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Dudz  
#1 Posted : 08 January 2013 09:47:26(UTC)
Rank: Forum user
Dudz

Hi folks, I need a sanity check please. How do other people manage to ensure they have sufficient COSHH information for users at point of use? We have a diverse number of chemicals based on site, and true to form the suppliers change their MSDS information on a regular basis. We manage to maintain our COSHH database however we are struggling to ensure all users of chemicals are kept abreast of the COSHH information. For the bulk chemicals its not such an issue, as we keep that information up to date and on site. However, how do we control Joe Bloggs who has just booked three aerosols of solvent cleaner out of Stores? I don't want to have to give him a copy of the COSHH sheet everytime he picks up a new can.
Kate  
#2 Posted : 08 January 2013 10:29:44(UTC)
Rank: Super forum user
Kate

What do you mean by COSHH sheet? The msds / hazard information for the substance, or a summary of the COSHH assessment setting out the required precautions for the task? All that Joe needs to know is how to do his cleaning task safely, not the detailed information about each product. If you look at it that way, it becomes a lot easier for everyone.
Dudz  
#3 Posted : 08 January 2013 10:46:51(UTC)
Rank: Forum user
Dudz

Apologies, I didn't make myself quite clear. The actual COSHH assessment - which in our case, does give specific information on how to undertake a task involving the chemical in question. We keep all MSDS information centrally and generate a COSHH assessment from that.
Kate  
#4 Posted : 08 January 2013 11:08:50(UTC)
Rank: Super forum user
Kate

Are the COSHH assessments organised by chemical (covering multiple tasks if relevant), or by task (covering multiple chemicals if relevant)? The second way often makes them easier to communicate on the basis of identifying who does those tasks.
HSSnail  
#5 Posted : 08 January 2013 11:22:24(UTC)
Rank: Super forum user
HSSnail

Does a change in the Data sheet actually alter the COSHH assessment? Your controls may still be valid so you will not need to change anything at the coal face. If the medical treatment has altered then clearly your need to ensure that the current data sheet accompanies any casualty should the worst case scenario occur. If the assessment has changed resulting in a fundamental change in the safe system of work needed then what clearly the staff will need the relevant information and possibly retraining. What's your normal procedure for changing systems of work?
chris.packham  
#6 Posted : 08 January 2013 11:25:56(UTC)
Rank: Super forum user
chris.packham

Kate is correct. What the employee needs to know is how to carry out the task correctly and safely and what to do in an emergency. The risk assessment for COSHH is your document that allows you to determine, so far as chemical hazards are concerned, what procedure is acceptable, including any measures such as PPE. If there is a change in a safety data sheet, then you will need to revisit the risk assessment to see if any changes in the work procedure are needed, and if so, communicate these to the employee.
james fleming  
#7 Posted : 08 January 2013 11:28:41(UTC)
Rank: Forum user
james fleming

If Joe Bloggs pops into the stores for the three aerosols of solvent cleaner why not have a folder at the stores with COSHH RAs in them. Joe rocks up. Asks for Product X. The store man hands over the risk assessment for Joe to read and sign. Any special equipment pertaining to control measures are handed out then. A WPT is then carried out on COSSH / Risk Assessments etc.
KAJ Safe  
#8 Posted : 08 January 2013 11:55:57(UTC)
Rank: Forum user
KAJ Safe

If a coshh assessment highlights measures such as PPE, isn't this already included on the msds or am I getting confused.
james fleming  
#9 Posted : 08 January 2013 12:01:33(UTC)
Rank: Forum user
james fleming

KAJ safe wrote:
If a coshh assessment highlights measures such as PPE, isn't this already included on the msds or am I getting confused.
Control measures, such as PPE, are included on the MSDS. However, a MSDS on its own must not be used as a Risk Assessment.
A Kurdziel  
#10 Posted : 08 January 2013 12:07:15(UTC)
Rank: Super forum user
A Kurdziel

I think some people have gotten a bit confused here. This might be due to the malign influence from the states. In the US they do not carry out COSHH assessments instead workers have copies of the MSDS displayed at the workplace. Some American owned firms have brought this practice over the pond but it is not necessary in UK law. What the employee needs is a set of work instruction (call it an SOP or method statement if you wish) that tell how to do the job safely. These should be based on the risk assessment (which might include COSHH) with information about the hazard information associated with substances coming from the MSDS (amongst other sources). I still here of people doing COSHH assessments for substances but this is the wrong approach. What you should be doing is looking at the risks from the use of the substances ie it should be task based.
damelcfc  
#11 Posted : 08 January 2013 12:18:28(UTC)
Rank: Super forum user
damelcfc

A Kurdziel - spot on. The MSDS alone is useless - This information is put together without knowing how YOU actually use the substance and in what quantities and where! Do you pour/decant/spray/bath/swim in it? 5/10/15/20 litres at a time Inside/outside Your TASK has all the answers.
Kate  
#12 Posted : 08 January 2013 12:37:25(UTC)
Rank: Super forum user
Kate

I've seen msds for things like salt that list full PPE (body, foot, hand, eye and respiratory protection, the lot). If your task is to wade about in a huge pile of salt then the PPE you decide on in your COSHH assessment may possibly match the PPE on the msds. If your task is to measure out very precisely a few grammes of salt and dissolve them in water then your COSHH assessment, if you feel it is necessary to record one, won't have any PPE in it at all. The controls in the COSHH assessment supersede the ones on the msds. For this reason, giving out the msds can actually cause confusion due to the contradictory statements.
chris.packham  
#13 Posted : 08 January 2013 13:10:19(UTC)
Rank: Super forum user
chris.packham

To comment on a previous posting, you would be very unwise to rely on the information on PPE on a safety data sheet. In my experience, particularly with gloves, this is almost always inadequate and often completely wrong. In any event, it is completely irrelevant. As others have already commented, the PPE that is really required will depend upon the nature of the real chemical hazard that arises when the chemical is used and the actual, or potential, level of exposure. In some cases the specific chemical may require a full, category III glove used for only a short period, in others protection for the same chemical may be adequate using only a category I glove as splash protection. It all depends. I worry that with COSHH the emphasis seems to be on the word 'substances' rather than on 'control'. Yet what COSHH is about is controlling exposure such that the potential for damage to health can be 'adequately controlled'. Given the emphasis on control, it should be obvious that it is the task and how to carry this out safely that should be the information provided for the employee. Different tasks may require different procedures and different control measures (PPE, etc.).
Ron Hunter  
#14 Posted : 08 January 2013 23:10:43(UTC)
Rank: Super forum user
Ron Hunter

You reference "point of use" (OP), but discuss point of issue (stores). Irrespective of any piece of paper, the requirement is to provide suitable, sufficient and comprehensible information, instruction and (where appropriate) training and supervision to ensure safe use, storage, transport and disposal. A system which relies on employees signing to say they have "read and understood" can fall well short of these requirements, and often a meaningless and pointless exercise.
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