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#1 Posted : 25 June 2008 15:37:00(UTC)
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Posted By safetybod
Can anyone tell me if there is a set period after which coshh assessments should be reviewed if the process/people/activity/substance etc has not changed?
Thanks in advance
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#2 Posted : 25 June 2008 15:58:00(UTC)
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Posted By Roger White
If you know definitely that none of those have changed then you have carried our the necessary review. Record that fact and move on.
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#3 Posted : 25 June 2008 16:04:00(UTC)
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Posted By Ron Hunter
As I recall, COSHH Regs have a stipulated review period of not more than 5 years.

The intention of the Regulations is that the employer must look afresh at the product or process to re-evaluate and ascertain if there are safer alternatives (in terms of both product safety and the technology involved in the process).

Your review therefore has to record at least some deliberation. Remember that the COSHH Regs. have a rather strict heirachy of controls!
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#4 Posted : 25 June 2008 20:44:00(UTC)
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Posted By D H
If there is a medium to high risk potential, then re assess when you consider fit - taking into account the possible consequences from the assessment going wrong then prioritise when the assessments need doing. Higher potential cases need reviewing more often than ones with negligible risk potential. But they must all be reviewed!
You must decide when, because if there is a accident and you end up in court, would a judge reckon a 5 year assessment period when an accident has occurred was reasonable?

Be wary that if nothing has changed, that people doing the tasks have not deviated from the laid down procedures. complacency is a massive cause of accidents / incidents.

Ask the people if they have any worries / problems.

Check for safer alternative chemicals.

Check that LEV etc has been maintained then sign off the review with the new date and set another review date.

Dave

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#5 Posted : 25 June 2008 21:54:00(UTC)
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Posted By Paul Leadbetter
Ron

Where do you get 5 years from? I don't think the Regs have ever specified an interval for re-assessment.

Paul
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#6 Posted : 25 June 2008 23:54:00(UTC)
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Posted By Ron Hunter
Sorry Paul, I got Reg 6 mixed up with Reg 10 a bit there. Even so, the 5 year period for retention of workplace monitoring (not involving individual employee exposure monitoring) is (IMHO) a reasonable 'absolute' period to apply to a COSHH Assessment review, with reference to paragraph 81(a)(ii) of the L5 ACoP.

All other things being equal, it is likely that there may have been product or technological advance over that period, which COSHH requires the employer to take account of.
Consideration of such in-depth review on (e.g.) an annual basis could I think be considered onerous and burdensome.

This review process is not to be confused with routine monitoring of the effectiveness of existing controls. In a Regulatory context, 'monitoring' and 'reviewing' are two distinct and seperate activities.
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#7 Posted : 26 June 2008 10:04:00(UTC)
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Posted By Ron Hunter
Paul,

Further to your question! I couldn't let this rest - I had to figure how and why I got this 5 year requirement fixed in my mind.
I referred back to my copy of the 4th Edition of Allan St John Holt's widely respected "Principles of Health and Safety at Work", and I quote from the discussion of what was Regulation 6 of the 1994 COSHH Regs.:
"A later amendment requires all risk assessments to be reviewed every 5 years, in addition to the requirement to review them if they are suspected of being invalid".
At that time then, what is now (IMHO) implicit was then explicit in the 1994 Regs. Sadly I don't have the time to research when that explicit requirement fell back out of the Regulations.
I would still advise 5 years as a reasonable interval for a more in-depth product and technological review.
emm.plant@me.com  
#8 Posted : 15 July 2020 14:52:16(UTC)
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emm.plant@me.com

Hi all, we used to constantly monitor our COSHH MSDS and update regularly via updates provided by the BESA. This is a service they no longer provide, is anyone aware of a service that can look after this for you that isn‘t part of a much larger package e.g. Barbour? We don’t need the other services. Would also be interested to see how often anyone else goes through the MSDS to ensure any changes are reflected in the assessment

chris.packham  
#9 Posted : 15 July 2020 16:36:54(UTC)
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chris.packham

Simply monitoring for changes in MSDS runs a significant risk of missing other changes. Firstly what about those chemicals for which there are no MSDSs but which can, when used, present a hazard to health (of which there are thousands particularly where skin exposure is concerned). Presumably the risk assessments have been based on the chemical hazard present when chemicals are used (as required by the current ACoP for COSHH). Have there been any changes in what happens there? Have there been any other changes in the way the chemicals are used that might affect the hazard they present? 

I have to take the view that a fixed period for auditing risk assessments could potentially land an employer in trouble. Changes that occurred, perhaps shortly after the last audit, could well create a situation where employees health was being damaged. Were the effect to be chronic, i.e. not appear for some time, the damage could well have been done before the next fixed audit point although the effect might not have yet become apparent. For me the system should be such that any change in chemical (perhaps a new supplier?), the way it is used, the level of actual/potential exposure, the exposure management arrangements, ambient conditions, etc. should trigger a reassessment. 

Roundtuit  
#10 Posted : 15 July 2020 17:26:41(UTC)
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Roundtuit

As with all other assessments time to review is when something new is PROPOSED, something is to be used or supplied in a different manner (swopping from brush to spray or tin to drum) or the actual supplier is being switched.

As the customer you are the one who should be being sent updated SDS by your suppliers when there is a significant change (check accounts are not receiving documents they just file with order acknowledgments / invoices) you do not need a third party, in fact I point blank refuse to deal with third party organisations who are not contributing to the cost and are not held responsibe under the REACH regulation for the accuracy of data they provide.

P.S. the rules on SDS preparation are changing again on 1st January 2021 from EU 2015/830 to EU 2020/878

Roundtuit  
#11 Posted : 15 July 2020 17:26:41(UTC)
Rank: Super forum user
Roundtuit

As with all other assessments time to review is when something new is PROPOSED, something is to be used or supplied in a different manner (swopping from brush to spray or tin to drum) or the actual supplier is being switched.

As the customer you are the one who should be being sent updated SDS by your suppliers when there is a significant change (check accounts are not receiving documents they just file with order acknowledgments / invoices) you do not need a third party, in fact I point blank refuse to deal with third party organisations who are not contributing to the cost and are not held responsibe under the REACH regulation for the accuracy of data they provide.

P.S. the rules on SDS preparation are changing again on 1st January 2021 from EU 2015/830 to EU 2020/878

chris.packham  
#12 Posted : 15 July 2020 21:37:34(UTC)
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chris.packham

The 'fixation' that the risk assessment can be based on the supplier safety data sheet hardly coincides with the requirement in the current COSHH ACoP:

Paragraph 10 - Employers should regard a substance as hazardous to health if it is hazardous in the form in which it may occur in the work activity. A substance hazardous to health need not be just a chemical compound, it can also include mixtures of compounds, micro-organisms or natural materials, such as flour, stone or wood dust.

No mention of the safety data sheet in that paragraph!

Consider that the most common cause of occupational contact dermatitis is water (wet work, skin hyperhydration due to glove use). When did you last see a safety data sheet for water?

There are 4900 chemicals known to dermatologists as skin sensitisers, only a fraction of which will have been assigned H317. It is unlikely that you will find the others listed as skin sensitisers on safety data sheets but some are quite commonly found in workplaces I have visited.

The ECHA in Helsinki studied REACH safety data sheets from over 1,000 chemical producers and classified 52% as 'deficient'.

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