I am getting more frequently asked for COSHH assessments for non hazardous items (Section 3 MSDS). Now we all know that using section 3 of the MSDS is not the be all and end all of whether a COSHH assessment is required but for things such as paint and filler (for which the average person would not get dressed up in full body armour with RPE to do over the weekend to do a bit of decorating), used in low quantities (5 ltr tins) is a COSHH assessment really called for?

Ive been asked for a specific COSHH assessment for using 5ltr vinyl matt paint (because of the hazards identified on the MSDS such as "eye and skin irritation from paint".

The person asking for COSHH assessments would "expect to see" an assessment to identify quantities used, location used, specific PPE such as RPE and eye protection, storage details and emergency spillage procedures!

Following the COSHH guidance in the Acop L6 (listing substances which pose little risk) is not good enough for this fella, now ive got to spend Monday doing a pointless paper filling in exercise.

I might just do a COSHH assesment for tap water as this has the potential hazard for skin irritation and we all know water has the potential to drown people!

Thanks for the advice, I agree, tried that, he is adamant individual COSHH assessments!

The training and competency by the way would be can you read the label and do what it says on the tin!

Instead of arguing the toss why not just do the COSHH assessment, it may take less time?

I do agree it would be OTT but if the DATA sheet will not siffice just appease him/her.

Firstly, according to COSHH any substance can become a substance hazardous to health:

“(e) 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” - COSHH regulation 2(1)

If you ignore those substances that do not have risk phrases (and therefore will not appear on the safety data sheet) then what might you be missing?

You mention paint. I have had several instances where a water based paint has caused both respiratory and skin reactions, due to the release of the preservative (methylchloroisothiazolinone/methylisothiazolinone) days after the paint had actually dried. No mention of this on the safety data sheet, yet most water based paints will contain a preservative that is actually a skin sensitiser and can elicit a reaction at a level that is below that where mention on the safety data sheet is required (even assuming that the sensitiser has been allocated a risk phrase, which several have not).

Secondly, a risk assessment is about the task and the use of the chemicals. Water is a skin irritant, but only a very mild one. However, excessive exposure to water can result in irritant contact dermatitis. So in my view for chemical exposure you have to start with what is being done using a chemical. Then consider whether as a result the chemical represents a hazard 'as used'. This will involve any changes in the chemical (or chemicals in combination) due to the process and whether as a result of the resulting hazard and the exposure there is a significant risk of damage to health.

It has been my experience over many years that it is not usually the really hazardous chemical that results in the skin disease, since the employer and user tend to be aware of the hazard. It is those substances that are considered non-hazardous and thus have been ignored or only cursorily assesed that end up causing the occupational contact dermatitis. Perhaps this explains why wet work, i.e. exposure to water, is one of the most common causes of occupational contact dermatitis.

So, as you will probably have gathered, I do not consider the request entirely unreasonable.

Chris

The primary issue here is perhaps down to suppliers bowing to customer pressure in the first instance and producing SDS for non-hazardous products?
There is often this self-perpetuation of inappropriate msds>COSHH assessment which can at worst obscure the attention needed for real workplace hazardous products.
Bounce back a sheaf of "COSHH Assessments" with the control measure "follow manufacturer's instructions printed on container as supplied" - it may prevent other spurious requests?
Have a word with your procurement people - make sure they aren't requesting/insisting on spurious MSDS?

Chris Packham has recently assisted me in assessing substances used by a hairdresser, mostly for chemicals the the average sane person would not put anywhere near a human scalp, and there was the issue of WATER which if exposed to for long periods, as Chris says can cause occupational dermatitis.

After that experience I would recommend listening to what Chris says as he does know what he is talking about.

Send him a pm I did - it'll cost you nothing and may help you, it certainly did help me.

I advise that you never undertake a risk assessment on your own - it is a team exercise

I do not know what your IOSH status is but I would recommend that you educate any person who wants any form of risk assessment with regards to just what a risk assessment is and the principals behind suitable and significant, reasonably practicable etc.

If we re-read the COSHH masters posts AKA Chris - COSHH must be specific to task. A downloaded 'assessment' is not suitable and sufficient.

To further reinforce what Chris says, I happen to have an MSDS on my desk for a Dulux water based paint. It carries the following R phrase.

R66 Repeated exposure may cause skin dryness or cracking

This now clearly places it into COSHH! Argument over?


N.B. They also appear to think it's flammable? hmmmm gotta love MSDS.

teh_boy

I file MSDS under "Works of fiction"! So many that I see are incorrect or misleading. Several studies have reached the same conclusion. Last year I went through 50 MSDS with a client and only one was accurate in all respects! I even had four from different suppliers for the same substance that did not agree on the risk phrases (and none complied with the Approved List)!

I have a collection of MSDS that I have acquired over the years. They make interesting reading, such as the "Non-solvent cleaner", the major constituent of which was a hydrocarbon solvent, or the metalworking fluid that claimed: "Non-hazardous, will provide full protection against any dermatological problem". Presumably with the latter if I have dermatitis and put my hands into this fluid the skin disease will disappear! Actually the dermatologist and I identified this fluid as the cause of the skin disease!

One of my concerns is that relatively few people appear to challenge MSDS, or possibly are not sufficiently well trained to be able to identify where the data sheet is obviously inadequate, or just plain wrong! I would like to see someone like IOSH produce a guide on this to help those who need to be able to interpret the MSDS.

Chris

I sometimes get quite sad at the fact that we can't even agree on the basics.

Think I'll leave it there.

I advise that legally you have to show that you have carried out a risk assessment and when you have and it come out as low then at least your employer and the employee can be assured that all principles of Sch 2 COSHH regs has been applied. Of course its not the just risk assessment its the implementation that is critcal to any assessment and often gets lost in the mist. A quick way of completing this task is to use HSE COSHH Essentials tool along with your own RA format. This is very quick, but remember that the HSE tool is only part of a full assessment.

Anything will burn given the right circumstances. If you doubt that just put the paint in a pan/bucket on a high heat and stand back, fire blanket and foam extinguisher at the ready.

yeah - but they use the term flammable as defined in CHIP (n.b. Flammable is not applicable under COSHH) - I doubt this is true of a water based substances - combustible maybe - flammable???

In all seriousness it appears they have used the same MSDS for solvent based and water based and the editor got bored before section 16, as everything else is correct.

This is from a leading manufacturer!

But on the other hand is it R.P. to prevent skin contact, educate the guys on how clean and protect their skin and educate them on the signs and symptoms of skin problems????

Chris, I'm trying to be sensible here...giving me a lecture on allergic/ sensitising nuances is not really very helpful.

I think I will join Claire and leave this topic whilst I still have some sanity and humour.

Zoltangera,

You really are in between a rock & a hard place as you say that " I will end up doing them in any case as if I don't my company will not get the work..."!

This is now probably academic as you were going to complete the assessment today, but this is a common problem when organisations/individuals probably don't really understand what they are asking for, & more importantly why.

I do understand where some of the previous posters are coming from as it is too easy to quote the Regs. or the advice from the HSE, i.e. a hazardous substance is: "a) which is listed in Table 3.2 of part 3 Annex VI of the CLP Regulation and for which an indication of danger specified for the substance is very toxic, toxic, harmful, corrosive or irritant."

You are unfortunately being pressurised into doing something that, in my opinion, does not warrant a COSHH Assessment & it's not what the original legislation intended to address.

I'm beginning to lose the will to live reading all that has preceded on this topic...
I see no problem with doing a single process based COSHH Assessment, e.g. painting, listing all the paints which are covered by that assessment (include the filler too if that's part of the job.

As far as I'm concerned, the argument "for which the average person would not get dressed up in full body armour with RPE to do over the weekend to do a bit of decorating" is one of the core issues with much H&S legislation. Doing something at home for a morning is a whole different ball game to doing the same thing at work every day.

A few years ago, at my wife's place of work, they were doing some surface treatment of woodwork with a very low VOC water based varnish/lacquer. My wife got a reaction that closed her eyes up! it took a second occurrence the following day for it to be confirmed as the varnish that was causing it.

That was a totally non-hazardous item as far as anyone was concerned at the time.

I also have to agree with those previous posters who have questioned the value of some MSDS. It can be entertaining to check the same product/manufacturer MSDS for different countries, e.g. UK, Canada, USA. You'd be forgiven for thinking they were totally different products half the time.

I would say, check the MSDS, then double check the data on the MSDS, and do a COSHH Assessment of the results, giving consideration to the degree of exposure during the working day/week.

As I asked Chris, how would you have carried out a COSHH assessment before your wife used the varnish....would you have stipulated her to be suited and booted with full RPE? We know what happened after the event, how should it have been approached before the use of the varnish?

i agree it always ends with my dads bigger than your dad

Yes DNT, I have an example of a soap MSDS too that says that, and I can understand that precaution if there is prolonged handling of bars of DRY soap. But for a short duration washing of hands and rinsing with water then gloves not required - that is what the COSHH sheet should say!