Does the sds mention pulmonary oedema?

The CLP/GHS Hazard Statements, due to its proposed use globally, have internationally agreed terminology. That is why in many cases there is difference between the old Safety Phrases and new Hazard statements. H304 is about aspiration toxicity and there is only one category in this, i.e Category 1

The information in Section 4.2 is about about First-Aid measures--and such a accident scenario will depend upon how the chemical is used.

Therefore, if such a scenario is most unlikely i.e. ingesting it or it entering the airways, the risk is low.
You need to bear in mind that the same SDS is provided by the supplier, irrespective whether one is using 10 milliliteres or 10000 litres of the same chemical.


The classification guidance for substances "R65 Harmful: may cause lung damage if swallowed" is:-
Liquid substances and preparations presenting an aspiration hazard in humans because of their low viscosity:
(a) for substances and preparations containing aliphatic, alicyclic and aromatic hydrocarbons in a total concentration equal to or greater than 10% and having:
(i) a flow time of less than 30 seconds in a 3 mm ISO cup according to ISO 2431 relating to Paints and varnishes - Determination of flow time by use of flow cups,14 or
(ii) a kinematic viscosity measured by a calibrated glass capillary viscometer in accordance with ISO 3104/3105 of less than 7 x 10-6 m2/s at 40°C (ISO 3104, relating to Petroleum products - Transparent and opaque liquids - Determination of kinematic viscosity and calculation of dynamic viscosity15; ISO 3105, relating to Glass capillary kinematic viscometers - Specifications and operating instructions),16 or
(iii) a kinematic viscosity derived from measurements of rotational viscometry in accordance with ISO 321917 of less than 7 x 10-6 m2/s at 40°C;

Note that substances and preparations meeting these criteria need not be classified if they have a mean surface tension greater than 33 mN/m at 25°C as measured by the du Nouy tensiometer or by the test methods shown in Commission Regulation No 440/2008; or

(b) for substances and preparations based on practical experience in humans.


The classification for H304, "Hazard category for aspiration toxicity" for substances is;-
Category =Category 1

Criteria is:-
Substances known to cause human aspiration toxicity hazards or to be regarded as if they cause human aspiration toxicity hazard
A substance is classified in Category 1:
(a) based on reliable and good quality human evidence
or
(b) if it is a hydrocarbon and has a kinematic viscosity of 20,5 mm2/s or less, measured at
40 oC.
Note:
Substances in Category 1 include but are not limited to certain hydrocarbons, turpentine and pine oil.

There is an awful lot of people out there who (a) simply do not have the knowledge to interpret the data shown in the safety data sheet and (b) have not yet grasped the concept that the safety data sheet does not provide the information you need for a risk assessment for when you actually use the chemical. Nor is this a primary task for the safety data sheet. Recognising this REACH requires the supplier to provide Exposure Scenarios that should provide information so that you can use the chemical safely for a specific purpose. Presumably these will provide the necessary information when you mix the chemical with another, react it with another, contaminate it in the performance of a particular task, etc., etc. However, the very few Exposure Scenarios that I have seen raise doubts about how effective they really will be, particularly since these are provided by the manufacture of a specific substance for that substance and the end user may be dealing with a formulation containing several different substances, possibly from different manufacturers, each with their own Exposure Scenario for that task and their substance. The potential for confusion seems to me to be quite large!
Chris

Steve

If you don't have the required knowledge and experience, you should use a competent occupational hygienist (like me!). You can find a list of hygienists here: http://www.bohs.org/OHServices-directory/

Beware anyone who claims to be able to carry out a COSHH assessment without visiting the site and observing the tasks to be assessed.

LB

In my statement I was not intending to suggest that any one particular person would not be competent to carry out a risk assessment for COSHH, particularly where skin exposure might be an issue. It is all about competency and knowing your limits. Some situations will be very simple and not require much knowledge about chemicals and the skin. Others can be incredibly complex and test even my knowledge, requiring me to consult toxicological data and perhaps speak with a toxicologist.

As it happens many of our new clients only approach us when they have an existing skin issue and are seeking help to resolve this. In many cases I find that what they have done in order to prevent the skin issue has actually contributed to this, simply because they have not been aware of some of the complexities of how our skin interacts with the (working) environment.

We have a saying in house that: "The danger arises when you don't know that you don't know."

This is the issue for me in many cases. Just how much training on skin management is included in the NEBOSH diploma? You can actually qualify as an occupational hygienist without knowing anything much about the skin as the training does not include a mandatory module on skin management. And is the training correct? In a recent article published in a health and safety journal on the NEBOSH module there were several fundamental errors. Even the HSE website contains errors, such as the provision of single use natural rubber latex gloves for protection against solvents and thinners in a paint spray booth!

Chris