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#1 Posted : 08 June 2009 15:21:00(UTC)
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Posted By Ashley Williams
Sorry if we have alrady had this discussion but I couldnt find it anywhere.

Has anyone seen the online generic COSHH assessments for small business produced by the HSE?

I've looked at them and personally don't think they comply with a suitable and sufficient COSHH assessment as they appear to use the five steps system.

I especially enjoyed the sandwich shop example stating the COSHH perils of a prawn cocktail???

comments?

Ash
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#2 Posted : 08 June 2009 16:34:00(UTC)
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Posted By Roly Buss
They can be found at http://www.hse.gov.uk/co...assess/sandwichmaker.htm
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#3 Posted : 08 June 2009 16:54:00(UTC)
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Posted By Chris Packham
Have you ever seen a sandwich shop with an extraction booth?

Some of these examples cause me some concern. For example, the simple assumption that for a degreasing solvent nitrile gloves are suitable. There are many common solvents for which nitrile is completely the wrong glove. So I believe it would be possible for someone who does not appreciate the complexities of choosing gloves to simply assume that nitrile is OK and expose his employees to a hazardous solvent. This is just one example of why I view these examples with concern.

The reality is that assessing the risk of damage to health due to skin exposure is far more complex that these documents suggest. I see many situations where action taken with the best of intentions has actually contributed to the skin problem, simply because of simplistic approaches.

And the idea that with SMEs the problem is simpler than with large organisations is also wrong. People interact with chemicals in the same way, whether in a large organisation or a small workshop. In fact, in a large organisation the probability is that due to the volume of chemical being handles appropriate methods will already be in place that eliminate or limit exposure. Will the same apply to the small workplace?

Chris

Chris
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#4 Posted : 08 June 2009 20:36:00(UTC)
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Posted By Kate Gibb
Ash, why would followin g the five-step system mean that it is not suitable an sufficient. The format of these risk assessments seem clear and easy to understand, although I agree they are a little too simplistic.

For a COSHH assessment to be suitable and sufficient it needs to follow the principles in the COSHH ACOP. It should assess what minitoring has been done, LEV through examination and checks and results of health surveillance. As far as I can see this template does address all of these. The key thing for smaller business, without dedicated SHE personnel, is not to overcomplicate the process - otherwise it misses the whole point. However making it too simplistic also means there is no benefit to the assessment.

I think you should pay heed to the HSE's disclaimer - i.e. it is a generic assessment and each company needs to take it's own approach. Personally I prefer the COSHH essentials route.

Finally, I did have a chuckle at the over bench extraction for the sandwich maker though - highly unlikely!!

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#5 Posted : 08 June 2009 21:12:00(UTC)
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Posted By Chris Packham
Kate

The problem arises when you start to consider risk assessment for skin exposure to chemicals. In the first place COSHH essentials is based on risk phrases. There are many chemicals that do not have a risk phrase but that can cause occupational contact dermatitis. There are chemicals recognised by dermatologists as common sensitisers that have not been allocated R43 and thus will not appear on the safety data sheet.

I can demonstrate easily that relying on COSHH essentials can lead to an invalid risk assessment, e.g. insignificant risk whereas the truth is completely different and workers' health would be put at risk if you accepted the COSHH essentials verdict.

Secondly, particularly in small organisations, many people will do several different tasks, possibly resulting in exposures to several different chemicals during the working day or week. Irritant contact dermatitis is rarely as a result of exposure to a single chemical. It is almost always repeated exposures over time to many different chemicals, often in different tasks. So a risk assessment needs to take a much broader view of tasks, exposures, chemicals, environment, etc.

Bear in mind also that chemicals change as used. So do the hazards. This is one reason why safety data sheets are rarely the right starting point for a risk assessment. Indeed the ACoP for COSHH para 13 recognises this.

This is why many risk assessments I come across for skin exposure are simply wrong!

Keep it simple - yes. But not at the risk of damaging people's health.

Chris
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#6 Posted : 08 June 2009 23:02:00(UTC)
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Posted By Ron Hunter
Ashley/Roly - thanks for highlighting this.
The more I look, the more concerned I become.
A Fruit Farm with no mention of pesticides?
An electronics firm with no controls in place for the control of solder fume?
A Garden Centre recommended to conduct dip slide tests but with no explanation as to how (or why)?
A Sandwich Shop recommended to initiate Occ. Health Surveillance?!!!
All a bit worrying?
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