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Posted By Jason Leigh Evans
Can anyone offer some advice?
I am the adviser in a FE College and have a problem with the handling of Chemicals in the Photography Department.
The info on the data sheets advises to wear PPE of various types, my question is does this only apply to the undiluted concentrate that is delivered, most of the chemicals are then diluted before use by students, no PPE is being worn. I believe this is the case in most learning environments, can anyone advise me on the law but also any examples of good practise.
Thanks for your help.
Jason
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Posted By Paul Leadbetter
Jason
As some photographic chemicals are sensitisers, you should be providing ppe if contact cannot be avoided. See the recent Photo-Me prosecution; there is an HSE press release at http://www.hse.gov.uk/press/2006/e06098.htm
Paul
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Posted By Jim Walker
Another point: Doesn't the college & lecturer have a duty to demonstrate to students & put in practice (thus reinforcing the training)) best practices, including H&S?
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Posted By Diane Thomason
Absolutely agree with the above posts.
You are right in that the MSDS refers to the chemical in the form it's supplied.
It's your assessment under COSHH that considers the risks and necessary precautions once the stuff is diluted for use. (and also takes into account what they are doing with it, how much they are using and the fact that students are involved i.e. inexperienced people.)
Many moons ago I did COSHH assessments for developer and fixer but I no longer have them. I could get hold of one if you like - for you to use as a base for your assessment.
Personally, as a lot of the components of this stuff are at least irritant, I would not use it without PPE. Not sure if people in "the industry" use PPE but I could find out if you don't get your answer from this thread.
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Posted By Chris Packham
When it comes to diluting chemicals and the resultant "hazards" and "risks" there is a range of factors you will need to consider.
Probably we are concerned here primarily with skin exposure to photographic chemicals. (If you are concerned about respiratory exposure, this is a completely different problem.)
Diluting a chemical may reduce the hazard, but by how much can vary considerably. With one chemical a 50% dilution may reduce the hazard considerably, but with another may actually increase the potential effect of exposure. For example, 2-butoxyethanol will penetrate the skin more rapidly when diluted with water than when neat.
Another consideration, touched on already, is the nature of the hazard. With a sensitizer you may need to dilute to a very considerable degree in order to have any major effect on the hazard. For example, with one chemical I have been dealing with recently, the patch test concentration for testing for an allergic reaction is 0.002%! With another chemical it is 50%.
With irritants it is even more complex. The Malten concept is that irritant contact dermatitis occurs due to repeated exposure over time, usually to a wide range of different irritant chemicals (including water). So considering the effect of just one chemical and its exposure may be completely misleading.
From all of this I hope you will have gathered that there is no simple answer to the question you posed. Even taking the decision to insist on PPE may not represent COSHH compliance. This requires that you control exposure firstly by methods other than PPE, with PPE being a last resort. So just putting all the student into gloves would not put you in the clear.
Isn't life complex? It certainly is when dealing with skin exposure. After 26 years concentrating on this particular aspect of health and safety I am still in a steep learning curve!
Chris
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Posted By Ken Taylor
There is still a tendency to use the MSDSs as if they are the COSHH assessments. You need to make use of the information in the MSDS but have your own COSHH assessment for each use of a particular substance (eg both for the dilution process and for the use of the diluted substance by the students). In this case, and whilst all potential controls should be considered, I suspect that it will still require ppe at both stages.
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