Welcome Guest! The IOSH forums are a free resource to both members and non-members. Login or register to use them

Postings made by forum users are personal opinions. IOSH is not responsible for the content or accuracy of any of the information contained in forum postings. Please carefully consider any advice you receive.

Notification

Icon
Error

Options
Go to last post Go to first unread
Admin  
#1 Posted : 15 March 2006 10:51:00(UTC)
Rank: Guest
Admin

Posted By Paul Price Our QC lab uses numerous chemicals in there testing process I have asked them to update thier RAs asthey are about to use eight new chemicals . I have told them to complete a risk assessment for all the chemicals .however the dept manager will only permit them to carry out RAs on two as they are the only ones that have R phrases in section 15 of the MSDS.Comments please.
Admin  
#2 Posted : 15 March 2006 11:18:00(UTC)
Rank: Guest
Admin

Posted By Keith E This is incorrect, just because a substance does not have an R phrase and/or classified as 'Toxic', 'Harmful' etc DOES NOT mean it should be ignored by the CoSHH Regs. There is a 'catch all' requirement under CoSHH Reg 1 - Interpretation In summary 'Substance hazardous to health' means classes listed in CHIP, substrances with WELs, biological agents, dusts of ANY kind 4mg/10mg limits etc and finally 'which, not being a substance falling in tha bove categories, because of its chemical or toxicological properties and the way it is used or is present at the workplace creates a risk to health' See Page 8 of the current CoSHH ACOP
Admin  
#3 Posted : 15 March 2006 11:23:00(UTC)
Rank: Guest
Admin

Posted By gham fine if they are to use the chemical as is (their determining this is in itself is an assessment?) but will a process change the properties of a chemical, e.g. heat, contact with other chemical, contact with catalyst. By assessing the full process the reactivity with other product or environmental factors will highlight any other hazards it would be intersting to know what the chemicals are for a more informed answer
Admin  
#4 Posted : 15 March 2006 11:24:00(UTC)
Rank: Guest
Admin

Posted By Paul Price Thanks Keith you echo what I have told them allready . I had to do RAs for 131 chemicals and 54 processes !!!!!!
Admin  
#5 Posted : 15 March 2006 11:39:00(UTC)
Rank: Guest
Admin

Posted By Keith E You're lucky!! I used to dream of only assessing 131 substances. At the last count my current CoSHH assignment was at 857 substances along with 23 processes, plus warehousing/storage/waste disposal along with and unknown number of mixtures/trials etc...still counting on that one. Luckily managed to group together and reduce the actual number of assessments required down to about 400 assessments. Tell that to the new kids trying to get into h&s and they won't believe you. My manager used to thrash me every day until I understood CoSHH.
Admin  
#6 Posted : 15 March 2006 12:02:00(UTC)
Rank: Guest
Admin

Posted By Dave Wilson Guys what you also have to remember is that all substances supplied for use will have a MSDS but not all fall under the COSHH Regs. If a substance has undergone the CHIP process and it is not classified as an R phrase or any other COSHH Phrase then it will not be a COSSHABLE Item. Do not do paperwork, time and effort if its not required. For instance we use a chemical which is Bio Degradeable and Non hazardous, it has an MSDS but does not fall under COSHH but still get asked for COSHH Sheets!
Admin  
#7 Posted : 15 March 2006 12:09:00(UTC)
Rank: Guest
Admin

Posted By Keith E Hmm, I both disagree/agree with the last comment - as I pointed out earlier just because a substance is not 'CHIP'ed', or a biological agent etc does not mean it should be ignored. You may well quickly conclude there is no health risk because of the circumstances of use etc - just remember the catch all statement with the CoSHH interpretation guidance. I'm all for minimising work/paperwork which is the bain of all our lives, but I would not agree with no assessment being needed. In these cases, I have/would enter on to a CoSHH inventory database, quickly followed by a note saying the substance is not considered to be a health risk in YOUR particular circumstances of use/exposure pattern to employees.
Admin  
#8 Posted : 15 March 2006 12:16:00(UTC)
Rank: Guest
Admin

Posted By Dave Wilson 'If the substance has gone through the chip process......' by implication if it hasn't you then have to! and it may then fall under COSHH or another set of regs (Explosive, Flammable etc) as a result, otherwise it would not be called COSHH but "Any Substance Which you may use even if its not harmful to health needs a Risk Assessment Regulations"
Admin  
#9 Posted : 15 March 2006 12:32:00(UTC)
Rank: Guest
Admin

Posted By gham I agree with Dave You can buy distilled and deionised water for use in many processes would you expect a COSHH assessment for that. G'
Admin  
#10 Posted : 15 March 2006 12:34:00(UTC)
Rank: Guest
Admin

Posted By Keith E Which is effectively what the 'catch all' element of CoSHH does. Clearly if a substance is a brick, piece of timber etc then no reasonable person/inspector would require an assessment... But what if the substance is a dust, liquid and are created by the handling/manufacturing process - how volatile is it? What are the chemical/physical properties of the liquids - boiling point/process temperature - i.e. how easy are vapours/fumes evolved, what are the likely particle sizes if a dust? With out knowing more about you're specific example, obviously hard to comment - my point is that unless blindingly obvious, I don't agree that you can simply say there is no health hazard with out at least doing a 'quick and dirty' assessment of the substance i.e. you have some sort of filtering system in place. Hence why I would log the details in a CoSHH inventory/database, as previously mentioned.
Admin  
#11 Posted : 15 March 2006 12:42:00(UTC)
Rank: Guest
Admin

Posted By gham Keith I agree with that also like i said before some sort of assessment must have been done to come to the conclution that it is safe or a full assessment is not required. Regardless of how safe any chemical is your still not likley to want to ingest, inhale it etc. You have to have a balanced system in place, and again without knowing what the chemicals are and the processes that they are involved in it is not really practical to comment beyond anything more than general terms
Admin  
#12 Posted : 15 March 2006 12:56:00(UTC)
Rank: Guest
Admin

Posted By Dave Wilson If it has already been 'chipped' and is labelled in accordance with this, then COSHH would not apply, we are talking about 'proprietry substances' and as such I would agree with the rest of your comments. Waste chemicals / synergistic effect etc
Admin  
#13 Posted : 15 March 2006 12:58:00(UTC)
Rank: Guest
Admin

Posted By Dave Wilson MSDS sheets are a catch all as the supplier/ manufacturer does not know the environment in which you are going to use the product, to such an extent 99% w/w in case of fire drench with water same as on a bag of peanuts 'warning contains nuts!'
Admin  
#14 Posted : 15 March 2006 13:01:00(UTC)
Rank: Guest
Admin

Posted By Alan Hoskins What about the process Keith? If you cut a brick or timber you get dust... Alan
Admin  
#15 Posted : 15 March 2006 13:19:00(UTC)
Rank: Guest
Admin

Posted By gham alan i think that was the point keith was making in the process they change state becoming harmful if inhaled and in some cases explosive if the dust particls are fine enough and in the right dilution in air They are just sitting there looking all innocent being a brick or a lump of wood then you take a grinder, saw, router, planer to them.......... watch out cause these thing can fight back, they'll get you if your not careful..................
Admin  
#16 Posted : 15 March 2006 13:23:00(UTC)
Rank: Guest
Admin

Posted By Keith E Yes, gham, thats exactly the point I was making. Substances change state, they can become 'CoSHHable' hence why you can't just rely on the MSDS, CHIP assignment etc and the reason for the 'catch all' bit of the CoSHH regs.
Admin  
#17 Posted : 15 March 2006 13:26:00(UTC)
Rank: Guest
Admin

Posted By Dave Wilson quite true mate but if you are using it as it says on the tin! then you don't
Admin  
#18 Posted : 15 March 2006 15:33:00(UTC)
Rank: Guest
Admin

Posted By Diane Thomason Dave W says: "MSDS sheets are a catch all as the supplier/ manufacturer does not know the environment in which you are going to use the product, to such an extent 99% w/w in case of fire drench with water same as on a bag of peanuts 'warning contains nuts!'" Exactly right. Safety data sheets are a statement of the HAZARDS not the RISK. This should always be remembered - the risk assessment is what takes into account the circumstances of use. Agree also that it's counterproductive to "COSHH assess" substances that really are not hazardous under any foreseeable circumstances of use at your workplace. And I agree very strongly that assessments can and should be done for a group of substances, or a process - e.g. a group of chemicals from the same chemical "family", with similar health effects, being used in a similar way. My heart sinks when I see another stack of COSHH forms, each for a single chemical, when 1 assessment would cover the lot. It all contributes to the notion that it's all about filling in forms or "doing COSHH", instead of properly assessing risks. (BTW I am a biological & chemical safety officer. Am on a bit of a hobby horse here.)
Admin  
#19 Posted : 15 March 2006 16:15:00(UTC)
Rank: Guest
Admin

Posted By Adrian Watson Dear Paul, To carry an effective CoSHH risk assessment you need to take into account the following: Agent -- environment -- person You need to find identify: - What hazardous agents are present, in what physical state; - What are the physical, chemical and toxicological properties for each hazardous agent; - How much of the hazardous agent is produced, released and distributed throughout the working environment; - What are the potential routes of entry (inhalation, ingestion and absobtion)into the body; - What is the frequency and duration of exposure to the hazardous substance for each route of entry; - What are the likely health effects for each route of entry having regard to the intensity, duration and frequency of exposure. From this information you can then evaluate the risk of injury or illness occurring and put into place appropriate control measures. Control measures should be proportionate to the degree of risk. The most effective way of identifying control measures is to do a gap analysis for each step. I have found that where the assessor does not do this they invariably accept the status quo rather than elevaluate all options. To do this you should: - identify all potential controls at the source, routes of exposure, and on the individual; - list your existing controls for each of the stages; and - challenge why you cannot put into place the additional measures necessary to prevent or control exposures. MSDSs only contain a small part of the necessary information to evaluate risks; furthermore they have a habit of being unreliable and tend to be either wrong or miss out key facts. I would include them, but do process based risk assessments as this is more efficient and tends to get you to the right results. Regards Adrian Watson
Admin  
#20 Posted : 25 March 2006 11:03:00(UTC)
Rank: Guest
Admin

Posted By Chris Packham In practice you may need to consider all chemicals. In my work, for example, dealing with potential and actual skin problems resulting from the working environment, water frequently occurs as a contributor, if not the main cause of occupational contact dermatitis. (I'm trying to remember when I last saw water on a safety data sheet.) Wet work in many occupations is a real problem and requires risk assessment. How will you know whether you have such a problem if you simply ignore those substances not carrying a risk phras? Had you ignored the substance and then there was a problem, for example a case of irritant contact dermatitis, where would you stand? It is, perhaps, relevant that in Germany this has been recognised. Currently Technical Regulation for Hazardous Substances no. 531 (although this will shortly be replaced by a new document in the pipeline) covers wet work and requires that where exposure to water is for more than 2 hours in any 8 hour shift this represents a hazardous substance and special precautions have to be taken. Remember that the SDS is for CHIP compliance (see HSE L130. Paragraph 13 in the COSHH ACoP draws attention to the fact the data for CHIP, i.e. that in the Approved Supply List, may not be adequate for COSHH.
Admin  
#21 Posted : 25 March 2006 18:24:00(UTC)
Rank: Guest
Admin

Posted By Charley Farley-Trelawney Keith has it about spot-on in my book! CFT
Admin  
#22 Posted : 13 April 2006 17:53:00(UTC)
Rank: Guest
Admin

Posted By kevin_2005 Hello I am stuck with my assignment on cement The assignment brief is "For a workplace of your choice choose one substance hazardous to health which employees may be exposed to whilst at work. Explain the adverse health effects that could result from uncontrolled exposure to the substance. Discuss, using reference to legislative requirements and relevant guidance how a suitable and sufficient assessment of the risk created by that work is undertaken. Review how the risks of exposure to hazadous substance can be either prevented or, where this is not reasonably practicable, adequately controlled to meet the duties imposed by COSHH 2002. Use findings of this review to evaluate the effectiveness of the existing control measures and discuss what further controls are required, supporting this with a cost benefit analysis. would anyone help me please thanks kevin
Users browsing this topic
Guest (2)
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.