Posted By Chris Packham In my experience the majority of MSDS are incorrect. I haven't seen one in the past 12 months, for example, that has met the legal requirement in terms of the information required about personal protective equipment. However, in the context of a risk assessment this is irrelevant as the MSDS is not the document providing the data for a risk assessment. MSDS are only about the chemical as supplied and, as I have stated many times on this forum, only provided to comply with CHIP. The ACoP for COSHH (para 13) actually confirms this. For a risk assessment you need data on the product as used. There is a requirement in Section 6-1 of the Health and Safety at Work etc. Act 1974 for the supplier to provide this, although most are not aware of this and almost none do - until this is pointed out to them, and even then with reluctance. I see numerous risk assessments based on the MSDS that from my perspective (skin exposure) are simply wrong. So yes, you need to review your risk assessments, but based on Section 6-1 information and not on the MSDS. Obviously I cannot go into great details on the reasoning behind this, but if you need more feel free to contact me direct. Chris

Posted By AJM A very interesting question, I have had personal experiance of auditing a companies full MSDS sheets and couldnt agree more. It was a big company with lots of dye chemicals and it was the first time they had been audited in 15 years. I personaly cross referenced the MSDS sheets with the most upto date EH40 document and there were a few that said non hazardous but when audited it turned out they were hazardous. Its important to check all the safety phrases too i had a few that had Sensitizing chemicals but no mention was made on the MSDS. I got involved so much that i was actually driving the companies who supplied the chemicals to change their MSDS sheets and that cant be right they should be the ones doing it. So i would personally advise an MSDS audit every few years or you could end up assessing something non hazardous when in effect it could be. Regards Alan

Posted By Martin H Thank you for all your replies. I will now go back and audit all our MSDS for inaccuracies.

Posted By Chris Packham Martin Fine to check safety data sheets, but keep Pete's and my comments in mind when readdressing your risk assessments. There are many substances that do not have risk phrases and thus will not generally appear on the safety data sheet, but that can cause damage to health if in contact with the skin. So if you rely just on the safety data sheet there is a very significant chance that your risk assessment will be wrong! Chris

Posted By Pete Longworth Any consultant worth his salt should know that an MSDS is not a suitable and sufficient COSHH assessment. Just imagine for one moment that there was an MSDS for water. It would probably say that it was fairly innocuous. But what if it was used in the form of super-heated steam, or used in the form of ice as a cooling medium. Would the MSDS mention that prolonged contact could result in dermatitis, I doubt it.That's why your COSHH assessment must be more than just an MSDS.

Posted By Chris Packham Jim And remember that EH40 is only for inhalation exposure. It has little relevance for skin exposure. Chris

Posted By Chris Packham Martin It could be a question of concentration. Below a certain level (1% or 0.1% depending upon state, e.g. liquid, vapour) even a substance with a risk phrase does not have to be mentioned on the safety data sheet. It could still cause an allergic reaction in a previously sensitised person, though! If you need to know more about why the safety data sheet is not suitable for a COSHH risk assessment e-mail me and I will e-mail you back a document on this. Chris

Posted By Chris Packham Donk Drop me an e-mail on chris.packham@enviroderm.co.uk and I will e-mail you back a copy. Chris