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#1 Posted : 10 July 2006 11:43:00(UTC)
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Posted By Darren J Fraser Hi all, I would appreciate clarification on the following: We use solvents as part of our process, in the production areas as much as 250 litres at a time, in the lab may only use 5 litres at a time. My question is this : Do we need to carry out a COSHH risk assessment for the solvents in question in respect of each process, or do we only need to carry out for the area of most use, or are we looking at this totally incorrectly. There is much debate within the management team at the moment, with some advocating the former and others advocating the latter. Just to complicate things further, the maintenance department use varies amounts for cleaning machinery as well. Further more the management team do not believe that cleaning materials, bleach, toilet cleaners, soap etc justify a risk assessment, just trying to demonstrate at the moment that they do. Any help in this matter would be appreciated.
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#2 Posted : 10 July 2006 11:55:00(UTC)
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Posted By stephencarey In my opinion because of the large difference in quantities separate RAs are required as the hazards are greater and more likely.
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#3 Posted : 10 July 2006 12:01:00(UTC)
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Posted By Paul Leadbetter Darren COSHH assessments must be process based so , if the same substances are used in different processes, separate R/As will be required. For the cleaning materials, some may not require COSHH assessments (check the MSDSs or other information provided by the manufacturer) but bleaches and toilet cleaners probably will (especially as they may be incompatible). Paul
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#4 Posted : 10 July 2006 12:01:00(UTC)
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Posted By TBC Hi Darren I've dealt with COSHH for many years (since it first raised it's head) and would recommend that you carry out assessments for each operation. Why? Because each operation differs as to the frequency of use, the exposure levels, the precautions that have to be in place, the way it is used and the personnel involved etc. Some people often think that gathering the MSDS sheets is a COSHH system, but it is only the second step the first being an inventory of all the substances on site whether bought in or generated. It can be a huge task and is better shared by those involved - after instruction of course. Oh! cleaning chemicals should be included, but the use of a little dab of correction fluid may be excluded.
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#5 Posted : 10 July 2006 12:04:00(UTC)
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Posted By jackdaw I think the answer is that it doesn't matter if you do one assessment covering the use of solvent, or separate assessments for each process so long as you take into account how the solvent is used throughout your organisation. I think it is important to remember that it isn't just the solvent you are assessing, it is how it is being used that is important. The solvent sitting in a closed container is a hazard - but low risk; the solvent taken out of the bottle poses a higher risk. So I think you need to decide whether you have taken adequate precautions during each of the activties - lab, process, etc, etc.
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#6 Posted : 10 July 2006 12:09:00(UTC)
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Posted By John Webster Not only are you using different quantities, more importantly, what you do with the solvent will most likely differ. You will use different equipment in a different environment and staff training/knowledge will be different (lab techs vs process operatives. No way can you cover both with the same assessment. As for cleaning chemicals - if they carry a hazardous substance(orange) label, they must be risk assessed. If not, then I would determine whether they are to be used in accordance with manufacturers directions for the purpose intended. If they are, then that may be all the assessment that is required. Remember, though, that many household cleaners are intended to be used maybe once a day or less. Use in industry many times a day or as part of a process is an entirely different scenario and must be assessed.
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#7 Posted : 10 July 2006 12:16:00(UTC)
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Posted By Bill Parkinson I have worked for a company where we did either a substance based assessment or a task based assessment depending on the substance. If you are likely to have problems with 5 litres of the stuff then you can do a substance based assessment as you will have the same problems with 250 litres but on a larger scale!! If you don't have problems with 5 litres but you then use it in a certain way or mix it with other things (or elevate the temperature etc.) then you need to do task based assessments. Also don't forget the fact that there is no OES or MEL anymore but we now have the WEL which is a limit not to be exceeded.
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#8 Posted : 10 July 2006 12:17:00(UTC)
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Posted By Steven The difference in volumes and methods of use would suggest that you need to do separate assessments, and yes some bleach/cleaning solutions may need assessments depending on where when and how used but I would say that soap would probably not need an assessment. TBC (anyone) – would you consider the generation of fumes from a recharging forklift battery as needing a COSHH assessment, it hadn’t occurred to me until I had to order a load of distilled water today!! Steve
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#9 Posted : 10 July 2006 12:22:00(UTC)
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Posted By Darren J Fraser I would just like to thank everyone for their comments. I have informed the management team that they will be required to carryout COSHH for each process, needless to say I am not the most popular person around at the moment.........nothing new there then. Once again thanks everyone. Darren
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#10 Posted : 10 July 2006 12:41:00(UTC)
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Posted By TBC Darren - goes with the job - not always Mr Popular. Steve - Yes - as you probably know the fume generated is Hydrogen (flammable) explosive if care is not taken - misuse or accidental ignition has caused batteries to explode. The acid inside is sulphuric and that's why we wear PPE (nitrile gloves, goggles and possibly an apron when topping up etc.
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#11 Posted : 10 July 2006 12:58:00(UTC)
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Posted By paul debney Items that are flammable are not covered by COSHH.
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#12 Posted : 10 July 2006 20:00:00(UTC)
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Posted By TBC http://www.coshh-essenti....uk/assets/live/SR18.pdf When is it COSHH and when is it DSEAR? It's COSHH because it is hazardous to health and it's DSEAR because it's flammable and explosive. It can be both so both apply.
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#13 Posted : 11 July 2006 07:44:00(UTC)
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Posted By paul debney Regulation 5 COSHH (1) Regulations 6 (COSHH Assessment) to 13 shall have effect with a view to protecting persons against a risk to their health, whether immediate or delayed, arising from exposure to substances hazardous to health except- (b) where the substance hazardous to health solely by virtue of its radioactive, explosive or FLAMMABLE properties, or solely because it is at high or low temperature or a high pressure. Guidance contained in the acop states 'In accordance with reg 5(1), COSHH only applies to substances which are hazardous to health. Substances which are capable of producing effects on health as a result of their explosive or flammable properties (an explosion may easily injure a person) are not covered by COSHH..' If a flammable substance is also an asphyxiant then yes COSHH cover. I am merely stating that a substance that is just flammable does not come under COSHH.
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#14 Posted : 11 July 2006 09:02:00(UTC)
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Posted By TBC Great Paul - I think we've clarified that one now.
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#15 Posted : 11 July 2006 09:25:00(UTC)
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Posted By paul debney We got there in the end TBC my friend.
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