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jorge.tunon  
#1 Posted : 05 July 2015 06:22:52(UTC)
Rank: New forum user
jorge.tunon

Hi, I am in the process of review several RA. When you evaluate a product using the SDS, do you use only Section 2 for the substance or (to be more conservative) you also use the R (H when applicable) phrases of the components in Section 3?
chris.packham  
#2 Posted : 05 July 2015 07:39:21(UTC)
Rank: Super forum user
chris.packham

Should you even be using the safety data sheet for a COSHH risk assessment? Consider what is now in the latest ACoP for COSHH. 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. and 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. and 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 This is further covered in paragraph 35, which states: When deciding whether the substances used or produced in the workplace are covered by COSHH, employers should also consider the following: 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. On the basis of this I contend that a risk assessment for COSHH has to start with the task, then identify what chemicals are used during the task and what happens to them when they are used. You can then identify the real hazard. Furthermore, there are thousands of chemicals that have never been assigned a hazard statement but that in use can represent a hazard to health (note the comment in the ACoP on wet work). In his latest edition of his guide to patch testing de Groot lists 4350 substances known to dermatologists as skin sensitiser, only a small fraction of which will ever have been assigned R43/H317. In my work I see numerous risk assessments based on the safety data sheet that are simple wrong because they have not identified the real hazard. Chris
jorge.tunon  
#3 Posted : 05 July 2015 08:01:51(UTC)
Rank: New forum user
jorge.tunon

Chris, Thanks for your great answer. Of course I am evaluating what are the tasks, who does it, quantities used, chemical stock, etc. (although limited by the proprietary software that my company asks me to use) I know a SDS is not a Risk Assessment, but it is a useful source of information, that's why I am doing the RA and not just file a bunch of MSDS as I have seen before. My question is that if section 2 states the dangers of the mixture (as received, not as used) or some of the risk of the individual components stated in section 3 may be applicable. What I assume from your answer is that those stated in section 3 of the individual components might be present depending on the 'use conditions' or at least is more conservative to evaluate them as they were whenever not enough information to rule them out. Am I right?
chris.packham  
#4 Posted : 05 July 2015 10:52:51(UTC)
Rank: Super forum user
chris.packham

Jorge The problem is that the safety data sheet does not really tell you what the real hazard is and can mislead. I had a case of supposed occupational allergic contact dermatitis to a sensitiser in an epoxy impregnated carbon fibre mat. The sensitiser (tetraglycidyl methyldianiline - R43) made up 63% of the epoxy impregnant. However, when we tested the material the TGMDA was not bioavailable and was therefore not the cause of the employees dermatitis. So the risk assessment did not need to show this as a hazard for the task in question. However, in another part of the plant the mat was softened using a solvent. As a result the TGMDA became bioavailable and thus a significant hazard requiring quite different control measures. Same product, different hazards. Would you be able to recognise this from the data on the safety data sheet? In any event, the safety data sheet is not a reliable indicator of what you have. A study by the European Chemicals Agency (ECHA), the organisation responsible for REACH, found that of 1,181 companies they inspected in 29 countries, mostly ‘downstream users’, i.e. formulators, regarding compliance with REACH, 52% were producing safety data sheets described in the study as ‘deficient’. ECHA – REACH-EN-FORCE2 The HSE has actually cautioned its inspectors about using the safety data sheet as a reliable source of product hazard data. Chris
chris.packham  
#5 Posted : 05 July 2015 10:58:33(UTC)
Rank: Super forum user
chris.packham

As an afterthought - what about all those constituents that, having no hazard statement assigned to them, will not be shown on the safety data sheet, but could be the cause of, or contribute to, a health hazard? The reality is that the consumer actually received more effective information, in that the package will contain a list of constituents. In theory, at least, they can then reach an informed decision as to the safety of the product for them. This is essential if, for example, they are allergic to one of the constituents (which might not be on your safety sheet!). I tend to go back to the supplier and request information to meet section 6-1 of the Health and Safety at Work Act 1974. This is, in my view, much more what is required from the supplier (who probably will never have heard of it and might well not have the expertise to comply - but that is another story!). Chris
jay  
#6 Posted : 05 July 2015 11:57:10(UTC)
Rank: Super forum user
jay

While it is true that SDSs' have varying information, we have to recognise that the classification of substances & mixtures is not to the degree of perfection, but based on current toxicological etc. data, knowledge & expertise, of which skin is a part but not the only one. It is indeed in Section 2 of the SDS that has a heading "Hazards identification" i.e. the hazard statements pertaining to the mixture/preparation are included and they should be the key ones to consider. For mixtures/preparations, Section 3 gives composition/information on ingredients I very much doubt that using SDS & H statement and other information in from SDS's is a flawed process as long as you recognise the COSHH Principles of good control practice. The HSE's COSHH e-Tool uses the H-Statements as one of the key aspects for a limited range of activities/operations. http://www.hse.gov.uk/ch...-classification-work.htm
jorge.tunon  
#7 Posted : 05 July 2015 12:02:48(UTC)
Rank: New forum user
jorge.tunon

For example, one of the products I have to assess is Rocor NB Liquid. Section 2 only states: R25 Toxic if swallowed and R60 May impair fertility. However its individual components are: Sodium tetraborate (1-2%): R60, R61 Sodium Nitrite (10-30%): R8, R25, R50 Benzothiazole-2-thiol (0.1-0.2%): R43, R50/53. Does all this porperties "get lost"once combined so the only risk are the ones stated on section 2? or the might still be present (as I believe). Very interesting point in your previous point Chris. Thanks for all your good advice.
chris.packham  
#8 Posted : 05 July 2015 13:59:53(UTC)
Rank: Super forum user
chris.packham

Jay "...so they should be the key ones to consider" What if the product does not contain any chemicals that have been allocated a hazard statement, or if, as a result, the supplier does not supply a safety data sheet? Does this mean you can ignore the potential for the chemical to cause damage to health? In my work I see many situations where damage to health has occurred as a result of exposure to a chemical that has not been assigned a hazard statement/risk phrase. Chris
jorge.tunon  
#9 Posted : 05 July 2015 14:13:58(UTC)
Rank: New forum user
jorge.tunon

Well, If we don't have the MSDS we need to get rid of the product. We do not have a single chemical, from soap to degreasers without SDS. I can't do research on all the components or the mix. Therefore I need to trust the information provided in the MSDS. 'grinding dust' is something we consider, but in the hot work RA, not in the COSHH, where we include chemicals (in a broad sense). I do not say is the best thing to do. There is always room for improvement.
chris.packham  
#10 Posted : 05 July 2015 15:05:57(UTC)
Rank: Super forum user
chris.packham

So what do you do about water then. Wet work, i.e. exposure to water, is the most common cause of occupational contact dermatitis. Do you insist on a safety data sheet for water, and would it indicate water as an irritant? Yet for the dermatologist water has long been recognised as an irritant. "An irritant is defined as any agent, physical or chemical, capable of producing cell damage. Everything can be an irritant if applied for sufficient time and in sufficient concentration. Water, being the most abundant element of the skin, is usually regarded as banal and gentle. However, the irritancy of water is beyond doubt." - From Dermatotoxicology, second edition, Zhai H, Maibach HI, CRC Press Chris
Kate  
#11 Posted : 06 July 2015 15:56:58(UTC)
Rank: Super forum user
Kate

In the first instance you use the hazard statements in section 2. Sometimes however you may need to delve in to Section 3, for example if the mixture is very nasty, it may be relevant to find out which components of it are making it so nasty as that may affect the exposure routes.
chris.packham  
#12 Posted : 06 July 2015 17:36:48(UTC)
Rank: Super forum user
chris.packham

An additional consideration is whether any one of the constituents is bioavailable. For example stainless steel will contain both chrome and nickel, two potent sensitisers. However, since they would not normally be bioavailable they present virtually no real hazard. Of course, should your process cause one or both of them to become bioavailable, then you have a real hazard to contend with. So the fact that your product may contain one or more 'nasties' does not mean automatically that these require special control measures. Another consideration is whether the product could contain something that changes in use. For example, a machinist allergic to formaldehyde reacted to a metalworking fluid where there was no mention of formaldehyde on the safety data sheet. The fluid did contain a biocide, but this was not per se formaldehyde. It was, however, what is known as a formaldehyde releaser, i.e. in use it changed and formaldehyde was released into the fluid, hence causing the allergic reaction. Chris
hilary  
#13 Posted : 07 July 2015 12:55:43(UTC)
Rank: Super forum user
hilary

Hi Jorge I use Section 2 and the R(H) phrases as well. However, if there is a constituent that looks a bit dodgy then I will put the CAS number into Google and have a deeper look at that individual component. Obviously this all goes along with the percentage in the product, how it's used, by whom, frequency, control measures etc and so on, but knowing your chemicals and doing a little bit of extra research won't go amiss. There are always going to be circumstances that are unique to your business environment. For example, we get asked a lot for paints containing microcrystalline silica which is no problem as this is in suspension and, therefore, non respirable........ however, 10 years down the line our product needs repair and some bright spark uses a grinder to remove the paint - suddenly we have a very real hazard issue of airborne silica and the risk of silicosis. With cradle to grave responsibility we take this very seriously and refuse to use a greater concentration than 20% microcrystalline silica and then we issue warnings by email to the customer, in the manuals and on the products of the hazards of removing the paint by manual methods. Sometimes you just have to think outside the box at all the potential ramifications now and going forward.
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