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chris42  
#1 Posted : 22 August 2014 09:45:45(UTC)
Rank: Super forum user
chris42

I'm due to review / do the company's COSHH assessments, and yesterday I thought I would try the HSE COSHH essentials. I was a little under whelmed by the output. It does seem to be intended for small / medium size organisations, so I did keep this in mind, but considered it quite unhelpful.

I thought I would put something easy into it - engine oil for topping up company cars. Obviously entered task duration etc and the "R" codes, and it decided that it was middle of the range for nastiness and pointed me to some leaflets on PPE etc. So really nothing that useful, for instance the PPE leaflet had a line drawing of a man in full protective overall with hood, visor, gloves and safety boots and no specific advice for this substance.

Ok I only did it out of curiosity, but what I entered would have been the same for a owner mechanic of a back street garage with say two employees, who would not have a clue what to do next. I'm ok with R code meanings, I'm happy looking at EH40 and say glove manufacturers glove data ( I can sort of guess Chris.P's comments, but it is all us mortals have to go on). The guy in the back street garage would be struggling, probably panic at the picture on the PPE sheet and would just end up employing someone else to do it ( therefore COSHH Essentials would be a complete waste of time).

What are others views on this, do you use them get the output and job done; use them as a starting point; or do you see little benefit and just go straight to doing your own.

Chris
chris.packham  
#2 Posted : 22 August 2014 10:20:32(UTC)
Rank: Super forum user
chris.packham

Moderators

My response should have gone as a PM. I inadvertently posted it to the open forum. Can you please remove it for me.

Many thanks
Chris
Dazzling Puddock  
#3 Posted : 22 August 2014 10:30:56(UTC)
Rank: Forum user
Dazzling Puddock


I think you are vastly underestimating the knowledge of a mechanic if you think he would not have a clue what to provide to his employees for transferring synthetic motor oil.

The HSE guidance on PPE linked to by COSHH Essentials is simply that,guidance on PPE, it is not specific to any particular chemical or process and uses the word appropriate many times.
jay  
#4 Posted : 22 August 2014 12:22:11(UTC)
Rank: Super forum user
jay

COSHH Essentials is based on a tried & tested concept of "Control Banding". If interested, there is guidance on the "technical basis of COSHH Essentials"

http://www.coshh-essenti....uk/assets/live/CETB.pdf

It does require input of the correct info and reading of some of the introduction etc.

As such, this tool or its equivalent have been adopted internationally and HSE has been in the forefront of compiling this tool!

The following are what some of the reputed national & international Occupational /Industrial Hygiene bodies think of this concept


http://www.bohs.org/StandardCopyPage.aspx?id=915#

http://www.ioha.net/controlbanding.html

https://www.aiha.org/get...nding-Working-Group.aspx

http://www.ccohs.ca/osha...als/control_banding.html

http://www.ilo.org/legac...rl_banding/practools.pdf

http://en.wikipedia.org/wiki/Control_banding
chris.packham  
#5 Posted : 22 August 2014 13:41:49(UTC)
Rank: Super forum user
chris.packham

Having looked at the guidance on COSHH essentials I am concerned that it still appears to rely largely on the hazard data as indicated by risk phrases or hazard statements. For skin exposure this is not acceptable, since the hazards that a chemical represents will almost always change as the chemical is used for the purpose for which it was purchased.

The sixth edition of the ACoP for COSHH recognises this.

Paragraph 10
Employers should regard a substance as hazardous to health if it is hazardous in the form in which it may occur in the work activity. A substance hazardous to health need not be just a chemical compound, it can also include mixtures of compounds, micro-organisms or natural materials, such as flour, stone or wood dust.

and

Paragraph 74
Where a work activity may expose employees to more than one substance hazardous to health, the employer must consider the possible enhanced harmful effects of combined or sequential exposures.

Paragraph 57
The risk assessment should consider the work activity, including:
all the substances hazardous to health (including biological agents, and simple asphyxiants) arising from the work (used, produced, synthesised, created as waste or by-products, or released from processes or during accidents, incidents and emergencies);
work done by sub-contractors, at the workplace, that may exposure employees to substances hazardous to health.

Paragraph 67
It may be necessary to collect information on the properties and attributes of substances hazardous to health from a variety of sources to fully inform the assessment process
Different forms of a substance may present different hazards, eg substances may not be hazardous in solid form but may be hazardous when ground into fine powder or dust that can be breathed into the lungs.
Nanoparticles (ie particles less than 100 nanometers) may be more toxic than larger particles of the same chemical substance.
Impurities in a substance can make it more hazardous, eg crystalline silica is often present in minerals which would otherwise present little or no hazard.
Some substances have a fibrous form which may present a potentially serious risk to health if the fibres are of a certain size or shape.
Some substances have a known health effect but the mechanism causing it is unknown, eg certain dusts of textile raw materials cause byssinosis.
Exposure to two or more substances at the same time or one after the other may have an added or synergistic effect.
Epidemiological or other data, eg reports of illness due to new and emerging agents, indicate that a biological agent that does not already appear in The Approved List of biological agents could nevertheless cause a hazard to health.
One-off, emergency situations arising out of the work activity, such as a dangerous chemical reaction or fire, could foreseeably produce a substance hazardous to health.
‘Wet work’ is one of the most frequently and consistently reported causes of irritant occupational contact dermatitis. ‘Wet work’ is the term used to describe tasks involving prolonged or frequent contact with water, particularly in combination with soaps and detergents.

Perhaps I am missing something, but I see nothing in COSHH essentials that incorporates these particular factors. Perhaps, also, this is why I see many risk assessments for skin exposure that do not reflect the real risk.

Chris
chris42  
#6 Posted : 22 August 2014 20:49:13(UTC)
Rank: Super forum user
chris42

I meant no offence to mechanics, just an example. However only recently there was a thread on this site about mechanics gloves, so not all may find it so straight forward. I'm sure most go for the ubiquitous blue single use nitrial, but I suspect these get used for more chemicals than they should (just my opinion). I think I was hoping the site would have been a bit more specific about the actual type of glove required etc, rather than a go away and think about PPE sheet.

I read one of the linked articles about the bands and that seems fair enough to rank your assessments. Its just after going through it I felt you then had to go away and actually do the assessment, so struggled to see the value. I guess others do.

I agree the COSHH Essentials seemed to be based mostly on the risk phrases. I was mildly amused when it suggested that I should consider replacing the engine oil with a paste ! ( they are obviously aware of cars I had in my youth)

Chris's original post (removed) and the last one did provide food for thought regarding the training adequacy from the NEBOSH Dip. I don,t know about others, but for gloves it was suggested that you consider the breakthrough times of glove manufacturers. However as Chris P has pointed out many times on different threads, there is more to it than this.

So do we all need to go on further courses before undertaking COSHH assessments. Will tools like the COSHH Essentials never be sophisticated enough to take everything needed into account? So many questions so little discussion.

Chris
Jane Blunt  
#7 Posted : 22 August 2014 21:35:15(UTC)
Rank: Super forum user
Jane Blunt

COSHH essentials definitely has its limitations, but it is an attempt to try to give the simple COSHH assessment some validity. It has a filter for the more dangerous chemicals.

Glove breakthrough times are specific to the chemical/glove combination. Since there are hundreds of thousands of chemicals we cannot expect specific advice in the COSHH essential documentation. You do need to make some enquiries before choosing a material.

Even when you have found a suitable glove, I would still not trust it. Gloves can have holes in them.

More training might help. However in the case of chemicals that are filtered out as more hazardous, you may need an experienced chemist to be able to unravel what the MSDS really means and how dangerous the chemical really is, in the circumstances in which you are using it.

chris.packham  
#8 Posted : 22 August 2014 22:15:15(UTC)
Rank: Super forum user
chris.packham

Jane

You are right about glove performance. It is far more complex than many realise. Indeed, when it comes to the 'official' test for permeation breakthrough time even the standard (EN374-3) states that this is for guidance and may not reflect what you will get in real use. This is just as well as the standard contains a significant flaw that could produce inaccurate results.

Some years ago I did a study together with Sunderland University. We developed a technique for measuring the performance of gloves under actual working conditions. The results bore little resemblance to the published performance date.

As an example, in one factory a nitrile glove was being used with xylene. Manufacturer's permeation breakthrough time to EN374-3 stated as 36 minutes. In one task we found no permeation breakthrough for 2 hours, in another (same glove, same solvent) just 5 minutes. And mixtures present a different issue. One manufacturer's glove states >24-0 minutes for each of toluene and MEK, but just 9 minutes when the two are mixed 1:1!

As a different example, methanol (not classified as a sensitiser) can be metabolised by enzymes in the skin. One of the metabolites is formaldehyde, a potent sensitiser. This will not be stated on the safety data sheet, of course.

I am a great believer in simplicity, but not at the risk of accuracy!

Chris
chris.packham  
#9 Posted : 22 August 2014 22:16:53(UTC)
Rank: Super forum user
chris.packham

Just to add to my posting, the British Occupational Hygiene Society have a proficiency module, P801, 'An introduction to the control of dermal exposure'. The syllabus covers some of these issues.

Chris
chris.packham  
#10 Posted : 23 August 2014 09:02:27(UTC)
Rank: Super forum user
chris.packham

Just noticed a typo in my last posting. It should, of course, read >240 minutes not 24-0!

Chris
jay  
#11 Posted : 26 August 2014 09:50:50(UTC)
Rank: Super forum user
jay

The risk phrases/hazard statements are based on classification thresholds and COSHH Essentials does take into account "how" the substances/mixtures including quantities and potential for inhalation exposure.

I accept that the skin is a complex tissue, but is also a robust barrier and by means of decent training in skin care and more so by the correct selection of gloves, PPE can be more easily used for skin protection compared to the much higher risks of exposure via inhalation. Last but not least. appropriate handling techniques can and do reduce the risk of skin contact. Whereever practicable gloves should only be used for accidental splash protection and disposable gloves discarded when contaminated. Wet working with gloves should be avoided.
chris.packham  
#12 Posted : 26 August 2014 11:45:22(UTC)
Rank: Super forum user
chris.packham

You say that skin is a ‘robust barrier’. In some respects this is true, but it is also a barrier that is very thin. Over most of the body the stratum corneum is only 0.01mm thick and this is where we find the barrier. It is easily penetrated by many chemicals. A study by the Health and Safety Laboratory found that skin exposure of one hand to methyl-pyrrolidone as a 15% solution in water for just 15 minutes was equivalent to 8 hours inhalation exposure at 10 mg/m3. Another study in an aerospace plant found that skin was the major route of uptake for methylene dianiline (Weiss T, Schuster H, et al.; Dermal uptake and excretion of 4,4’-Methylenedianiline during rotor blade production in helicopter industry – and intervention study; Ann.Occup.Hyg, 2011, 55, 8, 886-892 ). There are also studies showing that skin exposure to isocyanates can initiate an allergy to isocyanates. (e.g. Redlich C,.A., Skin Exposure and Asthma – Is There a Connection, Proc Am Thorac Soc. Vol.7, 2010 )

Just a few additional examples:

“Skin absorption can occur without being noticed by the employee and in some instances may be a more significant route than the respiratory system. This is particularly true for non-volatile chemicals that are hazardous and that remain on work surfaces for long periods of time.” - OSHA Technical Manual, Section II, Chapter 2

“Direct transdermal uptake from air is not routinely considered. Yet the studies outlined in the previous paragraph suggest that, for at least some indoor pollutants, direct dermal uptake from air may occur at rates that are comporable to or larger than inhalation uptake.” – Weschler CJ, Nazarofi WW, Dermal Uptake of Organic Vapors Commonly Found in Indoor Air, Environmental Science & Technology, 2014, 48, 1230-1237

“Air threshold limits are insufficient to prevent adverse health effects in the case of contact with substances with a high dermal absorption potential.” - Drexler H, Skin protection and percutaneous absorption of chemical hazards, Int. Arch Occup. Environ. Health (2003) 76:359-361

“In many instances dermal exposure is the principal route of exposure, especially for chemicals which are relatively non-volatile. For example, biological monitoring results of coke oven workers coupled with air monitoring of the employees’ exposure demonstrated that 51% of the average total dose of benzo[a]pyrene adsorbed by coke oven workers occurred via skin contact. Studies of employees in the rubber industry suggest that exposure to genotoxic chemicals present in the workplace is greater via the skin than via the lung.” - OSHA Technical Manual, Section II, Chapter 2

So concentration on inhalation exposure may not be sufficient. We need to keep in mind that it is the total dose reaching an organ that is important, irrespective of the route(s) of uptake.

Chris
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