Posted By Jason911
Hi All,

Can anyone tell me if the classification symbols used under CHIP & COSHH are mandatory? i.e Harmful,Irritant,Corrosive, Toxic and Carcinogenic.

I thought they were until I found a wheel cleaner solution in my local car DIY store that contained hydrochloric acid, but no sign of a 'corrosive' symbol.

Thinking about it, I suppose a car battery would be the same scenario, so what are the rules about symbol required or not, as I cannot find any reference to it?

Posted By Paul Leadbetter
Jason

If I remember correctly, if the HCl is less than 9%, it is only classified as irritant.

Paul

Posted By Jason911
So if only 9% would it still not need the irritant symbol? I am trying to devise a training powerpoint presentation for COSHH and I am having difficulty in how I can teach employees to recognise a COSHH substance when they see it, without looking at a huge list.

Posted By Sam Wade
Jason

I'm assuming that the wheel cleaner that you saw was a preparation which contained acid.

The acid is one of the ingredients of the preparation.

Just because one of the ingredients is a corrosive does not automatically mean that the whole preparation (which includes other ingredients) will be corrosive.

There's a bit more calculation / testing that goes into the classification process than just saying - it contains acid so it's corrosive.

Posted By anon1234
agree with the previous two posts

Posted By Jason911
Many thanks for all the responses, which I think anyone would agree are not exactly simplistic???

I am trying to comply with the regulations and design a more up to date COSHH training program for our employees via a Powerpoint tutorial.

I began with a simple question 'So how do you tell a COSHH substance from a harmless one ' but I don't see how a layman i.e a new employee on an induction course is supposed to take all that in.

Additionally the Regs appear to be insufficient, as there are obviously many other substances on the market that are still hazardous but not controlled by COSHH (wheel cleaner containing acid) and I want to include them in my training e.g how to clean up a spill, how should you dispose of etc......and then there's the issue of flour.

So I guess my training should be called 'Control of Substances Hazardous to Health (COSHH) and also other substances that are not quite as hazardous, but still pose a threat to your health training' I just want to keep it simplistic and comply with the regulations I mean why is flour a COSHH controlled substance, but has no labelling on any of its packaging???

Posted By Paul Leadbetter
Jason

Your wheel cleaner will be covered by COSHH even if it is not classified under CHIP!

Sorry about my misleading response earlier in the thread; it has been a long time since I had access to the Approved Supply List.

Paul

Posted By Chris Packham
Firstly I find the attack on my statement somewhat aggressive. As someone who has spent the last 27 years concentrating on the prevention of damage to health from workplace skin exposure I believe I can claim a certain expertise in this aspect of health and safety.

Secondly, wet work, i.e. exposure to water, is documented as one of the most common causes of occupational irritant contact dermatitis. This is a proven statistical fact. This is something that anyone who knows anything about the skin will have taken on board.

Exposure to water can denature the protein in the corneocytes that make up the stratum corneum, the barrier layer in the skin. Ultimately this degrades to the point where dermatitis occurs. Dermatologists classify water as a skin irritant, albeit a mild one. If anyone doubts this I will happily provide them with the peer reviewed papers on this from publications such as Contact Dermatitis, Acta Dermatoveneriologica etc.

In Germany this has been recognised by the authorities. If exposure of the skin to water is for more than 2 hours in any 8 hour shift this is considere a hazardous situation and special precautions have to be taken. See Technische Regel fuer Gefahrstoffe Nr. 401.

Thus if you have workers exposed to water you will need to assess the risk that this might cause skin damage to take the appropriate risk management measures.

There is a vast range of chemicals that will not have a risk or safety phrase but that can cause damage as a result of skin exposure. Furthermore, there are other factors, such as environmental conditions (e.g. humidity, ambient temperature etc.) that can act in conjunction with chemical exposure to increase the effect. Ignore these at your peril!

Chris

Posted By Mathew Wright
I think mistakenly some people believe that COSHH and CHIP are almost the same thing.

As taken from the HSE website - "CHIP is the law that applies to suppliers of dangerous chemicals. Its purpose is to protect people and the environment from the effects of those chemicals by requiring suppliers to provide information about the dangers and to package them safely".

It is also the law which requires material safety data sheets to be produced.

COSHH is about how substances are used, not just those classified as dangerous under CHIP. So I do agree that water and many other substances need to be considered under COSHH.

As has been said, if you have your hands in water all day it will cause harm to your skin. Similarly, you won't find a CHIP classification label on a plank of wood, but we know that exposure to wood dust can cause harm.

So your wheel cleaner - we know it isn't classified as harmful under CHIP (the concentration of acid isn't enough to make it corrosive) so you will be able to get some on your hands and know that it won't immediately burn. It shows me that if I spray my car wheels with it then I don't have to wear gloves, even if I get a small amount of mist on them. If it was classed as corrosive then the recommendation would be to wear gloves when using it.

It is very difficult to explain in words, and (this sounds patronising) I think before you develop a training package you need to understand it yourself because people will ask you similar questions and expect you to know the answer.

So to try and answer your question about the COSHH training package - you can identify a substances which has been classified as dangerous under CHIP by the label on it corrosive, etc - you know that if you use these substances then precautions must be taken to prevent/ minimise exposure.

With all other substances it depends what is being done with them and whether people are being exposed to them (breathing the substance in, getting it on the skin, or eating it), how often, how long, how much....and yes, this does include water.

Posted By I McDonald
Jason

I will hazard a guess and wait to be shot down in flames. The examples you gave I would see the marking requirements as follows:

1 - Bleach hazardous in the quantities sold to the public;
2 - Flour not deemed as hazardous when used for domestic purposes and in the quantities sold. Would think larger bulk packages (i.e. in storage, etc) would carry appropriate signage;

That's my stab at an answer and I await a stabbing from others.

Ian

Posted By Chris Packham
Matthew

My apologies for mixing up names.

Chris

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Posted By Kate Graham
If instead of buying a flour from a retailer you buy starch powder from an industrial supplier you will get a safety data sheet telling you about the hazards of starch powder.

The starch will not have a hazard label simply because the (very real) hazards of starch don't fall into any of the categories that require one (corrosive, flammable, etc). Not having an orange label does not mean the substance has no hazards, just that it doesn't have the hazards for which orange labels are specified.

Kate

Posted By Bill Elliott
Many substances do not come conveniently packaged with COSHH symbols, eg body fluids, but would still require to be assessed in certain situations. We have fallen foul of this is the recent past where, it subsequently turned out, an individual was spat at by someone with a known risk of a condition that could have prooved fatal if not treated.

Posted By Kate Graham
Often an activity involves both risks to health from exposure to a substance, and risks to safety. In that case you might choose to cover both under the same general assessment instead of having two separate assessments. For example, flour has the risks of respiratory sensitisation (COSHH) and dust explosion (nothing to do with COSHH) but you can control both risks using the same approach (preventing build up of flour dust) and document the risks and precautions on a single piece of paper. Personally I've found the combined approach works better.

Kate