Have been undertaking a COSHH Assessment through the COSHH Essentials website for a popular threadlocking adhesive from a certain large manufacturer. The MSDS does not list the boiling point or vapour pressure figures. I contacted the manufacturer for this information and they have not been helpful. They inform me that they are not legally required to include these figures on the MSDS and it would cost me 3000 Euros to have it tested. I am somewhat surprised by this response. We use other products that they make and the figures are included on their MSDS'. Where do I stand on this? Are they required to have this information available? I've only done assessments through the COSHH Essentials website, is there a way/method I can do it with out this data and website help? Thanks.

Do you know approximately the composition and the constituents? If you put a drop of it on a slide, how long does it take to evaporate? Can you make reasonable estimates?

Three points arise out of this: 1. The MSDS is not intended for COSHH. It is a requirement stipulated by CHIP, i.e. for supply. It only requires the supplier to include in his list of constituents those that carry risk phrases. If you consult the ACoP for COSHH (para 13) you will see that the ACoP considers that this is not adequate for a COSHH risk assessment. 2. The supplier has a duty under section 6-1 of the Health and Safety at Work etc. Act to provide you with information such that you can use the product safely for the purpose for which it was supplied. Assuming that the supplier was aware of the purpose and has supplied the product for this, then he has a duty to tell you how to use it safely. Most suppliers, in my experience, are unaware of this duty and many, when made aware, simply do not have the knowledge or data to be able to comply. In my view more emphasis should be laid on this duty rather than the provision of the safety data sheet. 3. COSHH essentials is, in my experience, inadequate when conducting a risk assessment for chemical exposure when skin exposure is a possibility. There are literally thousands of chemicals that do not have a risk phrase, but that in contact with the skin can trigger occupational skin disease. At a meeting recently of "Safehair" (the EU project to create guidelines for the reduction of skin disease in hairdressers) in Dresden we discussed this and one result was that water was included as a skin irritant in our considerations. There are several common allergens that have never been given risk phrases (I have a list if anyone is interested). Moreover, we buy chemicals to use. In the process we may change their properties, and thus their hazards. So risk assessment needs to identify the real hazard that arises when one or more chemicals are actually used. Note that this can change during the task or, where the same chemical is used for several tasks in succession, from task to task. Identifying the real hazard when chemicals are used can be tricky and is often the most difficult part of a risk assessment for skin exposure. Chris

Thanks for the advice, much appreciated. Jim

Is it not possible that they have not determined the BP & VP because it is insignificant? Please PM me with more details i.e. the brand/particular product.

Jim Let's come at this problem from the practical end. You say that the product is a threadlocking compound. Would I be right in guessing that it comes in a 5mL dispenser with some headspace filled with oxygen because it cures in the absence of oxygen, which is what happens when the user opens it, puts a couple of drops on the nut thread then torques the nut up tight? This is the generic nut locking technique I think. If so, what could the worst case exposure be? Drops on the skin - certainly and well worth considering as it might well be quite nasty from a dermatitis point of view. Inhalation - there isn't a short period where you've got to run the nut on or it's all evaporated and anyway I defy your fitter to get his nose close enough for it to be a problem. If this kind of rings true, then I go with the guys above who take the view that COSHH Essentials is sending you off rather on a wild goose chase. Those of you in the engineering industry, am I on the right tack? We can sometimes get too hung up on chemistry when the answers lie in the use of the material. Remember, it's the use of the material you are assessing, not the chemical alone. Jim

I would suggest that the BP and VP, if they have been determined, fall outside the range that COSHH Essentials evaluates, as inferred by a previous poster. I have inherited a system that uses COSHH Essentials as the initial screen and I find its limitations annoying at times

Ooops - one little point to add. Don't forget the risk of eye splash. Even a drop in the eye might be nasty. But I guess your works is likely to be an eye protection zone anyway and the stuff isn't going to scoosh out with enough force to get past the basic flying object and dust protection glasses that you've probably got already.

With regard to the comment re MSDS and REACH, I am not sure whether it will get any easier. As I understand it from my discussions with those concerned with this topic, the basic requirements for the information to go on the safety data sheet haven't really changed much. However, what is new is that ultimately all MSDS will have to be accompanied by Exposure Scenarios, stating how the product should be used safely for the particular task(s) for which it has been registered. (Note that if the task has not been registered it cannot legally be used for that task!) From conversations with those involved in REACH I have my doubts about how helpful the Exposure Scenarios really will be, bearing in mind that these will have been produced by the registrants of the individual substances and, unless you are very lucky, not by the formulator of the product (as a downstream user). If we cannot even get the MSDS correct, I wonder what chances we have of getting the far more complicated Exposure Scenarios right. Chris