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Posted By Darren Alcock
Dear All,
I've received conflicting advice from several different sources (including those product suppliers who produce MSDS themselves) and was hoping somebody could provide a definitive answer regarding which section (2 or 15) to refer to when trying to obtain the relevant risk phrases/hazard warnings for a substance (when carrying out a COSHH Assessment).
I've noticed that many MSDS refer to hazard warnings (toxic, corrosive etc in section 2 but then these don't appear in section 15. I presume this is because section 2 is a list of substances (often in small quantities)that comprise the product but section 15 lists the risk phrases and hazards applicable to the overall 'combined product' Please could anybody confirm?
Further, if this is the case, could somebody also clarify why sometimes a COSHH Assessment will be needed when a product contains a substance with an OEL(identified in section 2) yet there will be no hazard warnings or risk phrases in section 15? Am I missing something or could it be that there are inconsistencies in the preparation of MSDS?
Finally, please could somebody explain why sometimes section 16 carries additional risk phrases etc over what has been included in section 15?
Failing this, does anybody know any guidance detailing
Thanks for your patience!
Darren
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Posted By Darren Alcock
Apologies, I missed the end off my previous post. I'd started to ask whether anybody knew where I could get hold of any guidance that manufacturer's etc would refer to when producing a MSDS?
Regards,
Darren
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Posted By Kate Graham
>section 2 is a list of substances (often in small quantities)that comprise the product but section 15 lists the risk phrases and hazards applicable to the overall 'combined product'
Yes, that is usually the case.
Kate
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Posted By Kate Graham
>a product contains a substance with an OEL(identified in section 2) yet there will be no hazard warnings or risk phrases in section 15?
That's because the concentration of the hazardous component is so low that the hazard class or risk phrase doesn't apply to the preparation as a whole. There are set concentrations for this in CHIP (I used to have a very handy CD that gave them). For example if you have concentrated caustic soda it is classed as corrosive, if it's diluted below a certain level it is only classed as irritant and if it was a trace amount it wouldn't even be irritant.
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Posted By Heather Aston
Darren
Section 15 is the section you want in order to determine the hazards/risks presented by the overall substance and to find out the risk and safety phrases that apply for your COSHH assessment.
To answer your second point - Some of the individual substances mentioned in s2 may be present in such small concentrations that they don't contribute to the overall hazard provided by the substance itself. However the hazard posed by that individual substance (especially if it's toxic or a carcinogen) may have to be mentioned because of the clasification & labelling regs (CHIP Regs). These have slightly different criteria to COSHH.
Section 16 is "other information" and one of the suggested items in the HSE Guidance is the full text of any R & S phrases mentioned anywhere in the MSDS. Thus a phrase used in S2, which doesn't apply to the substance as supplied but may apply to a minor component of the substance would be written out in full in S2.
Finally HSE has published an ACoP on "The compliation of safety data sheets" - L130, which is £7.95 from HSE books. Unless you have to write your own, I wouldn't bother.
Heather
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Posted By Darren Alcock
Dear All,
Many thanks for your helpful replies. Please could I just confirm one other thing.
If those substances listed in section 2 aren't in large enough quantities to be deemed relevant for inclusion in section 15, would it follow that a COSHH assessment wouldn't be needed on a preparation that contained a substance with an OEL if that substance was only a small part of the overall product?
Hope this makes sense!
Regards,
Darren
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Posted By Kate Graham
You *may* still need to assess it depending on how it is used - for example if you are heating the material so that the hazardous component is evaporating into the air in quantities that do pose a significant risk.
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