HSE website states that COSHH products in the shop that have been there before 1 June 2015, do not have to be recalled for re-labelling
and re-packaging with the new pictograms (This derogation is available until 1 June 2017)

Should companies COSHH assessments be showing the new or old pictograms now or can they remain without changing them until June 2017.

Most of the assessment I have recently seen have the old symbols and still refer to Risk and Safety Phrases.

If a manufacturer / supplier has changed their market information (product label / SDS) to reflect CLP then the firm should be changing their documented assessment to include the revised information.

CLP has new classification methodology, lower limits and new hazards attributed to substances (and mixtures containing them) which would not be reflected by relying upon old CHiP information

There is confusion here about the CLP and COSHH regs.

CLP are the Chemical Labelling and Packaging regs which bring the EU in line with the GHS system. They make suppliers of chemicals responsible for providing information to users of chemicals about the hazards substances pose in the form of labelling information which includes the GHS pictograms. Users need to look at this labelling and use the information from the labelling, the SDS and any other relevant information to create a suitable and sufficient risk assessment. This process is the legal requirement under COSHH in particular reg 6. The COSHH assessment does not need to include these pictograms or any other pictograms, it just needs to describe the hazards and to establish what risk it poses to users. This can then be used to create suitable controls.

Just because the pictograms have changed and the terms used are now a bit different between CHIP and CLP does not mean that the hazard has changed: the properties of the substance are the same.  

Just because the pictograms have changed and the terms used are now a bit different between CHIP and CLP does not mean that the hazard has changed: the properties of the substance are the same.  

The problem is the hazard CAN change under the new CLP system for the same substance based upon new supplier information and evaluation of submitted dossiers - e.g. nonylphenol a constituent of washing up liquid was considered benign, then attracted an environmental pollutant classification and is now on the candidate SVHC list.

Many quarries supply sand as non-hazardous, in the UK brick manufacturers fail to identify the presence of RCS in their product - then you look at a US pallet and GHS08 bronchial man is all over the labelling

Dare I mention Asbestos

If we are so concerned about pictograms, i.e. a pictorial indication of a Hazard Statement, this suggests that we are relying on the information in the safety data sheet as an indication of the chemical hazard. Is this the correct approach? We purchase chemicals for a purpose. In using them we may well change their properties and therefore the hazard. Remember that paragraph (e) in regulation 2(1) covers substances that may not have been classified as hazardous and probably will not even be on the safety data sheet. These must be considered when conducting a risk assessment.

“(e) which, not being a substance falling within sub-paragraphs (a) to (d), because of its chemical or toxicological properties and the way it is used or is present at the workplace creates a risk to health” - COSHH Regulation 2 (1) Interpretation

The 6th edition of the ACoP for COSHH also states that when conducting a risk assessment we need to consider the hazard from substances that arises when they are used.

Paragraph 57 states:

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.

The latest book on skin allergy testing (patch testing) lists 4,350 chemicals known to dermatologists as sensitisers, the majority of which will not have been assigned H317. Can we ignore these?

Relying purely on the information on the safety data sheet can easily result in an invalid risk assessment. Perhaps this is why water (as wet work) remains the single most common cause of occupational contact dermatitis.

Chris

They should always be written in context and the way they are used, you can use the data sheet as long as people understand what the chemical does. I have been asked in the past for R/A for tipex, lock tight, even on hand soap because it hurts if you goes in the eye.

My responses were.

Tipex - If you mis-spell that much your in the wrong job

Lock tight - used sparingly and about once a month if that. so no assesment

Soap- don't get it in your eye. I also pointed out that they use it in the house so they know how to use it.  

Originally Posted by: hilary

Yes, you can use any pictograms you want because they are not legally required on your COSHH assessments.  I am currently going through a process of updating to the new symbols on mine as new ones come in but as you say, they are not all available in the new form as yet.

So, in answer, don't beat yourself up over it - if your people understand the old symbols, stick with that for now, change when you're ready and after full training of your staff to understand the new ones.

Whilst I will agree pictograms are not legally required on a COSHH assessment IF you are using them they should be changed when you get new supplier information.

I may be miss-reading this post but if the suggestion is to wait until all materials have the new symbols applied before bothering to train staff......