I will leave others to comment on exposure limits as for me, in my work with skin, they do not apply. With regard to skin health surveillance, the sixth edition of the COSHH ACoP is specific about the way in which the requirement, as contained within the regulations, should be interpreted. Paragraph 237, in particular, indicates where health surveillance is required. Examples where health surveillance is appropriate under the criteria in regulation 11(2)(b) are: where there have been previous cases of work-related ill health in the workforce/place; where there is reliance on PPE, eg gloves or respirators, as an exposure control measure; eg printers wearing gloves to protect against solvents used during press cleaning, or paint sprayers using two-pack paints wearing respirators to prevent asthma. Even with the closest supervision there is no guarantee that PPE will be effective at all times; where there is evidence of ill health in jobs within the industry; eg frequent or prolonged contact with water (termed ‘wet-working’) causing dermatitis in hairdressers and healthcare workers, or breathing in mists from chrome plating baths causing chrome ulcers in platers. Paragraph 238 amplifies this: This is not a definitive or exhaustive list and there will be many other instances where health surveillance is required. Employers will need to seek information or advice on the specific health risks identified in the risk assessment, or through any topic-specific HSE guidance, trade associations or other professional sources. Note that even though you believe that you have adequately controlled every aspect of your operation, should organisations with other similar operations have experienced health problems then you will need to have a very good argument if you do not also have health surveillance in place. If you need more on this feel free to PM me. Chris

It depends on the type of exposure. For example, laboratory workers are exposed to respiratory sensitizers (antigens)and these have no exposure limit, they all require surveillance.

EH40 whilst a useful reference is not the only source of information for workplace exposure limits. The manufacturers / suppliers Safety Data Sheet Section 8 may contain information not reflected in this particular HSE publication. You can also reference information by CAS number on the gestis database which provides international limits http://limitvalue.ifa.dguv.de/ more favourably this reference source also holds a DNEL (Derived No Effect Limit) which are becoming more prominent on Safety Data Sheets.

The specific requirements are covered in regulations 11 of the CoSHH Regs, but for a flavour; "Health surveillance shall be treated as being appropriate where- ...... the exposure of the employee to a substance hazardous to health is such that (i) an identifiable disease or adverse health effect may be related to the exposure So since cement dust can cause lung sensitisation and contact with unprotected skin can cause cement contact dermatitis I would say that you're in that category. The surveillance doesn't need to be onerous, skin check and lung function check at annual medical would probably suffice. An occupational health company would advise on that front.

Lots of useful advice here. However, to be sure that you are clear on the application of exposure limits, these only relate to inhalation exposure. There are no exposure limits for skin exposure. More than one study has shown that airborne exposure of a sensitising chemical at below the WEL can actually initiate a facial skin reaction in someone already sensitised. With cement it is entirely possible for someone to start to become sensitised on the first exposure. Sensitisation takes around 14 days and is asymptomatic, so that person will not be aware that this has happened. Then on the next exposure after sensitisation has occurred they might react with an allergic contact dermatitis. Note 'might'. It is common for someone to become sensitised and then never develop an allergic reaction, or possibly only on an exposure much (possibly years) later. In any event, with cement the far more common skin reaction is for an irritant contact dermatitis, almost always the result of repeated exposures to many different irritant chemicals (including water). In my opinion where skin exposure to any chemical occurs then skin health surveillance should be seriously considered. Chris

Health Surveillance is a generic term--refer to HSE Guidance:- http://www.hse.gov.uk/co.../basics/surveillance.htm http://www.hse.gov.uk/he...h-surveillance/index.htm