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Posted By John J
Chris,
I wouldn't trust most MSDS sheets and always refer to other documentation to support any COSHH assessment I may do. Unfortunately this can end up taking a lot of time.
This then leads to other problems. Generally PPE requirements are sketchy and misleading. As discussed before, glove information is generally vague and catch alls like 'eye protection to be worn' add no value.
How many data sheets still refer to MELs? That should be your first indicator all is not well.
John
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Posted By Chris Packham
John
I agree. I was conducting an audit for a client recently and went through about 50 safety data sheets. Only one was correct in all respects. As an example, three products contained in excess of 60% acetone. One had no risk phrases at all, the other two had different risk phrases, none of which agreed with the Approved Supply List. All of them recommended gloves from materials that were totally unsuitable for acetone.
I always return to the HASAWA, section 6-1 and the supplier's duty to provide information such that the product can be used safely for the purpose for which it has been supplied. The safety data sheet is not suitable for this purpose anyway.
I am not certain (and if I am wrong I am sure I will be corrected!) but I think that this is the first prosecution for an incorrect safety data sheet.
Chris
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Posted By bereznikov
I do not have direct responsibility for making/reviewing the company's product Safety Data Sheets, so forgive the question. But, do all of our SDS's need updating to be in line with the change from MEL/OES to WEL that the COSHH 2004 amendment made?
bereznikov
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Posted By Chris Packham
Short answer to the question is "yes". They also will need to change in due course to take account of REACH.
For whoever is responsible it may be relevant that the Chemical Hazards Communication Society run excellent basic and advanced courses on the production of safety data sheets.
Chris
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Posted By Ron Hunter
Thanks for the link Chris. I hope the supply chain sits up and takes notice.
A bit disappointing though that HSE didn't pursue the supply & conformance issues with the machine mentioned.
Seems to me that it would be relatively straightforward to track down the importer/distributor, rather than attempt to issue a questionable summons on a US supplier.
Perhaps yet another indication of the lack of resources at HSE?
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Posted By Chris Packham
Ron
I don't know for certain but it could be that the user imported this directly from the USA. In which case it is my understanding that it would be the user's responsibility to ensure that any CE marking was correct.
Chris
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Posted By AJM
Speaking from experiance in this, I worked for a Japanese Dying Facility, (Lots of chemicals) and i was tasked with checking MSDS sheets. It certainly opened my eyes. Not only where they out of date, but some had even changed from non hazardous to hazardous.
I also checked these in such detail i found quite a few errors including matching up EH40 with the MSDS and even ringing the companies up and getting THEM to change their MSDS.
Cheecking MSDS sheets is something i would always advocate once every couple of years.
Alan
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Posted By Ron Hunter
Yes Chris, but if the user had imported direct, I would have then expected charges against him.
Maybe they were dropped at some stage - so often we only get part of the picture with these case reports.
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Posted By Steve Clark
This SDS issue is a significant problem. I'm currently looking at a business opportunity which i think may end up being COMAH, trouble is a number of the SDS don't even have R phrases on them. I now have to go back to the customer and dig a little deeper into their purchasing procedures. Not a good start to a beautiful relationship.
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Posted By Chris Packham
Steve
Just keep in mind that under section 6-1 of the Health and Safety at Work etc. Act 1974 the supplier has a duty (in addition to the safety data sheet) to provide you with information such that you can use his product safety for the purpose for which it was supplied.
Check out also para 13 of the COSHH ACoP which covers whether risk phrases are adequate for a chemical exposure risk assessment.
Chris
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Posted By Raymond Rapp
Chris
It is a very good point and one that I believe has been raised before. The problem of incorrect or badly phrased MSDS presents real issues for practitioners. Worse still, what is the alternative? As you have mentioned already, doing searches for products and substances can be a very time consuming business. I also have found that contractors COSHH Assessments vary in quality.
I tend to take the view that if it is a low risk substance, then I do not dwell on the quality of the MSDS. In truth, there are very few substances that if digested, got in eyes and so on, will not cause some harm.
Not sure what the answer is. However, as with many documents, I would like to see an industry standard MSDS/COSHH Assessment, which would assist in simplifying the process in the first place.
Ray
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