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Evans38004  
#1 Posted : 14 October 2014 12:52:33(UTC)
Rank: Forum user
Evans38004

We have workers that work with chlorine gas - perfectly sealed, no known leaks in 20+ years.

Suitable rescue BA sets available etc.

Well managed / engineered system.

Employees have been provide with pre-employment medical, including lung-function test before they start their work and then every 3 years thereafter.

Recently changed OH provider (external) and they are now insisting that the workers get a lung-function test every 6 months as chlorine is a know sensitizer - as per legislation.

My query is which regulation?
Ian Bell  
#2 Posted : 14 October 2014 13:24:13(UTC)
Rank: Super forum user
Ian Bell

CoSHH Regs will give the general requirements for assessing hazardous material, including health assessments.

For more specific info, what does the current version of EH/40 say and the associated WEL data?
Jane Blunt  
#3 Posted : 14 October 2014 13:54:42(UTC)
Rank: Super forum user
Jane Blunt

I would ask them where they got the information from as to the potential for sensitisation. An MSDS from a well known chemical supplier lists the following:

Signal word: Danger

Hazard statement(s)
H270 May cause or intensify fire; oxidiser.
H280 Contains gas under pressure; may explode if heated.
H315 Causes skin irritation.
H319 Causes serious eye irritation.
H331 Toxic if inhaled.
H335 May cause respiratory irritation.
H410 Very toxic to aquatic life with long lasting effects.

Precautionary statement(s)
P220 Keep/Store away from clothing/ combustible materials.
P261 Avoid breathing gas.
P273 Avoid release to the environment.
P305 + P351 + P338
IF IN EYES: Rinse cautiously with water for several minutes. Remove
contact lenses, if present and easy to do. Continue rinsing.
P311Call a POISON CENTER or doctor/ physician.
P410 + P403
Protect from sunlight. Store in a well-ventilated place.

Roundtuit  
#4 Posted : 14 October 2014 14:32:12(UTC)
Rank: Super forum user
Roundtuit

The regulation would be CoSHH.

EH40 2011 did adjust the Short Term Exposure Limit for Chlorine.

In the ECHA web site under "Information on Chemicals" there are 5 registrations for Chlorine with one a full submission - under both the GHS and DPD classifications for Health Hazard "Respiratory Sensitiser" data is listed as "conclusive but not sufficient for classification".

So there is research indicating potential but there would be nothing definitively published for a lung function check at 6 month intervals - ask your provider for the specific lines from the regulation.

I do have a respiratory sensitiser at site - our OH Lung Function screening is each employee every 12 months however the provider attends twice a year so that we can fit in the necessary appointments and follow up if anyone is down with a cold / hay-fever etc.. on their scheduled appointment day

MSDS have R & S phrases / SDS have H & P phrases
Roundtuit  
#5 Posted : 14 October 2014 14:32:12(UTC)
Rank: Super forum user
Roundtuit

The regulation would be CoSHH.

EH40 2011 did adjust the Short Term Exposure Limit for Chlorine.

In the ECHA web site under "Information on Chemicals" there are 5 registrations for Chlorine with one a full submission - under both the GHS and DPD classifications for Health Hazard "Respiratory Sensitiser" data is listed as "conclusive but not sufficient for classification".

So there is research indicating potential but there would be nothing definitively published for a lung function check at 6 month intervals - ask your provider for the specific lines from the regulation.

I do have a respiratory sensitiser at site - our OH Lung Function screening is each employee every 12 months however the provider attends twice a year so that we can fit in the necessary appointments and follow up if anyone is down with a cold / hay-fever etc.. on their scheduled appointment day

MSDS have R & S phrases / SDS have H & P phrases
A Kurdziel  
#6 Posted : 14 October 2014 14:46:00(UTC)
Rank: Super forum user
A Kurdziel

Unless there was actual evidence of exposure to chlorine gas I would not expect staff to undergo any sort of lung function test. Chlorine from at I remember has serve acute effects but limited evidence of any sort of long term effects( which is what the lung function tests are supposed to test for)
You need to ask their criteria for these tests. These should derive from the requirements of reg 10(Monitoring exposure at the workplace) and 11 of COSHH(Health surveillance) and in particular what it says in the ACOP.
Jane Blunt  
#7 Posted : 14 October 2014 15:11:24(UTC)
Rank: Super forum user
Jane Blunt

Chlorine is lethal - it was used in the First World War. See https://en.wikipedia.org...l_weapons_in_World_War_I

Survivors could be left with long term effects. I used to know someone who had been over-exposed and he had both breathing and speech problems.
pl53  
#8 Posted : 14 October 2014 15:16:18(UTC)
Rank: Super forum user
pl53

I have experience of managing respiratory sensitisers, specifically subtilisin enzymes used in the detergent industry. The problem with sensitisers is that even very small amounts of exposure can result in sensitisation, and it can happen at any time. A person can be exposed for years without any effect and then suddenly become sensitised, or he/she can become sensitised after one brief exposure. Lung function testing would indicate any loss of lung function but would not be a definitive indicator of sensitisation. The method in the detergent industry for checking for sensitisation is the use of 6 monthly skin prick testing. This would not be appropriate for chlorine but maybe urology would. Lung function testing could support this regime but definitely would not replace it.
PH2  
#9 Posted : 14 October 2014 15:49:24(UTC)
Rank: Super forum user
PH2

It should not be a sensitiser as the employees are using full breathing apparatus (presumably positive pressure). They would only be inhaling the Chlorine if (1) there was a leak in the Chlorine system and (2) the employees wer either not wearing or incorrectly wearing their BA kit.

I would ask your OH provider to explain how, under tightly controlled conditions normally associated with Chlorine work, they consider it to be a sensitiser.

PH2
A Kurdziel  
#10 Posted : 14 October 2014 16:06:39(UTC)
Rank: Super forum user
A Kurdziel

Having re-read my post what I meant to say was that chlorine gas does not seem to have any cumulative effects ie the health effects from a small amount of gas does not build up over time. The main issue with chlorine is it’s acute ( potentially very serious ) effects. Lung function test would not on the face of it provide anything useful in relation to controlling the exposure to chlorine gas. What you would need is atmospheric monitoring and a robust system to control leaks.
leadbelly  
#11 Posted : 14 October 2014 16:21:15(UTC)
Rank: Super forum user
leadbelly

PH2

Whether a substance is a sensitiser does not depend on the control measures in use; it is an inherent property of the substance.

The control measures may control the risk of sensitisation in particular circumstances.

LB
PH2  
#12 Posted : 14 October 2014 16:54:06(UTC)
Rank: Super forum user
PH2

Hi Leadbelly,
Agree about the nature of sensitisers, but Chlorine is not one of them: it is a respiratory irritant, albeit a very nasty one.

Employees that I have worked with and who have accidently, (but very briefly) cracked open a valve on a Chlorine cylinder never need to be told again to wear BA when changing cylinders in the future.

PH2
leadbelly  
#13 Posted : 14 October 2014 17:55:44(UTC)
Rank: Super forum user
leadbelly

I agree about the health effect but that was not the point I was making.

LB
johnmurray  
#14 Posted : 15 October 2014 13:20:43(UTC)
Rank: Super forum user
johnmurray

Have fun.
Full lung function tests are unpleasant and expensive.
jay  
#15 Posted : 15 October 2014 15:39:46(UTC)
Rank: Super forum user
jay

As per GHS/CLP Classifications, Chlorine has H 335 (STOT SE 3) meaning it has specific target organ toxicity due to single exposure, but at category 3 which is the lowest category ( least effect) and the target organ is the lungs.
KD  
#16 Posted : 17 October 2014 16:15:48(UTC)
Rank: Forum user
kd

I would suggest, if you have recently changed OH provider and the new provider thinks Cl2 is a respiratory sensitizer, you should probably change to an OH provider that knows what they are talking about.

From what you have written, it seems you understand Cl2 really quite well.

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