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rockybalboa  
#1 Posted : 21 April 2011 12:46:31(UTC)
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rockybalboa

Hi Im sure this question was asked before but I'll ask it again. We employ contractors who undertake cleaning duties in our buildings but we supply the petty cash ad hoc for them to buy cleaning products such as bleach, flash, cif, toilet duck etc. Do these products fall within our COSHH risk assessment or as its our products but they are another company's employees they should fall within the cleaning persons' employers COSHH risk assessment ?
Kate  
#2 Posted : 21 April 2011 12:55:37(UTC)
Rank: Super forum user
Kate

The risk assessment is the employer's responsibility. But as the client you might well ask to see it. Do you have any say in which products they use or are you just paying for them?
Chris c  
#3 Posted : 21 April 2011 13:13:04(UTC)
Rank: Forum user
Chris c

RockyBalboa If you are supplying materials that come under the COSHH Regulations then you have a duty to provide information on the product how to used the product correctly in line with the MDS and manufactures instructions this would also be covered in the COSHH assessment , just rember information instruction and training and you wont go to far wrong Chris
rockybalboa  
#4 Posted : 21 April 2011 13:20:05(UTC)
Rank: Forum user
rockybalboa

Its really the cleaners choice what they think is best to clean the offices and toilets. Its a self employed person who employs other cleaners and the employer is the cleaner as well (family run). As long as the place is clean we dont really care what is used as its all stuff which is available to the public bought in sainsburys. Most likely they dont have a Risk assessment and it may be easier for us to do it for them. We also dont pay this person as their cleaning duties are traded for a service we offer to another company who pays the cleaner. kind of a weird set up.
chris.packham  
#5 Posted : 21 April 2011 14:17:23(UTC)
Rank: Super forum user
chris.packham

I think that the critical factor is that you do not actually buy the products, merely provide the funding for the contractor's personnel to buy what they believe they need. Since you do not buy the products you would not normally receive safety data sheets (particularly when purchased as consumer products in a supermarket). I would have thought that it is the cleaners' employer who needs to control this situation, although you would expect to see his risk assessments. Chris
Jim Tassell  
#6 Posted : 21 April 2011 15:19:53(UTC)
Rank: Forum user
Jim Tassell

Let's back up a bit here. Look at the products in question. They are all domestic products of which probably only bleach comes near COSHH application in the first place. Even the assessment for that is as simple as "we do what it says on the label". So your test of their COSHH compliance is that your dear cleaner knows not to mix bleach with anything else. That said, if you want to be COSHH-free (don't we all?) then get your cleaner to ditch the bleach for a less hazardous bog cleaner. By the way, it's not a well know fact but the caustic component in bleach attacks the glaze on most toilets so, over time, making them harder to keep clean (so you have to use more bleach, so....).
Jim Tassell  
#7 Posted : 21 April 2011 15:21:51(UTC)
Rank: Forum user
Jim Tassell

PS Glasgow joke - I take it you're a Goth???
teh_boy  
#8 Posted : 21 April 2011 15:37:35(UTC)
Rank: Super forum user
teh_boy

Jim Tassell wrote:
Let's back up a bit here. That said, if you want to be COSHH-free (don't we all?) .
It must be Friday... as good as anyway roll on Easter. I'll leave responding to this to Chris I think..... the only way to be COSHH free is to not use ANY substances at all, how do you know they are hazardous unless you assess them? http://www.hse.gov.uk/coshh/industry/cleaning.htm
Jim Tassell  
#9 Posted : 21 April 2011 16:14:28(UTC)
Rank: Forum user
Jim Tassell

Let me repeat my earlier statement. Read the initial post. It relates to the sorts of cleaning chemicals that we can all buy out of Sainburys/Asda etc etc. These are all products that fall within the scope of the vast legislation dealing with the labelling of hazardous products. But these simple soaps, detergents and grinding pastes (and not forgetting the nice smells that get put in them), as presented for consumer use fail to trip any of the triggers that might require them to be labelled as toxic, corrosive, irritant or harmful. So they are out of scope as far as COSHH is concerned. End of story. Thank you for the link but it presupposes the application of COSHH in the first place because it's got COSHH in the header and on each guidance sheet. For the avoidance of doubt, my view is that COSHH has a precise lower cut off point in this case. With the exception of bleach the materials quoted in this example fall below it. And please don't quote sub para e of the definitions in COSHH without taking account of the commentary at paras 17 and 18.
teh_boy  
#10 Posted : 21 April 2011 16:28:49(UTC)
Rank: Super forum user
teh_boy

A quick true story. We have a cleaning chemical used at work designed specifically for task, COSHH assessment shows that nitrile gloves should be worn during use and a long handled brush used to avoid contact. Operator decides to substitute said cleaner for washing up liquid. In his mind this is safer and he doesn't need to faff around with gloves any more. (It's a brand you could buy anywhere!) The task takes about 30 - 40 minutes and is repeated several times a day, it also requires the washing up liquid to be quite strong. After a few months we are now dealing with a case of skin irritation caused by prolonged contact with washing up liquid! When asked by our insurers did we COSHH assess..... um not for this task. DOH! I'm not saying the COSHH assessment has to be long, just done! See the HSE risk assessment templates for an example RA for a cleaners!
teh_boy  
#11 Posted : 21 April 2011 16:33:35(UTC)
Rank: Super forum user
teh_boy

Blimey - I had to check... "which, not being a substance falling within sub-paragraphs (a) to (d), because of its chemical or toxicological properties and the way it is used or is present at the workplace creates a risk to health" You have to love the law :)
Ron Hunter  
#12 Posted : 21 April 2011 22:54:23(UTC)
Rank: Super forum user
Ron Hunter

Jim, I think you need to go to the supermarket and have a look at some of those products. Many of them most certainly do come under CHIP and COSHH. Oven Cleaner anyone? Mixing Bleach with well known powder cleaners anyone? All that said, the suggestion that you do the Assessments for that other employer merely adds more mines to the minefield!
Jim Tassell  
#13 Posted : 23 April 2011 17:48:44(UTC)
Rank: Forum user
Jim Tassell

Ron I agree - several nasties lurk in the supermarket aisles. I took a look earlier today. Most are based on caustic or hypochlorite or both. But not many offices have ovens that get trashed like the ones we probably both have at home! Likewise, I'd send for a plumber (or in many offices, the landlord's plumber) rather than try blootering a blockage myself. So I'm after a sense of proportion. Let's not ask our cleaners for COSHH assessments when they aren't required, as is the case for most of the examples here. By all means pull the contractor up if they don't provide our cleaner with some (non-latex) gloves and perhaps even suggest that they should crack the common cleaner's addiction to chlorine as an indicator of hygiene. But let's not force them into paperwork that's not necessary, and keep ourselves in check when the assessment really boils down to "follow the instructions on the bottle..." Jim
rockybalboa  
#14 Posted : 24 April 2011 12:51:44(UTC)
Rank: Forum user
rockybalboa

Well, Ive had a lot of response and they are very good. I was thinking about it a bit more and though this is the employers responbsibility if they are under 5 persons in their employment thrn they are exempt from having written risk assessments, right? though, if we are buying and storing the cleaners on the premises then we should risk assess them if they are there to be used by people within the busines (as they potentially would be used). I think Im leaning closer to the risk assess whats on the bottle and go with the standard instructions on the bottle on our coshh form. And Jim, no Im not a goth, I just think that its a funnyGlasgow picture, goma style.
Ron Hunter  
#15 Posted : 25 April 2011 22:53:26(UTC)
Rank: Super forum user
Ron Hunter

Ah yes, the "under 5" oddity in the Management Regulations. Bear in mind though that all employers have a duty to communicate "significant findings" to employees. L21 ACoP states that the significant findings should include: "(a) a record of the preventive and protective measures in place to control the risks; (b) what further action, if any, needs to be taken to reduce risk sufficiently; (c) proof that a suitable and sufficient assessment has been made." How do you communicate all that without a written assessment though? If you only transport and store, then your assessment need only be limited to those activities, not use. Following the instructions on individual containers will not prevent inadvertant mixing of incompatable products and could lead to liberation of Chlorine.
chris.packham  
#16 Posted : 26 April 2011 09:16:30(UTC)
Rank: Super forum user
chris.packham

teh_boy has it absolutely right. Definitin (e) of substances hazardous to health covers everything. No exceptions! There is no chemical known to man that cannot require a risk assessment under COSHH, depending upon how it is used or is present at the workplace. Water, in the form of wet work, is the commonest cause of occupational contact dermatitis. If your employee is exposed to water to any extent as part of their work, then this will require a COSHH assessment. Incidentally, wearing occlusive gloves is equivalent to wet work, so extensive wearing of such gloves will also require a COSHH risk assessment. Chris
chris.packham  
#17 Posted : 26 April 2011 10:30:54(UTC)
Rank: Super forum user
chris.packham

This is really for Jim Tassell. I notice that you state (non-latex) gloves. Why? The optimum glove for the cleaning products that are under discussion will be a reusable natural rubber latex glove. And forget the hype over latex allergy. This only occurred with the single-use, powdered, high free protein gloves used in laboratories and health care. The reusable type (e.g. Marigold) have never been a concern. If you need confirmation of this the Royal College of Physicians did an evidence based study on this that can be downloaded from their website that confirms what I have stated. Chris
Guru  
#18 Posted : 27 April 2011 22:56:51(UTC)
Rank: Super forum user
Guru

Chris, I personally think carrying out a specific COSHH assessment for working with water a tad OTT. Provided you have carried out a general risk assessment on the task using water, and having sensible measures in place then surely this would be suffice? I can hear the cries of 'elf n safety gone mad' in the papers tomorrow! Similalry, a general risk assessment for the use of occlusive gloves would be suffice also? I did have a read at the report you mentioned regarding using latex gloves, and correct me if im wrong (usually I am) but reading through the evidence table for switching to powder free it states that reports of NRL symptoms before conversion was 44% and dropped to 27% after conversion. 27% of a test population still reporting NRL symptoms on non powdered gloves is still significant is it not?
Holbrook42275  
#19 Posted : 28 April 2011 09:02:37(UTC)
Rank: Forum user
Holbrook42275

I worked on a contract as an adviser to a paper manufacturer. The lady employed to clean around the offices and toilets had been at the site for as long as anyone could recall and was about 65 and very experienced. We had visitors coming so she decided to clean the shower curtains as they had black mould stains around the bottom, she tried household bleach, didnt work, she then applied a different cleaning product and we found her a little later unconcious on the shower room floor. The questions that would have been asked had she not recovered: Was she trained in the use of ? Was there a COSHH assessment in place? However the responsibility for ensuring these assessments are in place lies with the cleaners employers not yourself. If it was me I would be wanting them to provide me with COSHH assessments because I would want to know if there were any potential risks from the substances use to my staff / visitors.
chris.packham  
#20 Posted : 28 April 2011 14:45:18(UTC)
Rank: Super forum user
chris.packham

Guru If one is to carry out a risk assessment for COSHH, and I am concerned specifically with skin exposure, then the starting point is not the chemical(s) but the task. Chemicals are only a problem when you use them. So my risk assessment would be for a task involving exposure to water. If I felt that the exposure was of sufficient duration and frequency to represent a risk of dermatitis then this would be reflected in my risk assessment and the appropriate control measures introduced. A similar approach would apply when the task involved extensive wearing of gloves. Consider also that when we use chemicals we frequently change them. We may dilute, react, contaminate, mix, etc. This can significantly change the hazard. So the example in the other posting, where bleach was used then another cleaning product tried, could well have resulted in a chemical reaction creating chlorine gas, hence the unconscious worker! In my experience of risk assessments for skin exposure identifying the real hazard present during the execution of the task is often the most difficult part of the assessment - and crucial if the correct outcome is to be achieved. With regard to your comment on the latex report, once someone has become allergic to latex proteins, then even a minute amount can elicit a reaction. Bear in mind also that wearing the tight fitting single-use gloves causes hyperhydration and this reduces the threshold at which a sensitised person may react. Furthermore it is very difficult to differentiate between an irritant reaction and an allergic reaction (or a combination of both), so someone with a known allergy might react with an irritant reaction but the assumption could then be made that this was actually an allergic one! There have also been cases of people reacting on the assumption that they were being exposed to latex, when no actual exposure was taking place. Prof. Gieler of Giessen University, an expert in psychosomatic skin reactions, has labelled this "undifferentiated idiopathic somatoform allergy"! The German healthcare experience is probably one of the best examples of the latex allergy 'epidemic'. They banned powdered single-use latex gloves. The standard in these hospitals for single-use gloves is unpowdered low free protein natural rubber latex and, in the words of a leading German expert "latex allergy is history!" Chris
Jim Tassell  
#21 Posted : 28 April 2011 20:43:56(UTC)
Rank: Forum user
Jim Tassell

All this stuff about skin exposure is great, but as far as water is concerned it ain't COSHH. COSHH has limits. Always has had. But that is hardly surprising as it was the son of the original Control of Lead at Work Regs, where inhalation followed by personal hygiene were the key issues. It is remarkably precise about its application, as in the definitions section. Those who would say that COSHH has universal application need to face this question: if you are right, why did the HSC's legal draughtsmen waste their time on defining its application? Taking it further, think of the perhaps wider area of COSHH, not the manufactured substances, nor even what comes out of the taps but the myriad of biological agents. Does your universality extend to every sort of biological agent? If not then you have a serious inconsistency. If it does then I think my microbiologist friends would have something to say. But worse, if you glibly apply universal application to COSHH then you will have people chasing round after Will O' the Wisp problems rather than concentrating on the real ones to the detriment of overall safety. And court ridicule of the press. So if COSHH applies to water, why is it not mentioned as such in any of the HSE's example risk assessments, nor on the pages linked above? As Private Eye might say, "shome mishtake shurely." I profoundly differ from the "COSHH covers water" and "COSHH covers everything" brigades. Enough from me.
repulse  
#22 Posted : 28 April 2011 21:48:25(UTC)
Rank: New forum user
repulse

I could not agree with Jim enough. I am growing sick and tired of 'so-called' COSHH assessments. I have witnessed a situation in which ill-informed individuals request COSHH assessments for washing up liquid. The reason given for this request, by a senior auditor, was that if a person drank enough washing up liquid it could become hazardous to their health. I think we should all remind ourselves of the common sense approach to COSHH as prescribed by the HSE ACOP: that being in many circumstances we need only consult the manufacturers SDS to determine if our current control measures are sufficient. Alan Matthews
Guru  
#23 Posted : 28 April 2011 22:55:29(UTC)
Rank: Super forum user
Guru

Chris, Reading your statement 'And forget the hype over latex allergy. This only occurred with the single-use, powdered, high free protein gloves used in laboratories and health care' It totally inaccurate when reading the actual reports findings. The report clearly states that 27% of the test population complained of NRL symptoms after switching to powder free latex, and 27% of any test population is still significant. So I struggle to find your justification if we are only to look at the mentioned report findings. End of the day, people can and do have reactions to latex, whether using powdered, or unpowdered low free protein natural rubber latex, this is a fact that your report confirms. Unless Im totally missing something in it? Anyway, time to sleep and there is a big party tomorrow!
teh_boy  
#24 Posted : 29 April 2011 08:32:23(UTC)
Rank: Super forum user
teh_boy

@repulse Please re-read my posts with care. 1- Currently in a difficult situation thanks to washing up liquid! 2 - the HSE example RA I pointed too shows what is expected as a minimum. It worries more and more that chemicals are regarded as so 'normal' and safe. This is in everyday life as well as safety. I don't think anyone here is saying we need a 40 page assessment for washing up liquid, but we need to risk assess the task. (see HSE example and Chris' wise words) If we can't even do that, and don't understand that washing up has dermatological consequences then are we in the right job? Yet again, I stree I am not advocating 'elf and safety' but simply that we follow the basics.
chris.packham  
#25 Posted : 03 May 2011 09:51:53(UTC)
Rank: Super forum user
chris.packham

teh_boy You refer to the paper by Korneiwicz DM et al and seem to get hung up on the 27% figure. You should keep in mind that these are people already suffering from type I allergy to natural rubber latex protein. It is not surprising that they respond to wearing a natural rubber latex glove. As I stated in a previous posting, once sensitised, even a minute level of exposure may suffice to trigger al allergic reaction. Such people are well advised to avoid NRL gloves as a matter of principle. In fact, if you refer to the actual paper, the conclusion of the authors was: “This study demonstrated that conversion to the use of powder-free, low-protein NRL gloves not only reduces health care worker NRL symptoms, but also positively affects the costs of glove purchases and workers' compensation.” I can show you many other papers, most not featured in the evidence based report, that come to very similar conclusions, e.g. “Change to powder-free NRL gloves in the German health care system resulted in decline in occupational allergies. Conclusion was that this was a valid solution to the problem. ”Allmers H et al, Primary prevention of natural rubber latex allergy in the German health care system through education and intervention, Journal of Allergy and Clinical Immunology, 2002, 110,2,318-323 The following might also be relevant: “The gloves in categories ‘very low’ and ‘low’ contain such low levels of the main natural rubber allergens that they are suitable not only for non-allergenic persons but also for most of the sensitized users.” Turjanmaa K, Kanto M, Kautiainen H, Reunala T, Palosuo T; Long-term follow-up of 160 adult patients with natural rubber latex allergy; J Allergy Clin Immunol 2002, 110, 70-74 If you still need more drop me an e-mail. Chris Note also the statement in the NHS Plus/Royal College of Physicians document: “No reports of new cases of latex allergy arising from non-powdered low protein latex glove use were found.”
chris.packham  
#26 Posted : 03 May 2011 09:56:36(UTC)
Rank: Super forum user
chris.packham

Repulse It so happens that frequent hand washing in healthcare is a common cause of occupational irritant contact dermatitis (reportable under RIDDOR). Are you suggesting that we do not need to risk assess the hand hygiene procedures in health care to ensure that hand washing does not result in an occupational skin disease? Chris
Guru  
#27 Posted : 03 May 2011 12:24:01(UTC)
Rank: Super forum user
Guru

Chris, I see what your saying but end of the day its prudent for all employers to move away from latex all together.
teh_boy  
#28 Posted : 03 May 2011 12:31:05(UTC)
Rank: Super forum user
teh_boy

Chris.Packham wrote:
teh_boy You refer to the paper by Korneiwicz DM et al and seem to get hung up on the 27% figure. .”
Wrong person - i'm on your side :)
chris.packham  
#29 Posted : 03 May 2011 12:38:54(UTC)
Rank: Super forum user
chris.packham

Guru I have to disagree. For many situations NRL is the best material for protective gloves. I have several clients who insisted on moving away from NRL to nitrile, despite the fact that they had never had any occupational allergic reactions to their NRL gloves. Having moved to nitrile they experienced a significant number of cases of allergic contact dermatitis to the nitrile gloves, which in any event were not providing the same level of protection. How would you defend this when the compensation claims start to come in? Indeed, there are now reports of type I immune reactions (same reaction as latex allergy) from nitrile and one case I had referred to me of anaphylaxis due to single-use nitrile gloves. Thousands of reusable NRL gloves are used daily by cleaners around the world with virtually no cases of latex allergy, and only very occasionally a case of allergic contact dermatitis to the chemicals used in their manufacture. They provide the strongest, most flexible gloves offering superb protection against a wide variety of cleaning chemicals. No other glove material can offer the same characteristics at a sensible cost. If you want someone else's opinion on this try reading "Protective Gloves for Occupational Use" (CRC Press, ISBN 0-8493-1558-1). Chris
chris.packham  
#30 Posted : 03 May 2011 12:39:59(UTC)
Rank: Super forum user
chris.packham

teh_boy Apologies! Chris
Parker20149  
#31 Posted : 03 May 2011 14:35:17(UTC)
Rank: Forum user
Parker20149

shouldn't really be using a supermarket product in an industrial application; safety data sheet??? Some are corrosive, toxic, harmful, etc.
Kate  
#32 Posted : 03 May 2011 15:41:38(UTC)
Rank: Super forum user
Kate

So supermarket products are fine for the general public but shouldn't be used by commercial cleaners? Why ever not?
Parker20149  
#33 Posted : 03 May 2011 15:56:06(UTC)
Rank: Forum user
Parker20149

safet data sheet!! Its not the products but everything that goes with it. Domestic users aren't covered by the H&S requirements and therefore do not need to demostrate they are managing risks effectively or decide if COSHH assessments, etc, are required. Labelling on supermarket products is good but is nowhere near as good as a proper safety data sheet supplied with industrial chemical cleaners.
Kate  
#34 Posted : 03 May 2011 16:26:10(UTC)
Rank: Super forum user
Kate

Safety data sheets for domestic products are normally available from the manufacturer - so this shouldn't be a problem.
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