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benek84  
#1 Posted : 21 November 2016 20:55:31(UTC)
Rank: Forum user
benek84

I am about to complete COSHH assessment and thinking to create new stations for....not sure if should i make sds or assessments sheets available at point of use?also the previous manager located the sds even in toilets.i think that in toilets there is sufficient to label dispensers with significant hazards and control measures and some other cleaning products are sufficiently label. Am I correct? Thank you
chris.packham  
#2 Posted : 21 November 2016 21:41:22(UTC)
Rank: Super forum user
chris.packham

Take a look at the 6th edition of the ACoP for COSHH. You will see that the safety data sheet hardly features when it comes to a COSHH risk assessment. What this should be based on is the hazards represented by the chemicals when they are used for a particular task.

The ACoP includes the following:-

===

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.

===

In any event, I would not post safety data sheets anywhere other than in the filing cabinet. I would not even post up the risk assessments. These just establish what the risk might be when the chemicals are used. What the employee needs to know is how to use the chemicals safely.

Safety data sheets only provide very limited information about the constituents of the product as supplied. There are thousands of chemicals that can cause damage to health that, having not been assigned a hazard statement, will not appear on the safety data sheet but where exposure could easily result in damage to health.

It is a lot more complex than many realise.

Chris

thanks 1 user thanked chris.packham for this useful post.
A Kurdziel on 22/11/2016(UTC)
RayRapp  
#3 Posted : 22 November 2016 08:40:43(UTC)
Rank: Super forum user
RayRapp

An excellent post by Chris, no more to add.
A Kurdziel  
#4 Posted : 22 November 2016 08:53:36(UTC)
Rank: Super forum user
A Kurdziel

What Chris said

chris42  
#5 Posted : 22 November 2016 09:49:43(UTC)
Rank: Super forum user
chris42

You seem to have two issues 1) where you are going to produce COSHH assessments and its as Chris P said, but also 2) do you have to provide copies of the SDS at point of use. 

On the second point, you don't have to provide at the point of use, but you have to make them available to employees (reg 12 (2a iii), unless this has been superseded. I doubt anyone will look at them, but must be available ( as Chris said in a filing cabinet somewhere is fine).

Chris42

sadlass  
#6 Posted : 24 November 2016 09:31:40(UTC)
Rank: Forum user
sadlass

What Chris said . . . !!

But as a BTW, I have just received a number of new SDS's. Each 40 pages long. You're gonna need a bigger wall . . .

chris.packham  
#7 Posted : 24 November 2016 12:01:32(UTC)
Rank: Super forum user
chris.packham

Sadlass

Just file them. I doubt whether they will form a valid basis for a risk assessment. When you use chemicals for a particular task you will almost inevitably change them resulting in a potentially quite different hazard. Changes will result from:

Conltamination - reaction - dilution - heating - cooling - oxidisation - processesl that change the properties of the chemicals, e.g. vulcanisation - metabolisation in the skin itself - physical changes, e.g. leaching into metalworking fluids, dust.

There are thousands of chemicals that in contact with the skin can cause damage but as they have not been assigned a relevant hazard statement will not appear on the safety data sheet. The latest list by a leading dermatologists (de Groot) shows 4,350 chemicals known to be skin sensitisers. Only a minority of these will have been classified as H317. As an example, dermatologists will tell you that water is a skin irritant. Indeed, wet work is the most common cause of occupational contact dermatitis.

As you can see from this, risk assessment is not quite as simple as many assume.

Just as a final point. A while ago the ECHA in Helsinki carried out a review of safety data sheets being produced for REACH by formulators. They reviewed those from over 1,000 companies and concluded that 52% were 'inadequate'.

Chris

hilary  
#8 Posted : 24 November 2016 12:24:51(UTC)
Rank: Super forum user
hilary

I put my assessments and the original MSDS on the public network file for all in the company to read but not change.  The information is available to all, if they want more information they can come and see me.  There is only a virtual filing cabinet on the server and everything is either saved as a pdf or scanned.

Graham  
#9 Posted : 24 November 2016 16:10:33(UTC)
Rank: Forum user
Graham

We have three lever arch files worth of out of date safety data sheets tucked away somewhere.

I need to find them and throw them away.

All the safety data sheets I need are on the web site of the chemical supplier we use.

We don’t keep them on paper or on our servers. 

They are on the supplier’s server and that’s where we go if we need to look at any.

 

But as Chris P says, they’re not much use anyway.  You’d be using breathing apparatus for just about everything we have in our labs, which is obviously nonsense

Jim Tassell  
#10 Posted : 25 November 2016 13:38:59(UTC)
Rank: Forum user
Jim Tassell

Let's look at this from the other end. What does the user of the substances/operator of the process really need to know? Are they really going tob sift through all the (to them) meaningless techy stuff in pages of data sheets, or even your full risk assessment or will they be much better off with a clear direct and simple summary of the process (even if it's just cleaning the toilets) and the consequences if they get it wrong. The KISS rule!

richv  
#11 Posted : 25 November 2016 14:25:42(UTC)
Rank: Forum user
richv

Chris has nailed it with the answers to your questions but as another BTW if relevant to your situation. I used to have a complete set of MSDS held at the gatehouse (Manufacturing facility) with a schematic of locations as there were bulk storage of some items. This was made available as part of the emergency / evacuation process to any emergency services that may be attending.
A Kurdziel  
#12 Posted : 25 November 2016 14:40:47(UTC)
Rank: Super forum user
A Kurdziel

Reading as SDS is more of an art than a science (which is why the so called COSHH software is generally so poor). You must understand your processes and know what information you want and be able to ignore the irrelevant stuff and also to recognise the lies and speculation that get into some SDS.  This is why giving operatives SDSs is in most cases pointless. As the post above said give them work instructions based on what YOU found out from the SDS.

chris.packham  
#13 Posted : 25 November 2016 16:37:20(UTC)
Rank: Super forum user
chris.packham

Look at it this way. What does the employee who is going to carry out the task need to know? Essentially how he or she should execute the task and what to do if something goes wrong. Everything else is just likely to confuse them or give them information that they can misunderstand. So on the data sheet it states H310 - Fatal in contact with skin - for one constituent. However, this is there in a minute amount and not bioavailable. Furthermore, the way in which the chemical is used is such that skin exposure is virtually excluded. What is the potential for sight of the safety data sheet to cause unncessary anxiety?

I agree with KISS - keep the information simple and relevant for the person who has to carry out the task.

Chris

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