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Posted By Geoff S Bottomley
I work for a plastic food packing manufacturing company and use a product that cleans rollers and is food approved. It is an American product that does not come with an EU Safety data sheet.
Can it still be used even though it does not comply with EU law (i.e. 16 point MSDS). We have been unable to find a suitable alternative.
Regards Geoff Bottomley
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Posted By Heather Aston
Geoff
I have been in a simialr situtaion with products supplied from Japan or the US. My approach has always been - does the provided MSDS give you sufficient information to understand what the hazards presented by the product or its constituent chemicals are and can you carry out a suitable and sufficient risk assessment under COSHH using the data given?
To do this you muist have some idea of an exposure limit and be able to measure the exposure of your workforce against that criteria. You must also know what PPE protects against it and whether any health surveillance is required.
If you can be confident in those points, then I would continue to use the material. If not then I would not.
Heather
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Posted By Kevin Walker
I would find it hard to believe that an American product does not have an MSDS, considering they are now a very standard item, it may not be exactly the same as a UK one but would contain the same information. You would be best suited to get in contact with the manufacturer first, if not an internet search should easily put you in the right direction.
kevin
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Posted By Jonathan Breeze
Geoff,
I would say yes it still can be used, but you should take more care to find out a lot more information when completing your COSHH Assessment as this is your responsibility.
Perhaps an internet search could be done although be aware of problems with chemical names (see 'Dioctylpthalate' thread).
Maybe you should also take the time to convert their Safety Data Sheet into the EU format as you will probably find all the information is there (you just have to look harder to find it).
Finally contact them & suggest that the provision of the incorrect documentation may be adversely affecting their sales in the EU.
If your relationship is good, they will probably thank you & make the appropriate modifications promptly.
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Posted By Heather Aston
Kevin
I think Geoff meant he had a US standard MSDS which does not have the same numbering format, but as you say contains essentially thet same info although it will not have the CHIP classifications on it in most cases.
In my experience of this, US data sheets tend to be more "extreme" than EU ones, so that if you follow the precautions on the US MSDS you are likely to be well within EU guidelines.
Heather
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Posted By Kevin Walker
Heather
true agree completely. The excessive amount of info on the US sheets sometimes makes interesting reading. I seem to remember that there was going to be an international standard on these things but I don't know if it ever materialised. Of course then there is the problem with inconsistencies with exposure limits and standards. Thankfully at least the transportation stanards are much the same.
Kevin
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Posted By Heather Aston
Kevin
The one that always gets me is that some US states have different rules - Califormia seems to be the worst. So you get a separate statement "Does not contain any substance known to the state of California to be a carcinogen".
I have once had a shipment of a particular chemical, which is absorbed onto amorphous silica to make it less hazardous. In the US, amorphous silica is categorised as a carcinogen - in the UK it's only the crystalline version that is so categorised. Of course the shipment had US labels on by mistake - BIG PROBLEM!
Heather
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Posted By Ron Hunter
Lots of discussion of COSHH, CHIP, MSDS, etc by forum members, however, what about the first question: Is the product a hazardous substance?!!
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Posted By Kate Graham
If it's approved for food use you would tend to think it's not all that dangerous!
A good website for information on chemicals is
http://www.the-ncec.com/cselite/index.html (I think you have to register). It gives the labelling, risk phrases and safety phrases for individual chemicals.
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Posted By Jonathan Breeze
Duh, of course - my stupid!
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Posted By Heather Aston
The substance might not be hazardous if approved for food use, however it might still be dangerous.
I present to you the example of custard powder - not obvious to the uninitiated that a custard powder explsion could destroy a factory is it - in fact it sounds like a bad joke......
With regard to the "is it hazardous?" question - I would have thought you probably need the MSDS to make that decision so it's a circular argument!
Heather
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