Metals Industry Liaison Group update


A new version of WM3 has been published, v.1.2.GB. This update will be reflected in WM3 1.2.GB across England, Wales and Scotland, and WM3 1.1.NI in Northern Ireland.

You will find the update in Appendix B (pg. 87 of the PDF). The reason we have updated Appendix B is to reflect the need to consider a specific form / physical state of a substance if it is included under the CLP Regulations as an entry in the Mandatory Classification List (MCL).

An example of a substance that will be effected by this change is the classification of Titanium Dioxide (TiO2) which has been recently classified as hazardous (carcinogenic – HP7) if inhaled in powder form containing 1 % or more of particles with aerodynamic diameter ≤ 10 μm. This classification came into force on 01st October 2021.

The update has been welcomed by industry via initial communications through CIWM and ESA. To achieve the update we have worked closely with our Chemicals team and HSE colleagues.


You will be aware that in September we published new EALs for twelve substances, which included two new ones for carbon capture and storage following public consultation (Environmental assessment levels (EALs) used in air emissions risk assessments – GOV.UK ( These ‘Phase I’ EALs are now live on the air emissions risk assessment guidance on (Air emissions risk assessment for your environmental permit – GOV.UK (

We have now kicked off ‘Phase II’ which will update the EALs for a further ten substance. Background toxicological work has been conducted by Ian Martin and he is project managing work by Cambridge Environmental Assessment to produce reports and recommendations for the ten substances listed below. I have provided the sectors where emissions of these substances are greatest from recent pollution inventory data in brackets for information:

  • Butadiene (Chemicals, Cement & minerals, Refineries & fuel)
  • Carbon tetrachloride (Water Industry)
  • Chloromethane, also known as methyl chloride (Removed from PI after substance review of 2012, 2009-2011 data showed emissions from Chemicals and Landfill sectors)
  • Copper dust/mist (Metals, EfW, Chemicals, Combustion, Cement & minerals)
  • Dichloromethane (Chemicals)
  • Hydrogen cyanide (Chemicals, Metals)
  • Mercury (Combustion, Cement & minerals, EfW, Metals)
  • Selenium (Combustion, Metals)
  • 1,2,4-Trichlorobenzene (Water Industry)
  • Zinc oxide (Metals, Combustion, Chemicals, Cement & minerals, Refineries & fuel)

The project is scheduled to run until 31/03/2022. We will then hold a public consultation on the new EALs on Citizen Space early in the next financial year. Therefore, at this time we do not know what the final EALs for these substances will be.

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