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#1 Posted : 12 June 2009 14:54:00(UTC)
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Posted By Paul Durkin Hi All, I have mentioned strippers before.However,their are now two, both with the busy title of 'Carefree'.I only found out their were two when searching a site for their MSDSs.I was looking to see if there had been any improvement to their data sheets since REACH i.e. exposure scenarios.These strippers are to strip polish from floors.The only difference in their names is that one is called SPEEDY and contains a solvent with a WEL of 25ppm.Have I missed something or is there a time delay in manufacturers adding exposure scenarios to MSDSs? Regards,Paul
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#2 Posted : 12 June 2009 15:26:00(UTC)
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Posted By Paul Leadbetter Paul It will be some while before exposure scenarios are required, I think. Paul
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#3 Posted : 12 June 2009 15:55:00(UTC)
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Posted By Rodger Alan Ker Used this product a few years ago for this purpose. Diversey: Taski R20-strip F41 It was a client specified product for "removing polish from water resistant hard floors" Don't have any other details now.
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#4 Posted : 12 June 2009 16:09:00(UTC)
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Posted By Saz G I was at a recent meeting relating to my particular industry and the subject of updating MSDSs with REACh info such as Exposure Scenarios came up. It appears that there will be IT tools developed to enable Companies to enter information and it create REACh compliant MSDSs for you and my particular industry is leading the way with this through EUPR funding, but it is some way off yet. 18 months at the earliest. I believe that the exposure scenario data is still being worked on and fear it will be some time before we start seeing them come through the system or be available.
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#5 Posted : 12 June 2009 16:15:00(UTC)
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Posted By CFT Actually as Paul L mentions exposure, this reminds me of a well known metallised emulsion seal stripping product which should only ever be used with cold water. It contains ammonia and for obvious reasons shouldn't be mixed with other products. (of course everyone has this information given in training). I witnessed it mixed with hot water once and arranged for four or five operatives to go to hospital. It is next best thing to impossible to breathe in minute quantities of the vapour given off with hot water. Taking it up on behalf of a client I contacted the company and they subsequently re-wrote everything. Not sure it's still available ... hope not! I think Paul (OP), it was the same manufacturer ... evil stuff used incorrectly, as is the case in some instances sadly. CFT
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#6 Posted : 12 June 2009 16:39:00(UTC)
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Posted By Decimomal With all this talk of stripping and exposures I need a lie down! Bon weekend to all.
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#7 Posted : 12 June 2009 16:48:00(UTC)
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Posted By Chris Packham I have a concern about whether Exposure Scenarios will really produce anyting of great help to the end user. Remember that REACH is only concerned with individual substances. What most of us will use will be preparations, i.e. mixtures of substances. Thus for a preparation containing, say, ten substances as constituents the formulator will have ten relevant Exposure Scenarios. He does not have to produce a new Exposure Scenario for the mixture but can pass on the relevant ones with his own data sheet for the preparation. The questions in my mind are: 1. Will the different substance providers coordinate their Exposure Scenarios? If not what does the end user do should he or she receive ten Exposure Scenarios for the one product, each of which suggests different risk management methods? 2. How will one substance supplier decide what the hazards and appropriate risk management measures are if his substance is being mixed, reacted or otherwise in contact with other substances? Chris
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#8 Posted : 12 June 2009 17:07:00(UTC)
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Posted By Chris Packham Just to add to my last posting: As far as I am aware there is no plan to rescind section 6-1 of the Health and Safety at Work etc. Act 1974. This requires the supplier to provide information such that his product can be used safely for the purpose for which it was supplied. So forget safety data sheets (many of which are wrong anyway) and Exposure Scenarios. Just insist that your supplier complies with his duties under section 6-1 of the Act. If you can make him do this then you should receive the information you really require.
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#9 Posted : 15 June 2009 09:08:00(UTC)
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Posted By Paul Durkin Thanks All, I did not realise that the exposure scenarios only applied to individual substances (Thanks Chris)The strippers are obviously mixtures,the Speed one containing a very good solvent.My problem has been getting from the manufacturer sufficient info on likely airborne exposures.They continually sent me info on similar, but not the same product.In the end I had to resort to my old Phys chem books(i.e. Rault's law)to enable some idea(without monitoring) of likely exposure levels. So it seems that the situation will remain the same.I was hoping for improved info on the new MSDSs,but I guess that's out of REACH. Regards,Paul
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#10 Posted : 17 June 2009 10:42:00(UTC)
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Posted By Paul Durkin Hi All, Having read the REACH leaflet no 13(UK REACH Competent Authority Information) REACH is not exclusive to substaces but includes mixtures such as medical products or cosmetics (their examples) The leaflet also notes that the 'inclusion of exposure scenarios including any risk management,where required in an Annex to the SDS'.So hopefully that will differentiate a Carefree Stripper from a SPEED one.Hope these revised SDS will not be out of REACH for too long. Regards,Paul
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#11 Posted : 28 June 2009 22:33:00(UTC)
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Posted By Chris Packham Paul In response to your last posting (apologies for delayed response but was at an internation conference on skin issues [OEESC2009] and then on holiday for a week) the following is my understanding of the situation regarding REACH and substances/preparations: The registration under REACH is purely for individual substances at present. Each registration will comprise a Chemical Safety Assessment and Report accompanied by Exposure Scenarios with Risk Management Measures for each 'use' for which the substance is being registered. Any 'use' not included will be illegal once registration has taken place. The Exposure Scenario (EDS) will be for the substance registered. There is no provision at present for preparations, i.e. mixtures. However, the registrant of the substance will need to drill down the supply chain to take account of any effects from mixing/reacting when his substance is combined into a preparation so that he can produce meaningful Risk Management Measures. Of course, the substance provider will still have to produce a safety data sheet (SDS) to which he will attach all the relevant ES. According to one petrochemical manufacturer for some of his substances there will be one SDS attached to which will be around 500 ES! A downstream user who is a formulator will take several substances and mix/react them. He will have to issue a SDS for his preparation but need only attach the relevant ES to this. Imagine a preparation with ten constituents and three different uses covered by the original registrations. You could end up with a SDS with 30 ES documents attached. These will be provided by ten different substance suppliers. Will they agree? What will the owner of a SME make of all this paperwork? Since we cannot even ensure accurate SDS what chance do you think we have of accurate ES? Actually, the picture is not all that depressing. As far as I am aware there is no intention to remove section 6-1 of the Health and Safety at Work etc. Act 1974. This requires a supplier to provide information such that the product can be used safely for the purpose for which is supplied, a simple basic requirement. So one can argue that in 1974 the U.K. passed a law that is still superior in practical terms to REACH (if only the HSE would enforce it!) Chris
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