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CdC  
#1 Posted : 13 March 2015 10:15:09(UTC)
Rank: Forum user
CdC

Hiya, We are an office and I am having a discussion with my team as to what items need COSHH. They want to include all items that fall under CHIP, even if they are not classed as officially Very toxic, Toxic, Harmful, Corrosive, Irritant, Sensitising, Carcinogenic Mutagenic, or Toxic to reproduction. The extra items would include hand sanitizers in bathrooms (flammable only as per chip), toners, liquid tip ex. But COSHH also requires an assessment for any chemicals if they are not deemed as above but their use may be harmful to health. I am arguing though that the extra items in their current use do not justify COSHH. And we are not full of vulnerable people who need supervision and would drink the stuff and abuse.... It's not alarp. What's your thoughts on this?
chris.packham  
#2 Posted : 13 March 2015 10:28:58(UTC)
Rank: Super forum user
chris.packham

You have a PM Chris
CdC  
#3 Posted : 13 March 2015 10:41:48(UTC)
Rank: Forum user
CdC

Sorry... still thinking about this: From the COSHH ACOP: "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." Hand sanitizer in the bathrooms???
chris.packham  
#4 Posted : 13 March 2015 11:44:24(UTC)
Rank: Super forum user
chris.packham

Hand santiser in the bathroom? It could be if they were to drink it! Not joking. This is an issue with patients in the NHS with mental problems! Chris
CdC  
#5 Posted : 13 March 2015 11:46:14(UTC)
Rank: Forum user
CdC

chris.packham wrote:
Hand santiser in the bathroom? It could be if they were to drink it! Not joking. This is an issue with patients in the NHS with mental problems! Chris
Hi Chris, but we are an office and don't work with vulnerable people.
chris.packham  
#6 Posted : 13 March 2015 12:22:51(UTC)
Rank: Super forum user
chris.packham

I think this is my point. For you it will not be an issue, but in a hospital, particularly one that has mentally ill patients, it could be. It is all about the circumstances surrounding the chemical that determines whether it is hazardous or not. It is what happens to the chemical in the workplace that matters. Chris
Ian Bell  
#7 Posted : 13 March 2015 12:30:05(UTC)
Rank: Super forum user
Ian Bell

Reading between the lines on this - it seems to be essentially domestic cleaning products and in the same amounts as found in a domestic situation. Sounds to me as you/your people need to follow the instructions on the label. Thats about the limit of CoSHH applicability. CHIP is no longer used. I am assuming that this is a genuine query/post?
Gav81  
#8 Posted : 13 March 2015 12:33:40(UTC)
Rank: Forum user
Gav81

I would put together a register of everything you have in a table. Get Safety Data Sheets for each product, and make an assessment of how each is used. (this initial assessment doesn't necessarily need to be documented, its just an evaluation of the hazardous nature of the product and how you use it) Have a column in the register, COSHH Assessment needed Y/N or similar. This shows that you have evaluated each product and made a decision to carry out a further assessment based on the use of the product and the risk to employees. You will find that surprisingly, there shouldn't be many to do, because of the way you use the product
Ron Hunter  
#9 Posted : 13 March 2015 13:03:06(UTC)
Rank: Super forum user
Ron Hunter

Gav81: We mustn't request "safety data sheets" for products that don't need one. Over the years, the supply chain has succumbed to repeated requests for SDS by customers for products whcih are not hazardous. The misguided then take this SDS as a prompt to create "COSHH assessments" for soaps, pencils, and all sorts of nonsense.
A Kurdziel  
#10 Posted : 13 March 2015 13:46:33(UTC)
Rank: Super forum user
A Kurdziel

You do need COSHH risk assessment but it need not be anything complicated. Essentially it will consist of a list of potentially hazardous substances such as cleaning products with a check to make sure that staff only use them in accordance to manufacturers’ instructions.( eg not mixing them or not using PPE) Remember that some ‘cleaning products’ are quite hazardous, for example some commercial drain cleaners contain sulphuric acid.
CdC  
#11 Posted : 13 March 2015 14:00:18(UTC)
Rank: Forum user
CdC

Thank you for all your posts. We are not even talking about cleaning products, as these are covered by the COSHH from our cleaning contractors. These are the items: Hand sanitizers liquid TipEx Toners Dishwashing tabs (we produced a COSHH for this one, as irritant) And yes, this is a serious post, not a troll.
A Kurdziel  
#12 Posted : 13 March 2015 14:26:20(UTC)
Rank: Super forum user
A Kurdziel

If these are the only substances that you are concerned about: Hand sanitizers liquid TipEx Toners Then the COSHH assessment should say something along the lines "potentially harmful- only use in accordance with manufacturers' instructions". If you really want you could bulk out to cover one side of A4!
Ron Hunter  
#13 Posted : 13 March 2015 14:46:38(UTC)
Rank: Super forum user
Ron Hunter

On the subject of toner, carbon black is an excellent conductor. If there is a spillage, you don't want to use an ordinary vacuum or Henry! There's also a risk of creating an explosive mixture.
Gav81  
#14 Posted : 13 March 2015 16:04:58(UTC)
Rank: Forum user
Gav81

Ron Hunter wrote:
Gav81: We mustn't request "safety data sheets" for products that don't need one. Over the years, the supply chain has succumbed to repeated requests for SDS by customers for products whcih are not hazardous. The misguided then take this SDS as a prompt to create "COSHH assessments" for soaps, pencils, and all sorts of nonsense.
Ron, I didn't state that you should request SDS for products that don't require one. I thought that would actually be understood without the need to stipulate that, as we are all safety professionals. I really goes without saying that you don't need an SDS for a pencil and to suggest that would be insulting everyone's intelligence!
Ron Hunter  
#15 Posted : 13 March 2015 16:13:52(UTC)
Rank: Super forum user
Ron Hunter

No slight intended Gav81. This is a public Forum though, and not everyone knows the ropes. COSHH Assessment for using a pencil/ bar of soap, etc: I came across these specific assessments in my own Organisation. The repsonsible person in one of our divisions had spent a small fortune on and external health and safety consultant to "do" the COSHH Assessments.......................
Gav81  
#16 Posted : 13 March 2015 16:19:52(UTC)
Rank: Forum user
Gav81

No problem Ron, understood. I imagine the consultant was getting paid per COSHH assessment, so carried them out for everything they could think of. Doing an assessment for a pencil is absolutely ridiculous. It's prats like that, that give H&S a bad name.
jodieclark1510  
#17 Posted : 13 March 2015 16:22:24(UTC)
Rank: Super forum user
jodieclark1510

Personally I would say yes to toner, no to sanitizer and tipex
jay  
#18 Posted : 13 March 2015 16:30:25(UTC)
Rank: Super forum user
jay

Most modern laser printers/copiers have cartridge tyoe toners, therefore the key consideration is to site the equipment in a well ventilated area--( for ozone dilution/extraction) and what to do if someone mamages to spill the toner--most unlikely foir cartridge type toners that cannot be refilled by lay users. The key aspect of COSHH is also what is the route of exposure and the probaility of that exposure occuring
Ian Bell  
#19 Posted : 13 March 2015 17:13:47(UTC)
Rank: Super forum user
Ian Bell

Mountains out of mole hills starting to appear, by the look of things. As previous - read the product labels/instructions, and leave it at that.
paul-ps  
#20 Posted : 16 March 2015 16:26:38(UTC)
Rank: Forum user
paul-ps

chris.packham wrote:
Hand santiser in the bathroom? It could be if they were to drink it! Not joking. This is an issue with patients in the NHS with mental problems! Chris
Would water also be assessed as they could drink huge amounts and flood their organs, causing death???
Animax01  
#21 Posted : 17 March 2015 09:16:59(UTC)
Rank: Super forum user
Animax01

I went to a seminar recently at the Babraham institute where Jane Blunt and another gentleman (who's name I don't recall) gave a speech on COSHH and it's application. A very similar debate ensued in the seminar, it wasn't that heated but it was a little awkward. It's all about the assessment, if the risk is perceivable, document it and make suitable arrangements.
chris.packham  
#22 Posted : 17 March 2015 10:09:41(UTC)
Rank: Super forum user
chris.packham

My comment regarding drinking the hand sanitizer was not intended to be taken too seriously. Equally with regard to drinking too much water as unless this was a task requirement it would not be occupational and therefore not part of COSHH. This issue is not the chemical but what we do with it and, as a result, the possible consequences. So for Tippex unless one was using vast amounts in a confined space, where the solvent vapour might be an issue, the risk is almost non-existent. With the carbon black toner again, unless there is a risk of extensive exposure, which, given the cartridge type that one normally finds, then the risk is only if someone breaks the cartridge. The risk then could dictate specific actions for clearing up the spillage. There might be a slight risk if the internal surfaces of the machine had to be cleaned, but this can be done with minimal exposure, so no significant risk provided that the appropriate method is defined and adhered to. Incidentally, with copier toner on the skin wash only in cold to lukewarm water as heat may 'fix' the toner to the skin and this is then almost impossible to remove. Chris
jay  
#23 Posted : 17 March 2015 11:28:11(UTC)
Rank: Super forum user
jay

Animax01 wrote:
I went to a seminar recently at the Babraham institute where Jane Blunt and another gentleman (who's name I don't recall) gave a speech on COSHH and it's application. A very similar debate ensued in the seminar, it wasn't that heated but it was a little awkward. It's all about the assessment, if the risk is perceivable, document it and make suitable arrangements.
Risk perception varies and therefore, if we were to document all "perceivable" risks, that may include trivial risks. For Laboratory environments where a whole range of chemical hazards are present and therefore risks ( and sometimes with a transient user community) , it may be a pragmatic approach to evaluate chemical health risks, classify them , say, low/medium/high risks and have proportionate documentation/controls. The key operating term is "proportionate"
paul-ps  
#24 Posted : 17 March 2015 16:28:26(UTC)
Rank: Forum user
paul-ps

paul-ps wrote:
chris.packham wrote:
Hand santiser in the bathroom? It could be if they were to drink it! Not joking. This is an issue with patients in the NHS with mental problems! Chris
Would water also be assessed as they could drink huge amounts and flood their organs, causing death???
I think thats where the difficulties arise with COSHH. You would likely feel that an assessment for the hand sanitiser would be necessary in such an environment, although not an actual occupational risk.
Littlebeeches  
#25 Posted : 02 June 2015 12:49:35(UTC)
Rank: New forum user
Littlebeeches

This topic will always be a subject with those who decide it to be 'trivial' and those who take it too far. The subject of cleaning gear being trivial is a case in point. It cannot be dismissed that when certain cleaning products are mixed they have the potential to kill. In my previous employment, I had an individual who without malice who thought he was doing the right thing, was removing damaged cleaning products, pouring the contents into the same bucket and then disposing of it down the drain, with little environmental or health and safety considerations. Without conducting and recording an assessment, how can you truly know what the effects these products will have? I am amazed by the attitude of some key players both on this forum and out in the manufacturing world, who give such scant regard to this topic. I have recently tried to get MSDS datasheets from 3 major suppliers of cleaning products whose MSDS have on receipt been woefully poor, the information serves no purpose, to the extent that it did not even relate to the chemicals actually contained within the product. (According to the label on the product).. But it appears that in the eyes of some of the contributors to this forum this is ok as it is only 'cleaning products'... But is it? Those individuals who have been exposed to chemicals and have suffered from work related dermatitis know too well the effects of being given the wrong advice. I think we need to get back to why we as H&S Managers are employed as such and ensure that our members of staff are protected by ensuring that the relevant information required to undertake their roles is available to the best of our ability as opposed to finding ways of not doing our jobs.
chris.packham  
#26 Posted : 03 June 2015 20:48:28(UTC)
Rank: Super forum user
chris.packham

If you have not already done so, first read the relevant sections of the sixth edition of the ACoP for COSHH, specifically the section on risk assessment. At long last the HSE has moved away from the concept that the risk assessment can be based on what is in the safety data sheet. The risk assessment has to be based on the real chemical hazard that is present when the chemical(s) are used for a particular task. So risk assessment has to be task based not chemical based. There is no such thing as a 'good' or 'bad' chemical; it all depends upon how it is used. Hydrofluoric acid can cause major trauma, i.e. in contact with the skin is 'bad'; however, in certain industries it performs extremely useful purposes, i.e. is 'good'. To approach this from another direction, you have your workers wearing chemical protective gloves for most of their working shift, i.e. the gloves are there to protect. However, all occlusive gloves will cause damage to the skin, reducing its ability for some considerable time after the gloves have been removed to actually properly protect the person. So you eliminate damage to health due to the chemicals but cause damage to health due to the gloves (hydration dermatitis). Where do you stand then if it comes to a prosecution or compensation claim? I take the view that each and every task must be risk assessed. Of course, with many the risk assessment is quick and simple as the risk will be minimal. However, you might be surprised how often you come across a risk that needs appropriate action, even though the chemical itself might not even qualify for a safety data sheet. Chris
jodieclark1510  
#27 Posted : 04 June 2015 00:00:41(UTC)
Rank: Super forum user
jodieclark1510

Littlebeeches wrote:
This topic will always be a subject with those who decide it to be 'trivial' and those who take it too far. The subject of cleaning gear being trivial is a case in point. It cannot be dismissed that when certain cleaning products are mixed they have the potential to kill. In my previous employment, I had an individual who without malice who thought he was doing the right thing, was removing damaged cleaning products, pouring the contents into the same bucket and then disposing of it down the drain, with little environmental or health and safety considerations. Without conducting and recording an assessment, how can you truly know what the effects these products will have? I am amazed by the attitude of some key players both on this forum and out in the manufacturing world, who give such scant regard to this topic. I have recently tried to get MSDS datasheets from 3 major suppliers of cleaning products whose MSDS have on receipt been woefully poor, the information serves no purpose, to the extent that it did not even relate to the chemicals actually contained within the product. (According to the label on the product).. But it appears that in the eyes of some of the contributors to this forum this is ok as it is only 'cleaning products'... But is it? Those individuals who have been exposed to chemicals and have suffered from work related dermatitis know too well the effects of being given the wrong advice. I think we need to get back to why we as H&S Managers are employed as such and ensure that our members of staff are protected by ensuring that the relevant information required to undertake their roles is available to the best of our ability as opposed to finding ways of not doing our jobs.
I agree. As a cleaner and sufferer of dermatitis in a previous job role often the cleaners are forgotten, and are often faced with comments such as we use bleach at home and that's not a problem. But as you say it's the mixing and potential extended contact time that can make it hard to deal with. I am all for COSHH and feel it should reflect what's going on in that environment. Washing up liquid for example to rinse a few bits isn't a big concern, but continuous use and potentially being on your hands for long periods can cause problems.
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