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KAJ Safe  
#1 Posted : 15 August 2011 13:43:11(UTC)
Rank: Forum user
KAJ Safe

I work for a large company and I have been given the task of sorting out our policy/procedure for COSHH, we are multi-site and have a varied range of substances covering bleach up to acetylene. Any pointers on where to start or advice from those who have had to clear old procedures in order to introduce new would be appreciated. Thanks for taking the time to read.
Kate  
#2 Posted : 15 August 2011 14:46:11(UTC)
Rank: Super forum user
Kate

I'll mention some of the shortcomings often found in COSHH systems: 1. COSHH assessments based on substances (eg bleach) instead of activities (eg cleaning) 2. COSHH "assessments" that consist of transposing information from the msds into another format 3. COSHH assessments done without any involvement of people who do the job 4. COSHH "assessments" that copy the PPE requirements from the msds 5. COSHH assessments that specify PPE without considering the hierarchy of controls 6. COSHH assessments that only include normal operations and not spills / leaks 7. Neglecting maintenance & testing of control measures eg LEV 8. Requiring "gloves" without specifying what kind of gloves 9. Not communicating the assessment findings in an accessible way to the people who do the job
David Bannister  
#3 Posted : 15 August 2011 14:53:25(UTC)
Rank: Super forum user
David Bannister

10. Forgetting intermediate or by-products, waste 11. Holes in the procurement/purchasing arrangements allowing uncontrolled risks to be introduced 12. Not considering "dose" 13. Maintenance departments being overlooked 14. Over reliance on software or online resources If you manage to develop a system that manages to avoid all these pitfalls you will have the makings of a great system.
Jane Blunt  
#4 Posted : 15 August 2011 15:13:10(UTC)
Rank: Super forum user
Jane Blunt

15. Failing to identify carcinogens, mutagens and substances toxic to reproduction 16. Failing to identify sensitisers 17. Failing to identify where medical surveillance, health surveillance or health records are required (e.g. in conjunction with 15. and 16.)
chris42  
#5 Posted : 15 August 2011 16:25:58(UTC)
Rank: Super forum user
chris42

I would like to add 18. Failure to take account of the effects of interaction of substances. 19. Failure to take account of transport and storage, especially substances that should not be stored together. On the systems side, which I suspect you may actually be referring, I had a large database of each substance, how it should be stored transported etc and a reference to the acceptable storage points and task specific assessment(s). This was open for anyone to look at with a pc, but also a hard copy at the storage locations as a reminder for those that did not. The assessments were also hard copy near point of use.
Jim Tassell  
#6 Posted : 15 August 2011 16:46:53(UTC)
Rank: Forum user
Jim Tassell

Wow - better quality thread than many! 20. I hesitate to add this, but from a user's point of view, please keep it simple!
moonpool  
#7 Posted : 16 August 2011 12:50:52(UTC)
Rank: Forum user
moonpool

Afternoon Cuttell80003, There is some really good info in the above threads and all points certainly need to be considered. I am in a similar position to yourself and I have a wealth of research and templates for your disposal. PM me your email and I will forward onto you. Now that you are conducting this review it would be prudent during this phase to collect all the data to comply with REACH. Also with the new GHS (Global Harmonised System) system coming into play, symbols are changing and MSDS (SDS’s) materials will have to be authorised for the way you use them. I.e. Acetylene may be registered as a welding gas onshore; if you are offshore you can’t use it. My approach would be: 1) COSHH Review Plan (Chemical Control, Pre – Authorisation, CMS, training, etc) 2) COSHH Procedure including Policy 3) Generate a CMS (Chemical Management System) this should include an MSDS library. 4) COSHH Assessments by department (High – Low) 5) A system that allows the mapping and tracking of revision (CMS again) Get in touch and I can give you some pretty cost effective solutions that will keep you compliant with COSHH, EH40, REACH and changes associated with GHS once tailored to your organisation. Were are entering an era were companies have to consider more than just the requirements off COSHH I am afraid ;0) Regards Kev
GTM  
#8 Posted : 16 August 2011 13:41:54(UTC)
Rank: Forum user
GTM

Concur with all of that; had the very same task to perform at my place of work and definitely start on the principles of control, I had at least a dozen hazardous substances struck off and replaced with less hazardous alternatives. Yes too, the assessment has to take account of the product AND its application, I have some applications that differ for the same substance, direct liquid concentrate application V's diluted aerosol spray bottle application, separate assessment for each obviously. Get your supply, storage, uses and disposal lines clearly defined in your Policy Document, the assessment should be structured with due regard to your work place, sounds obvious but often overlooked, it's quite pointless declaring on an assessment "dispose of IAW SEPA Regulations" when the end user (reader) has no knowledge of those regulations, so assess your disposal methods relative to your site and keep the language easily understood e.g. - "dispose of via domestic skips on site" or "quarantine to on site hazardous waste container for disposal via local council hazardous waste collection site". You will probably have a huge catalogue of suppliers that will have to issue you with an appropriate MSDS, but did you know that any item sold at B&Q has an MSDS to download free, just go to the website and follow the link to the H&S page, COSHH/MSDS, punch in the number that appears below the Bar Code and presto, PDF format MSDS; its good for those lesser items that constantly appear on site no? Also Screwfix, similar deal; for real!
Jim Tassell  
#9 Posted : 16 August 2011 14:27:11(UTC)
Rank: Forum user
Jim Tassell

Just a query, bearing in mind posts 7 and 8. Why do we persist in keeping libraries of safety data sheets (whether in paper or electronic form) when at any one time several are likely to be out of date? Why not just put links into your documentation that go straight to the suppliers? And another point, why chase around at all for most domestic cleaning products which hover just about on the border of COSHH (and Reach?) when conc. and probably fall out when dilute? What's wrong with the simple exhortation to do as it says on the label?
moonpool  
#10 Posted : 16 August 2011 15:39:50(UTC)
Rank: Forum user
moonpool

Jim Tassell wrote:
Just a query, bearing in mind posts 7 and 8. Why do we persist in keeping libraries of safety data sheets (whether in paper or electronic form) when at any one time several are likely to be out of date? Why not just put links into your documentation that go straight to the suppliers? And another point, why chase around at all for most domestic cleaning products which hover just about on the border of COSHH (and Reach?) when conc. and probably fall out when dilute? What's wrong with the simple exhortation to do as it says on the label?
Hi Jim, Links are fine, and this could be me being old fashioned - but what if an incident occurs and computers, electricity, internet, website are lost. E.g - an acetylene bottle is on fire already - in the decomposing state, are you going to tell somebody to log in and get the info rather than muster away from the danger zone with the information readily available? The fire service or ambulance etc may need a hard copy due to this scenerio, to ensure the right antidote or fire fighting method is correct! I have spoken with DSEAR - PFEER experts on this very matter and electronic copies of these documents is fine, if you have considered the "What if's", which is near on impossible to overcome without hard copies. There is no border on COSHH materials, if it is deemed hazardous regardless of what it's application then an assessment must be carried out. REACH could see the restrictions of materials that are not hazardous in any way - the hazardous agents involved in the manufacturer may become banned rendering the non-hazard item "no longer available"... hence the chemical and business risks surrounding COSHH, REACH, EH40, CHIP-GHS all need to be considered. Regards Kev P.S Those simple labels will be a thing of the past soon as well, as those labels will be incorporating all the EU member state languages! Hence the need for a complete revision now, to save a repeat system review in few years time..
Jim Tassell  
#11 Posted : 16 August 2011 21:06:17(UTC)
Rank: Forum user
Jim Tassell

Thanks Kev. Can't resist responding. In reverse order - instructions in all EU languages.... YES!! It'll save a lot of hassle trying to inform cleaners who hail from the new parts of Europe. And for every user of acetylene these days, I hesitate to think how many cleaners there are. A big multiplier I suspect. Re acetylene "brewing up". It's probably not strictly a COSHH matter anyway but let's not go there now (and where's your flashback arrestor?). I bet your treasured library of data sheets will be inside the fire brigade's exclusion zone anyway. Most fire officers I've come across only trust what they get via their control rooms in such circumstances, pretty understandably I think. So, my money is that your hard copies won't be terribly useful. What's wrong with a smartphone? You could get all you want on it directly, outside the exclusion zone and maybe you'll be lucky and have a listening fire officer. See points 1,2,4,5 and 10 above as well. Regards Jim
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