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#1 Posted : 13 February 2007 14:54:00(UTC)
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Posted By Karel Simpson Quick query, Can a safety data sheet be used as a COSHH Assessment? All the relevant information is there or do you need to create this in different format as such to show that you have looked at the risks etc? All help gratefully recieved. Regards Karel
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#2 Posted : 13 February 2007 15:15:00(UTC)
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Posted By David Bannister Karel, the MSDS will tell you about the substance but absolutely nothing about the way in which it is used, stored, transported etc or in what quantities, at what temperature, dilution, etc. The biggest variable of all is the people who may be exposed. All of this must go in to the mix to reach an accurate assessment of the risk of harm to people.
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#3 Posted : 13 February 2007 15:23:00(UTC)
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Posted By Mitch Try this link, http://www.coshh-essentials.org.uk/ Regards Mitch
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#4 Posted : 13 February 2007 15:24:00(UTC)
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Posted By Karel Simpson Cheers, Much Appreciated. regards
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#5 Posted : 13 February 2007 16:00:00(UTC)
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Posted By Bill Parkinson Karel The purpose of the MSDS is to help to gather information regarding the substance you are looking at. You need to consider what you are actually doing with the substance as to whether there is a significant risk or not. For instance if the MSDS indicates a concentration which is below a concentration limit as specified within the Approved Supply List then any risk is reduced. In my years as a safety practitioner and chemical engineer I have found that you will not complete a suitable and sufficient COSHH assessment by just using the MSDS alone. Regards Bill
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#6 Posted : 13 February 2007 17:08:00(UTC)
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Posted By Chris Packham Safety data sheets are supplied to comply with CHIP not COSHH. They may not contain the information you need. I have seen many risk assessments made based on safety data sheet information that were simply inaccurate and, in some cases, were resulting in workers being exposed to significant risks. If you check out paragraph 13 of the ACoP on COSHH this should help to you to appreciate this. Last year the BOHS ran a Webinar on safety data sheets. You will find the notes on this on the BOHS website. They should make it clear to you why you should not rely upon the safety data sheet for a COSHH assessment. I also have a document: "When is a safety data sheet not a safety data sheet". I will happily e-mail this to anyone who sends me their e-mail address. In any event, it is the responsibility of the supplier under Section 6-1 of the HASAWA to provide you with the information to enable you to use the product safely for the purpose for which it is supplied. I most cases I find that this comes as a surprise to suppliers, who thought that all they needed to do was provide you with the safety data sheet. Not so! Chris
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#7 Posted : 13 February 2007 23:57:00(UTC)
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Posted By John Murgatroyd And you need to bear in mind that the MSDS are frequently plain wrong. It has always puzzled me that many of the constituents of paint, for instance, are only irritants when mixed but are toxic on their own. On one instance I enquired of a univ about the lack of fumes on their test results, only to be told that the manufacturer had specified the test results on a paint thickness of 5 microns. The paint, when used in industry, is applied to a thickness of 100 - 150 microns.
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#8 Posted : 14 February 2007 10:53:00(UTC)
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Posted By GavinR I agree that MSDS are not COSHH assessments as they are not specific to the activities that the substances are used for in each workplace and each process but surely the MSDS is an important tool in conducting a COSHH assessment. If the MSDS being filled with wrong information then the supplier(s) are surely not complying with their duties under CHIP. It is my understanding from the ACOP that Reg.5 of CHIP that the suppliers have a responsibility to anticipate the use of the substance which they are providing to their customers and prepare the MSDS to reflect this. Would this not mean the MSDS should provide suitable info to conduct the COSHH assessment? If MSDS is useless with regard to COSHH assessments can anyone advise me on how to carryout a COSHH assessment. Must we source a chemist to assist with all future COSHH assessments?
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#9 Posted : 14 February 2007 15:27:00(UTC)
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Posted By Chris Packham The supplier has a duty under section 6-1 of the Health and Safety at Work Act to provide the user with sufficient information that he can use it safely for the purposes for which it has been supplied. Re the previous question about relying upon safety data sheets. This implies that the supplier knows what you intend to do with his chemical. Do you inform him of this and make him aware of the need to provide this information? REACH will emphasize this requirement in that in addition to the safety data sheet the supplier will be required to provide an "exposure scenario" for this very purpose. Furthermore, the user will have the right to inform the supplier of the use to which he intends to put the chemical and the supplier will have to provide an exposure scenario to cover this. However, neither REACH nor any other regulation that I am aware of addresses the problem when you purchase two different chemicals from two different manufacturers and then mix them. Who is then responsible for the exposure scenario is not clear! I have a standard letter that I get my clients to send to their suppliers. If anyone would like a copy, drop me an e-mail. Chris
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#10 Posted : 14 February 2007 17:53:00(UTC)
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Posted By Andy Brazier I'd look it as the MSDS providing information about the hazard. Your job is to complete the risk assessment and identify suitable controls, which forms your COSHH assessment. I would think it fairly clear in most circumstances that if you mix two substances, it is your responsibility to assess the risk of doing the mixing and for using the mixed material. I guess if the two substances are supplied together and intended to be used together (e.g. epoxy resin) then the supplier should cover the mixed as well the individual substances.
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#11 Posted : 14 February 2007 18:15:00(UTC)
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Posted By Chris Packham Andy In how many SMEs do you imagine there would be sufficient chemistry knowledge to understand the hazard that mixing two chemicals together might produce? Remember also definition (e) in COSHH. All chemicals have the potential to cause harm under the right (wrong?) circumstances. One of the most common causes of occupational contact dermatitis is wet work, i.e. excessive contact with water. When did you last see water on a safety data sheet? There are literally thousands of chemicals that can cause dermatitis that will not have a risk phrase and therefore are unlikely to be shown on the safety data sheet. Do you take account of these when doing a risk assessment for skin exposure? How, if you haven't been told that they are there? Please, I am not trying to be confrontational. I frequently see situations where those responsible for health and safety have taken action with the best of intentions - in my case in respect of protecting the skin - which has actually increased the risk or has even been responsible for the contact dermatitis. If you don't believe me about this take a look at the document on the IOSH Merseyside website on managing skin disease. Chris.
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#12 Posted : 15 February 2007 09:42:00(UTC)
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Posted By Andy Brazier Chris I'm a bit lost now. I don't want to say anymore until I understand the point you are making. Perhaps you could provide a bit more information about the situation you refer to where the risk of dermatitis was increased by well intentioned actions. Also, I have had a quick look at the Merseyside IOSH website and couldn't find the document. Thanks Andy
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#13 Posted : 15 February 2007 09:58:00(UTC)
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Posted By Chris Packham Andy Try http://www.ioshmerseysid...dex.php?iosh=200716thjan (Its under Events - Branch Events ...) On the other aspect I could quote you a whole raft of incidents. I have just reviewed the glove selection document for a major chemical company. This contains a number of recommendations for glove use that are simply not correct and which would be putting workers at risk. Incorrect selection and use of gloves is a common problem, simply because those doing the selection do not understand how complex glove performance really is and that manufacturers' published performance data does not indicate useful glove life under actual conditions of use. Last year I had a safety office (MISOH) accept the claims of a supplier and recommend a barrier cream as protection against hydrofluoric acid! If you want more examples, I suggest you contact me direct. Chris
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