers. International Uniform ChemicaL Information Database (IUCLID) software is used when submitting information to ECHA and using the automated ‘Validation Assistant’ plug-in is useful to show if your dossier is technically complete. However, it does not include aspects of ECHA’s manual checks. The manual checks cover aspects such as substance identification, justification for waiving standard information requirements, testing proposals on vertebrate animals, chemical safety reports (or justification for waiving these) and specific requirements for nanoforms.
| reach |
| CHEMICAL INDUSTRY JOURNAL |
A complete dossier is essential, but it is also vital to ensure that your dossiers are compliant with the information requirements, including scientifically robust justification of any adaptations from the test endpoints used. This extends to checking if new evidence relating to your substance(s) or new guidance recommended by ECHA has been published since submitting your dossier. Particular issues to be aware of include:
UVCBs Around 20% of registered substances are known as substances of unknown or variable composition, complex reaction products or of biological materials (UVCBs). These complex substances are particularly challenging to characterise and to assess their hazards and risks, and are a common source of issues when checking the compliance of registration dossiers. Read-across Read-across is an application of the grouping concept, whereby existing data from one or more analogous substances (‘source chemicals’) can be used to fill a data gap for an endpoint of another substance (‘target chemical’). While read-across has been employed extensively in some dossiers, guidance provided by ECHA has evolved, meaning that early justifications may no longer be compliant. QSARs QSAR models are used to predict properties of substances based on their chemical structure. These models can sometimes be used in place experimental data, for example to reduce animal testing. However, they require a robust scientific justifications and many dossiers are lacking this information. Accepted QSAR models are generally not available for complex toxicological endpoints.
It is also important to ensure that test information remains up to date and is appropriate. Using tests not suitable for the substance affects the quality and validity of the data,
which could trigger unnecessary further testing and/or further regulatory risk management. If one or more of the information requirements is deemed to be non-compliant by ECHA, then the registrants will receive decision letters requesting additional information. In April 2020, an amendment to REACH was adopted requiring ECHA to increase the number of checks it carries out from 5% to 20% of dossiers to improve the compliance of REACH registrations. In addition, it has committed to screen all dossiers in the tonnage band of over 100 tonnes/ year by 2023 and for the tonnage bands 1-100 tonnes/year by 2027. REACH Article 22, requires registrants to update their dossiers ‘without delay’ when new and relevant information becomes available. A new implementing regulation has clarified the deadlines for updating different types of information. This regulation imposes legally binding deadlines of between 3 and 12 months to update dossiers, depending on the circumstances and type of information. Failure to comply with these timelines would mean the dossier is non-compliant and could lead to fines or other enforcement action being taken against offenders. A proactive approach to dossier compliance can reduce the risks of unexpected costs and disruption from urgent regulatory demands for data and leads to lower costs of REACH compliance. By conducting a manual review of your dossiers, you can demonstrate that you are complying with the requirements of REACH and with industry standards to update and maintain your registration dossier. By putting the time in now, you can save time, costs and disruption in the long run. For more information and resources about REACH dossier compliance and how to achieve it, please email email@example.com and visit www.the-ncec.com/reachdossiers
| reach |
| CHEMICAL INDUSTRY JOURNAL |
KKDIK PRE-REGISTRATION DEADLINE ON THE DOORSTEP, 31 DECEMBER 2020! EU REACH and CLP regulations are implemented to enable harmonisation of chemicals regulations with the EU in Turkey by Turkish Ministry of Environment and Urbanisation. Turkish Competent Authority, MoEU recently announced that there are only days left for the pre-registration deadline for Turkish REACH-like Regulation, KKDIK to end. MoEU also informed companies that the registration module of the Chemicals Registration System; abbreviated as KKS will be ready and active for any entries for registration purposes as of 31/12/2020. KKS has been under construction managed by the IPA Project (Instrument for Pre-Accession Assistance) co-financed by the European Union and Republic of Turkey that started on 1 November 2019. According to the Transitional Article (2) of KKDIK, substances placed on the Turkish market and meeting the conditions below should be registered during the registration period unless exempted from the obligation to register.
MoEU registration fees will need to be paid. There has been quite a lot of discussions within and outside of Turkey about this duplicate effort needed for the dossier preparation and associated cost for the last few years. Therefore, especially considering the economic conditions the industry is facing in Turkey as a result of the pandemic, MoEU has drafted fees with massive reductions from the initially anticipated numbers which would be identical with the ECHA fee figures but in Turkish currency. The other purpose of the reduced fee structure drafted is to support the companies under the difficult conditions resulting from Covid 19 pandemic. Special reduced fees are defined for SMEs in the Draft List as well. Also, there is a significant cost advantage for companies that will perform joint submission. KKDIK Fee Structure can be accessed from MoEU website.
BECOMING A SIEF MEMBER
The registration period starts on 31/12/2020 and continues until 31/12/2020 regardless of the tonnage band and hazard classification of the substance.
Companies submitting pre-registrations to MoEU’s Chemicals Registration System, KKS, do automatically join the corresponding Substance Information Exchange Forum; MBDF. MBDF enables all potential registrants and data holders to interact and prepare for registration. Manufacturers, importers and Only Representatives have to pre-register and join pre-SIEFs for joint registration of their substances through KKS of MoEU. Companies joining the pre-SIEF can reach potential co-registrant’ contact information through KKS. Ministry urges manufacturers, importers and only representatives interested in the registration of the same substance to start communications for data and cost sharing negotiations required for registration.
After the registration deadline 31/12/2023, substances cannot be placed on the market unless registered.
SUBSTANCES PLACED ON THE MARKET AFTER 2020
substances on their own or in mixtures and articles under certain conditions manufactured or imported before 31/12/2023 and substances equal to or above 1 tonne/year,
DOSSIER SUBMITTAL FEES The following procedures are subject to payment according to KKDIK: Registration Registration update Non-public access information request Process and Product Orientated R&D (PPORD) notifications Authorisation application Review of Authorisations With only a few days left until the start of registration; a Draft List has been published that includes the fees for registration, registration update, non-public access information request, and process and product orientated R&D (PPORD) notifications. The final list will be published in Ministry of Environment and Urbanization’s circulating capital enterprise unit price list on early 2021. Since the authorisation provisions will enter into force on 31/12/2023, fees for the authorisation process will be determined later.
If a substance which has not been pre-registered within the given deadline, the KKS system will still allow such companies to pre-register before they place the substance on the Turkish market for the very first time after 2020. However, it is strongly recommended to complete the preregistrations until the deadline, 31/12/2020, for effective functioning of the joint registration process and also to be on the safe side if annual substance volume may reach or exceed 1 ton threshold anytime. RGS Group is based in Brussels, Belgium with offices in Istanbul, Turkey. The team of experts within RGS Group transferred years of regulatory experience into practical solutions for non-Turkish companies to comply with Turkish chemicals regulations. Do not hesitate to contact RGS, if you need more details on our services. We can assess your compliance status and build tailor-made solutions for your company. Dr.Yaprak Yüzak Küçükvar REACH Global Services Group Director, Global Regulatory Affairs & Product Stewardship www.reach-gs.eu
Manufacturers in Turkey placing products on the EU/EEA market have already registered their substances according to the obligations of EU REACH Regulation and paid their ECHA fees accordingly. Turkish KKDIK Registrations of the same substances compliant with the EU REACH Regulation, will be submitted to MoEU separately and
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
| supply chain |
| CHEMICAL INDUSTRY JOURNAL |
ORDER BOOKS AND SALES BOUNCE BACK Order books and sales have bounced back since the last Supply Chain Trends Survey by the Chemical Business Association (CBA) in June 2020 and are now showing a positive surveyto-survey swing of more than 50%. Future sales margins, on the other hand, are forecast to fall by more than 25% over the next three months. Peter Newport, CBA’s Chief Executive, said, “This Survey shows the volatility of the current market. CBA’s view of the bounce back is that it is caused by a combination of two factors. Firstly, a return to more or less normal working by most downstream sectors after the full national Covid-19 lock down. Secondly, companies are stock Peter Newport building to prepare for a No Deal exit from the European Union. This Brexit outcome has also resulted in the three-month outlook for sales margins declining by more than 25%.” The CBA’s on-line Trends Survey was conducted during the two weeks from 5-16 October 2020 and is based on responses from 65 member companies – the highest level of responses since these surveys began seven years ago.
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 – positive swing of more than 50% Members are asked if their order books are better, worse, or the same than during the last three months. The October 2020 survey shows a balance of +20% - this represents a positive swing of +53% in the three months since CBA’s last survey (June 2020, -33%). SALES VOLUMES – Current sales rise by more than 50% Respondents compare their current sales volumes with the preceding three months and indicate their expectations for the next three months. Current sales volumes have bounced back into positive territory, showing a balance of +25% which is a swing of +56% since the last survey in June 2020. The outlook for the next three months is subdued but remains positive at +5% (June 2020, +9%). SALES MARGINS – Margins turn negative; future margins fall by 25% Companies compare their current sales margins with the preceding three months and also forecast their trend over the coming three months. Current sales margins have. turned negative at -6%. Future sales margins accelerate this trend and have also turned negative (-32%) a fall of 25% since the last survey in June 2020. EMPLOYMENT – negative trend continues Member companies are asked if their employment levels will be higher, lower, or remain the same over the next three months. In June 2020, for the first time since these surveys began in 2013, member companies reported a negative trend in employment (-8%). This trend has continued with a negative outlook for employment of -11% in the current survey.
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