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HSE_Steve  
#1 Posted : 08 August 2013 09:30:23(UTC)
Rank: Forum user
HSE_Steve

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.
chris.packham  
#2 Posted : 08 August 2013 09:55:33(UTC)
Rank: Super forum user
chris.packham

Forget R40 as this is now being phased out. 1,4-Dichlorobenzene is classified under CLP as H351 - Suspected of causing cancer. However, the first question has to be at what concentration is this chemical in the product you are using. If it is there at just 2% then the SDS will show H351, or R40 in the old system. This not necessarily mean that the product itself represents a serious hazard. I had a case recently where the package label showed the symbol for irritant and this had been associated with a skin condition. However, on examination of the constituents it turned out that the hazard symbol only related to eye exposure, not skin. Next question would be what the potential for and extent of any exposure (actual or probable) would be? Apart from momentary contact when placing the blocks in a urinal, what is the likelihood of someone being in contact with the chemical? Another question would be whether the particular constituent is bioavailable. For example, stainless steel, which contains nickel, is not normally a problem for a nickel allergic person as no nickel molecules are being released. I had a case where an epoxy impregnated carbon fibre mat was being cited as the cause of an occupational allergic contact dermatitis. The epoxy contained >60% of a skin sensitiser (R43). However, our investigation showed that the release of this constituent was so minor that it could not have caused the skin problem (which turned out to be a non-occupational condition!). I hope that this helps. If you need more PM me. Chris
HSE_Steve  
#3 Posted : 08 August 2013 10:29:18(UTC)
Rank: Forum user
HSE_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.
JohnW  
#4 Posted : 08 August 2013 10:35:23(UTC)
Rank: Super forum user
JohnW

Chris, that is all good advice for Steve, but I expect may confuse. There is this new Regulation on classification, labelling and packaging ("CLP Regulation") which will change phrases and classification, but seems like Steve has a situation where the current MSDS, or the software that generates it, comes up with phrase R40 and he may need to explain what it means to medical staff. Steve, I've had to explain these phrases in toolbox talks etc and well, I try not to worry people. I might be wrong to say so but I have said R40 means there are no cases of humans developing cancer with this substance. There's another phrase R45 'may cause cancer' again I've said it 'likely' means there are no cases of humans developing cancer with this substance, but has maybe caused results in tests on cells or animals. Labelling, pictograms, phrases are all changing. Right now I have an issue with toxicity in some raw materials which used to say 'Toxic' with a skull/crossbones, now there is a 'chest' pictogram suggests 'serious long term health hazards'......
chris.packham  
#5 Posted : 08 August 2013 11:03:43(UTC)
Rank: Super forum user
chris.packham

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
JohnW  
#6 Posted : 08 August 2013 11:22:18(UTC)
Rank: Super forum user
JohnW

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
JohnW  
#7 Posted : 08 August 2013 11:23:38(UTC)
Rank: Super forum user
JohnW

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
chris.packham  
#8 Posted : 08 August 2013 11:47:58(UTC)
Rank: Super forum user
chris.packham

John The whole COSHH, CHIP, REACH, CLP situation is a bit of a nightmare! I see many safety data sheets with a combination of hazard data that simply do not help, but confuse. I also see exposure scenarios that have been written by people who do not appear to have any first hand knowledge of how the particular product will be used. In any event, REACH only deals with individual substances and not mixtures, which are what I am usually confronted with. I have seen safety data sheets with 6 pages of MSDS plus in excess of 50 pages of exposure scenarios (none of which sometimes apply to what my clients is going to do with the product). I have difficulty in interpreting these, so I wonder what the small employer does. (Actually, I think I have a good idea as to that!). Chris
jay  
#9 Posted : 08 August 2013 12:59:17(UTC)
Rank: Super forum user
jay

HSE_Steve wrote:
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.
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).
JohnW  
#10 Posted : 08 August 2013 14:56:48(UTC)
Rank: Super forum user
JohnW

Jay, you are correct with regard to Steve's initial concern with, say, A&E staff looking at his MSDS; they would only be concerned with acute hazards. In their efforts to get the patient up and walking they would disregard R40 and long term hazards like cancer. The discussion here did go on to matters/confusions with the new CLP/CHiP pictograms and statements/phrases. In your list of acute hazards you did mention 'Toxic' and indeed the new 'Toxic' pictogram, I believe, is only used where the substance might be swallowed, and so the CLP 'Toxic' hazard would indeed be something that an A&E department would want to deal with. The new CLP pictogram with the 'chest' symbol, as I call it, I think deals with longer term hazards as a result of skin or repiratory exposure, likely this would be ignored by A&E but they would refer the patient to his GP? JohnW
HSE_Steve  
#11 Posted : 08 August 2013 15:58:13(UTC)
Rank: Forum user
HSE_Steve

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.
JohnW  
#12 Posted : 08 August 2013 17:22:49(UTC)
Rank: Super forum user
JohnW

I said above
JohnW wrote:
the new 'Toxic' pictogram, I believe, is only used where the substance might be swallowed
That is not true, I just mis-interpreted what it says in an indg. I've just downloaded a fuller explanation of pictograms and statements; that will be my future reference :o)
Steve e ashton  
#13 Posted : 09 August 2013 10:20:37(UTC)
Rank: Super forum user
Steve e ashton

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...
Barrie(Badger)Etter  
#14 Posted : 09 August 2013 11:31:03(UTC)
Rank: Super forum user
Barrie(Badger)Etter

chris.packham wrote:
Forget R40 as this is now being phased out. Chris
Hi Chris, Along with your comment saying the R phrases are to be phased out, why is it that I'm seeing H, Pmodified R phrases on various web sites when I check for the latest information? Badger
JohnW  
#15 Posted : 09 August 2013 22:35:43(UTC)
Rank: Super forum user
JohnW

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
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