Posted By R Clark
We are intending to provide an alcohol hand rub to healthcare staff in hospitals as a promotional item. It has a flammable sign on the label, but has been bought from a promotional gifts company who, in turn, have purchased it from the manufacturers. Should it have come with a COSHH data sheet as standard because of the flammable sign? The manufacturing company may be located in the Far East - if they are not able to provide a data sheet (if we need one) does it fall to the promotional gifts company or us to develop one? Any advice would be helpful.

Posted By Adrian Watson
Dear Paul,

This substance may fall within COSHH because of the definition of a hazardous substance, esp (e) below:

"substance hazardous to health" means a substance (including a preparation) -

(a) which is listed in Part I of the approved supply list as dangerous for supply within the meaning of the CHIP Regulations and for which an indication of danger specified for the substance is very toxic, toxic, harmful, corrosive or irritant;

(b) for which the Health and Safety Commission has approved a workplace exposure limit;

(c) which is a biological agent;

(d) which is dust of any kind, except dust which is a substance within paragraph (a) or (b) above, when present at a concentration in air equal to or greater than -

(i) 10 mg/m3, as a time-weighted average over an 8-hour period, of inhalable dust, or

(ii) 4 mg/m3, as a time-weighted average over an 8-hour period, of respirable dust;

(e) which, not being a substance falling within sub-paragraphs (a) to (d), because of its chemical or toxicological properties and the way it is used or is present at the workplace creates a risk to health;

Whether or not a substance needs a Safety Data Sheet is determined by The Chemicals (Hazard Information and Packaging for Supply) Regulations 2002.

The duty to supply a safety data sheet falls on the supplier. 5. - (1) Subject to paragraph (7), the supplier of a dangerous substance or dangerous preparation shall provide the recipient of that dangerous substance or dangerous preparation with a safety data sheet.

"supply" in relation to a substance or preparation means, except in regulation 6, making that substance or preparation available to another person and includes importation of the substance or preparation into Great Britain, and "supplier" shall be construed accordingly.

Therefore your supplier should provide you with the safety data sheet which you should pass on to the final user. If your supplier is the importer, the duty to classify the material falls on them.

Regards Adrian

Posted By Gareth Bryan
Ignoring Paul's less than helpfull input.

You need a data sheet to be able to assess the product. the supplier must provide it. If the supplier is also the importer they must still provide it.

The product is flamable alcohol based, alcohol is a solvent, solvents are known to cause a variety of health problems. You need to know the %age alcohol content as a starting point as well as the type of alcohol.

Posted By John Paul Battye
Message from Ireland.

Our legislation is similar to the UK, so based on Irish and EU Regs, have formed the following opinion:

The importer (promotional gifts company) has a duty to provide an SDS to any professional user (yourselves/hospitals), since they are the ones who are bringing the substance into the EU market.
As the label states that the handrub is "flammable", one would assume that the handrub has been notified and assessed by the appropriate authority, and that an SDS is available.
In short, telephone the importers. If they are of no help, don't do business with them.

IN ADDITION...
As an occupational health advisor (OHA) who has worked in hospitals, I would be a little suspicious of a handrub supplied by a "promotional gift company". If I were an OHA in a hospital that you are proposing to deal with, I would DEFINITELY need to review the SDS to assess the occupational health hazards that the handrub may present to hospital staff.
Alcohol hand rubs tend to be very hard on the skin, and can cause contact dermititis with overuse. There are milder versions on the market (from reputable healthcare firms)with some moisturising properties.
Would advise that you talk to occupational health staff in the hospitals before potentially wasting your time & money.
Hope this helps.

Posted By gham
You will nees a MSDS which should be provided by the supplier OR manufacturer.

If it is flammable you need this information to deterime under what conditions.

The COSHH assessment is required under the COSHH regs so you will need to have the assessment done before you use it, you should be able to do that from the ingredients and cross referencing it with the EH40 to establish the WES's for those ingredients. You may also require a EH64/65 but for the product you are talking about I doubt it.

Remember the COSHH assessment is very different from the data sheet. If you are selling it on you will need the MSDS

Posted By Dave Wilson
No wonder we get a bad nqame, COSHH does NOT I REPEAT DOES NOT APPLY, DSEAR does not apply will this substance blow up and explode when I put it on my hands !!!!!

I can see Jeremy Clarkson having a right laugh at this.

Posted By Adrian Watson
I totally agree with the last response. Recently I was an expert witness in a case where a nurse had dermatitis through using alcogel and hand soaps. The case settled with large amounts of damages being paid by the trust.

COSHH did apply because there was a health risk. The trust was negligent for breach of an absolute duty under the Regulations in not carrying out a risk assessment, not using the most suitable product available, not providing hot water and suitable towels for regular hand cleaning, not providing suitable and sufficient information, instruction and training, and not providing health surveillance!

DSEAR 2002 Reg 5. - (1) Where a dangerous substance is or is liable to be present at the workplace, the employer shall make a suitable and sufficient assessment of the risks to his employees which arise from that substance.

(2) The risk assessment shall include consideration of -

(a) the hazardous properties of the substance;

(b) information on safety provided by the supplier, including information contained in any relevant safety data sheet;

(c) the circumstances of the work including -

(i) the work processes and substances used and their possible interactions;

(ii) the amount of the substance involved;

(iii) where the work will involve more than one dangerous substance, the risk presented by such substances in combination; and

(iv) the arrangements for the safe handling, storage and transport of dangerous substances and of waste containing dangerous substances;

(d) activities, such as maintenance, where there is the potential for a high level of risk;

(e) the effect of measures which have been or will be taken pursuant to these Regulations;

(f) the likelihood that an explosive atmosphere will occur and its persistence;

(g) the likelihood that ignition sources, including electrostatic discharges, will be present and become active and effective;

(h) the scale of the anticipated effects of a fire or an explosion;

(i) any places which are or can be connected via openings to places in which explosive atmospheres may occur; and

(j) such additional safety information as the employer may need in order to complete the risk assessment.

DSEAR is not likely to apply, because with the amounts used and the conditions of use you are unlikely to exceed the LEL. As such an explosive atmosphere cannot exist.

Regards Adrian Watson

Posted By Adrian Watson
Unlikely, you don't get presentation packs in 1000 l IBU's! What is the largest spillage you can get?

Regards Adrian

Posted By MichaelM
"bramds"?

Posted By Paul Leadbetter
Thank you , Rob

Paul

Posted By Kim Sunley
Advice from NHS Estates issued in June 2005 not sure whether it is any help - no mention of COSHH:

In September 2004 the NPSA issued its fourth patient safety alert (Alert 04: Clean hands help save lives) which advised NHS Acute Trusts to implement near patient alcohol based hand rubs by April 2005. NHS Trusts must make these hand rubs available at the point of clinical and patient care ¡V either attached to the bedside or carried by members of staff. The Alert advised local Trusts to undertake a risk assessment to ensure the range of risks were minimised, including fire.

NHS Purchasing and Supply Agency (PASA) has recently provided a new national contract for alcohol based hand rub products. Products on the new contract had varying range of flashpoints, which may lead to confusion in product selection. PASA have therefore undertaken independent tests to assess the flashpoint of each product available on the national contract. All products were subjected to the same test in an effort to ensure consistency. These tests indicate that there is only a marginal difference (1o) between flash points of all the products, and users are therefore advised not to use quoted differences as a factor in the final product selection process.

Some Trusts have expressed their concern regarding the potential fire risk associated with these alcohol-based products. It is therefore considered appropriate to issue this alert to offer additional guidance on the safe storage of alcohol based hand rub products. This alert should be read in conjunction with the Alert previously issued by the National Patient Safety Agency. (www.npsa.nhs.uk/advice).

The NHS PASA contract has five products available. The hand rub containers are available in a range of sizes from 60ml to 1 litre. The smaller containers are generally carried as personal issue by the staff, with the larger containers located on the wards usually attached to the patient¡¦s bed.

During the process leading up to the NHS PASA contract, consideration was given to the potential fire risks. A risk assessment was undertaken with one of the chief recommendations made to minimise risks related to the correct storage of products within hospitals. The risk of fire was considered to be low and not perceived to be significant in relation to the huge benefits in terms of reducing HCAI. Guidance was also sought from the Health and Safety Executive.

Guidance

All alcohol-based products are flammable. However, the potential benefits in terms of reducing avoidable infections amongst patients (HCAI) far outweighs any potential fire risks which can be managed in line with the usual management of flammable materials and products.

All flammable liquids are considered to fall within the scope of the Dangerous Substances and Explosive Atmospheres Regulations 2002. The Approved Code of Practice to accompany the Regulations recommends the maximum amount of flammable liquid in the workplace should be 50 litres. For the purposes of the Regulations, the ¡§workplace¡¨ is regarded as being the ward or department. Quantities of all flammable liquids (including the alcohol based hand rub) in the workplace should not therefore exceed 50 litres.

Reserve stock of alcohol based hand rub (and other flammable liquids) in the workplace should be kept in a lockable metal cupboard.

The hand rub must be kept away from naked flames and ignition sources. Dispensers should not be sited directly above or adjacent to electrical sockets or switches.


Where the hand rub is sited in corridors, and accessible to visitors, the following conditions should be met:

„XThe corridor width should be 2 metres or greater;
„XDispensers should be a minimum of 1.2 metres apart;
The maximum container size should be 1 litre;
„XDispensers should not be located in public areas that are carpeted.

Purchase of alcohol based hand rub via the NHS Logistics route enables wards and departments to carry the minimum stock level. Ideally, implementation of a ward-based materials management approach would further reduce local stock holding levels.

Bulk storage in Pharmacy Departments (or Main Stores) must be in fire resisting cabinets.

Enquiries

Enquiries to NHS Estates should be addressed to :
Paul Roberts
Environmental Safety and Risk Manager
Department of Health
NHS Estates Quarry House (3N34A)
Leeds LS2 7UE
Tel : (0113) 254 6881
Fax : (0113) 254 624 E mail : paul.roberts@dh.gsi.gov.uk

Posted By Richard Mathews
I agree with Paul Leadbetter and Rob T, original question: “Should it have come with a COSHH data sheet as standard because of the flammable sign?” Answer: No. I also agree with most of the others it should have a MSDS, which would inform a general risk assessment, which in turn would identify whether or not a COSHH assessment (or any other specific assessment) would be required.

Richard