Hi everyone, wonder if you can help

I'm writing a COSHH assessment for some urinal blocks, I've got the SDS and it contains the Risk Phrase, R40 - Limited evidence of a carcinogenic effect.

Further down the SDS, in Section 11 - Toxicological Information it states that the product 'Does not contain any substances known to be carcinogenic'.

1,4-Dichlorobenzene is the active ingredient, and EH40 doesn't class it as carcinogenic, so what does R40 actually mean? These things are used up and down the country without huge controls, and members of the public come into contact with them so they cant be too bad . . .

One of my concerns is that I keep a folder in the first aid cabinet with every COSHH assessment and SDS we have, in case of an accident the first aider can take this folder with them to hospital to help the medical staff appraise the situation - if staff see the word Carcinogen, in any context they are going to be worried.

Thanks in advance.
Steve.

Thanks Chris, thats great.

I see, H351 is also on the SDS as you said.

Exposure would be extremely limited, a couple of seconds every other day and the operative would be wearing disposable gloves as well.

I'm quite satisified the risk is low with this one, but in more general terms is there any way for a non-scientist or specialist to know the level of bioavailability of a certain substance?

Thanks again Chris for taking the time to help, much appreciated.

John

Point taken. Another area for confusion is that whilst at the moment the supplier is supposed to show both classifications on the safety data sheet, with some chemicals they do not agree. I have several substances that I quote when training where the hazards shown under CHIP differ from those shown under CLP.

Incidentally, I also have a list of several substances known to dermatologists as common skin sensitisers, to the extent that they feature in the lists of sensitisers for specific occupations, but that have never been classified as R43 (and also do not feature as H317).

Steve

Given the level of exposure that you describe I doubt whether you have much to be concerned about, unless some individual decides to chew on one! But then, as a quality inspector once said to me many, many years ago: "You can make it fool proof. What you can't do is make it b....y idiot proof."

Chris

Chris, thanks for that.

I'm in receipt of some recently revised MSDSs which now only show the NEW pictograms in section 2, and lists the H and P statements, then just below in section 3 the ingredient hazard information has just the old R and S phrases - you have to look up section 16 for their meaning..... The pictograms include the 'chest' image while the package text says Toxic...... This is an msds for pure 2-ethoxyethanol which is present in many paints but also sometimes used neat as an additive.

Using such substances can be done safely. As you say not idiot proof, but there's also the 'freak' accident situations like a spill or a small explosion which leads to operators inadverently ingesting substances, and in that situation someone like Steve then has difficulty knowing what is the risk to that operator.

Steve hope we are being of some assistance here, as Chris said you probably have little to worry about in normal usage situations.

John

For emergency response & treatment, trained nurses/health professionals would generally NOT be worried by CHRONIC health hazards of chemical materials that have varying categories such as carcinogens as their effects are due to long term exposure. The response personnel would be concerned about the more ACUTE health hazards such as Toxic, Corrosives, Sensitisers, either by inhalation or by contact with skin etc.

Both the CHIP and CLP classification is based on threshoold levels in mixtures if the material being handles is not a pure substance.

Therefore, it is possibe to have, in an MSDS for a mixture, a constituent that has a particular risk phrase in Section 3 that does not appear in the actual classification which is NOW for the REACH compliant MSDSs in Section 2.

R40 is used when it is a category 3 carcinogen.
What it means is that these are substances which cause concern for humans owing to "possible carcinogenic effects, but in respect of which the available information is not adequate for making a satisfactory assessment. There is some evidence from appropriate animal studies, but this is insufficient to place the substance in Category 2.

Therefore, in the first instance, is the R40 in Section 2 or is it in Section 3?

Secondly, COSHH defines a carcinogen as a substance or preparation (ie a mixture or solution of two or more substances) which either:
(a) is classified for labelling purposes as carcinogenic category 1 or 2 carrying the risk phrases R45 ‘May cause cancer’, or R49 ‘May cause cancer by inhalation’; or
(b) would be so classified if the European system for classifying substances and preparations dangerous for supply was applied (even if the law does not require this, as with certain pharmaceutical products or by-products such as hardwood dust).

Thanks everyone.

re. A&E, I understand they certainly wouldn't be interested in chronic effects, my point was that I keep a copy of ALL our COSHH assessments in there to avoid confusion, and staff members could well see the word Carcinogen and be (quite rightly) concerned.

An interesting point from this, kind of an aside but still a good learning point - I saw this risk phrase and got fixated on it, forgetting the first (second?) rule, substitution. Quick google search, plenty of these urinal cakes out there which are specifically marketed as being free from 1-4, Dichlorobenzene so we'll get some of these, hopefully they are just as effective, or at least effective enough.

Thanks for all the comments, I've certainly learnt some things for next time when perhaps substitution isn't available.

thanks
Steve.

Some years ago my (very) young nephew ate and swallowed four or five of the 'pineapple chunk' type urinal toilet sanitiser blocks. His mother rushed him to hospital where they advised against any medical intervention. He was perfectly well (apart from reportedly having particularly foamy pee for a few days) and has grown into a fine upstanding (6ft 4in upstanding) young man...

Badger, we are still in a transition stage, the indg that I referred to above explains:

Substances
1 December 2010 – 1 June 2015 : suppliers must classify substances according to both CHIP and CLP, and they must label and package according to CLP.
1 June 2015 onwards: uppliers must classify, label and package substances according to CLP.

Preparations or mixtures
20 January 2009 – 1 June 2015 : suppliers must classify preparations according to CHIP, and may continue to label and package them according to regulations 6 to 11 of CHIP.
As an alternative, they may choose to classify, label and package mixtures according to CLP. In this case, they must, in addition, continue to classify under regulation 4 of CHIP, but the requirements on labelling and packaging in regulations 6 to 11 of CHIP no longer apply.
1 June 2015 onwards : uppliers must classify, label and package according to CLP.

Clear as mud!!


JohnW