Rank: Forum user
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Hello,
if a supplier doesn't actually label a substance as a Irritant but just says that is could have health effect, such as itchy eyes etc..
That is not a hazard classification, is that correct.
Thanks for your confirmation,
katie
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Rank: Super forum user
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Katie,
Where does the supplier state it could have a health effect such as itchy eyes?? Is it in the MSDS, label or both and under what heading?
Essentially, and thereofore you are correct that the health hazard classification is based on threshold levels.
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Rank: Super forum user
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Lots of things can cause irritation without being classified as irritants - so this is perfectly possible.
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Rank: Super forum user
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One of the problems with Safety Data Sheets is that they are written for CHIP, not COSHH. They are only required to list those constituents that have been allocated a Risk or Safety Phrase (and now Hazard Statement under CLP). There are literally thousands of chemicals that do not have such a phrase allocated to them but that can cause damage to health. For example, if you consult the list of common sensitisers for which suppliers provide materials for patch testing to dermatology clinics you will find several of these that have not been classified as R43 and therefore are unlikely to appear on the safety data sheer.
Indeed the ACoP for COSHH confirms this. Paragraph 13 states: "Many commonly supplied substances, classified in one or more ways described above, are listed in Part I of the Approved Supply List: Information approved for the classification and labelling of substances and preparations dangerous for supply. However, that document should not be regarded as a complete listing of chemicals covered by COSHH as it deals only with substances subject to CHIP and even then omits many substances and all preparations."
As it happens, the chemical that is the most common cause of occupational contact dermatitis is water (wet work). Water is recognised as a skin irritant by dermatologists, yet is frequently overlooked by those carrying out COSHH risk assessments. Incidentally, wearing occlusive gloves for any length of time has the same effect as skin exposure to water, plus the hyperhydration of the skin causes physiological changes that result in the skin becoming excessively dry once the gloves are removed.
Finally consider Regulation 2(1) which includes the following definition of a substance hazardous to health as " (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." This definition means that almost any chemical under certain circumstances could become a substance hazardous to health.
So in answer to your original question, what your supplier is stating is a description of a hazard, just not one as defined in the Approved List (or now according to CLP).
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