Posted By Chris Packham
I have posted concerns about the use of Material Safety Data Sheets for COSHH risk assessments on several occasions on this forum.

Investigating a suspected case of occupational skin disease for a client yesterday I was presented with a safety data sheet for a cleaning fluid that the employee used. Section 16 of this safety data sheet contained the following statement:

“The information relates to the specific product designated and may not be valid if it is used in combination with other materials or process.” (Incidentally, nowhere on the safety data sheet is a “process” defined.)

Question 1:- How is one going to use a cleaning fluid without it coming into contact and absorbing other materials?

The Health and Safety at Work etc. Act 1974, Section 6-1, imposes a duty on the supplier:

“It shall be the duty of any person who designs, manufactures, imports or supplies any article for use at work –
(c) to take such steps as are necessary to secure that there will be available in connection with the use of the article at work adequate information about the use for which it is designed and has been tested, and about any conditions necessary to ensure that, when put to that use, it will be safe and without risks to health.

Question 2:- Given the statement in the safety data sheet how can the supplier claim that he has complied with Section 6-1?

Question 3:- How many of your safety data sheets contain a similar clause and what are the implications if you rely upon the information in the safety data sheet for your risk assessment?

Chris

Posted By anon1234
Agree with your concerns - it doesn't help that a lot of people refer to an MSDS as a CoSHH sheet or similar.

Clearly an MSDS is NOT a CoSHH assessment but I have come across far too many 'health and safety professionals' (?!?) who think they are one in the same. Which links to one of my pet subjects - competence of those giving advice. there are too many people who are willing to wing it in our profession and we need to do something about this. Although I don't subscribe wholly to the theories such as 'you arn't competent unless you are CMIOSH' - and by the way I am CMIOSH so I'm not arguing against it because I haven't got 'it'. I (hopefully) recognise when I don't have the right competencies to undertake something/provide advice on something and think we need to encourage this 'self-assessment' approach more.

Posted By Chris G
I've also come across suppliers not providing adequate information on usage. A two part expanding foam filler, each of the components (tube A & tube B) had MHDS, but supplier does not supply a sheet for the foam produced by mixing these as "we don't supply or package the foam so we're not obliged to provide a MHDS." It turned out the foam was a respiritory & skin sensitiser. I'd also add that a similar lack of info on mixtures is fairly common with 2 pack paints & glues

Chris G

Posted By Chris Packham
Chris

Of course this means that the supplier is denying his responsibility as set down in section 6-1 of the Health and Safety at Work etc. Act. (see my original posting).

I frequently find that suppliers are unaware of this duty, believing that providing they have supplied the safety data sheet this is all they have to do.

When I point out to my clients' suppliers their duties under the Act the response is often one that would be unprintable here! Some then comply, others refuse (and needless to say, usually lose the business!)

It becomes even more complicated if you have two chemicals purchased from two different manufacturers and then react these. How far is each responsible? As far as I can see this is not covered in any regulation (and not even in REACH!)

Chris

Posted By Fornhelper
I sometimes feel that when undertaking COSHH assessments we can sometimes be guilty of 'information overload' and miss the whole point of carrying out the assessment!!

Whilst I appreciate that detailed information and assessments are very often necessary, I do feel that 'COSHH' is an area where many practitioners tend to 'overegg' things and they believe that some kind of technical knowledge / chemistry background is needed. I despair when I see 'COSHH assessments' for using cleaning agents / toner ink / washing up liquid / paint etc full of details of MEL's & OELs and what to do if someone drinks or eats it!!! - not to mention the entire contents of a safety data sheet being transferred on to the assessment.

I appreciate that in industries where substantial quantities of substances are being used or specific processes are being carried out then more detailed assessments will be necessary but in a care home or a building site do we really need to know the MEL and flammability properties of 'Mr Muscle' or emulsion paint and what to do if someone digests them ???? (I've yet to see a risk assessment for using a stanley knife with 'person swallows blade' identified as a significant risk!!!)

I totally agree that it is part of our role to recognise our level of competence and say 'I need help' when necessary, but I would also submit that we shouldn't be afraid of having a COSHH assessment that says 'Wear gloves and eye protection' (sorry went immediately to 'last' control measure there!!!) without including technical data and information that means little or nothing to the employee (or the practitioner!!!) and has nothing to do with the process or task a substance is being used for.

Regards
FH

Posted By Darren Beavan
I am not a chemist but have found that COSHH assessments can come up with sensible solutions provided you spend most of your time reviewing the activities being done (incl. frequency), the quantity of substance in use and the size and type of dispensing containers. I have found once armed with such information it is much easier to extract what you need from the MSDS in respect to hazard information. Admittedly the format of the MSDS is poor and the manufacturer/supplier will try and include as many over the top controls as possible to remove liability (probably why no one has ever been prosecuted). However, if you follow the approach of the online COSHH essentials and see which data it uses you can cut through all the waffle. Personally I use a two stage assessment process (simple and complex) to ensure the assessments are fit for purpose and add value. I also always ensure that whatever information needs to be communicated to the user is presented on the first page of the assessment in a summary. I actually do this will all types of assessment as I believe it respects the way people want to deal with information today - short sharp and to the point.

Regards

Darren

Posted By steve e ashton
Chris:

You are highlighting a serious and long standing problem. Far too many MSDS appear to be suppliers trying to duck any and all responsibility for providing sensible relevant or accurate information.

My all-time favourite was the skin cleanser / disinfectant MSDS which included the phrase 'avoid skin contact'...

Steve