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DHM  
#1 Posted : 14 May 2018 07:27:45(UTC)
Rank: Forum user
DHM

Hi everyone,

My client is reluctant to write risk assessments for straight forward cleaning chemicals in an office environment. I am looking for examples of where accidents or prosecutions have taken place using normal supermarket bought cleaning chemicals that I can show to my client to demonstrate why they should be doing these RA's.

Any help with this would be welcomed.

Thanks

DHM

A Kurdziel  
#2 Posted : 14 May 2018 08:19:28(UTC)
Rank: Super forum user
A Kurdziel

The law is quite clear that CIOSHH applies to any hazardous substances in the workplace and this includes domestic cleaning products used in the workplace. As far as I know there are no examples prosecutions for employers for simply not having a risk assessment.  Generally what has happened is that something goes wrong and then it emerges that there is no risk assessment covering that work. For example there is a case of a sports centre (Wakefield?) where a drain cleaner (available in all good hardware stores) was used on a floor drain. A kiddie then sat on the drain and burned their bottom. I cannot remember if they were prosecuted under COSHH or if they just used Section 3 of Health and Safety at Work Act.  UK law obviously advances by use of precedent and case law and as a bit of legal nerd I am please your client has decided to provide an opportunity to advance the law by ignoring it in this way. Good luck to them!

chris42  
#3 Posted : 14 May 2018 08:36:04(UTC)
Rank: Super forum user
chris42

Originally Posted by: A Kurdziel Go to Quoted Post

UK law obviously advances by use of precedent and case law and as a bit of legal nerd I am please your client has decided to provide an opportunity to advance the law by ignoring it in this way. Good luck to them!

They say sarcasm is the lowest form of wit but can be funny on a Monday morning

A Kurdziel  
#4 Posted : 14 May 2018 09:02:23(UTC)
Rank: Super forum user
A Kurdziel

Originally Posted by: chris42 Go to Quoted Post
Originally Posted by: A Kurdziel Go to Quoted Post

UK law obviously advances by use of precedent and case law and as a bit of legal nerd I am please your client has decided to provide an opportunity to advance the law by ignoring it in this way. Good luck to them!

They say sarcasm is the lowest form of wit but can be funny on a Monday morning

Start low and work your way down!

Ian Bell2  
#5 Posted : 14 May 2018 09:07:54(UTC)
Rank: Super forum user
Ian Bell2

I have a great deal of sympathy for the employer. However context is important. Are the domestic cleaning products only used by company employees? No kids/vulnerable adults/contract cleaners? If, not, yes, it should be a 1 sheet tick box assessment for legal compliance etc. It would seem a fair assumption that domestic grade cleaners are being no differently in an office than at home in which case I would argue that the products should be treated no differently. Keep things in proportion.
lorna  
#6 Posted : 14 May 2018 09:13:27(UTC)
Rank: Forum user
lorna

I give Departments a form to list product, any symbols, risk phrases or other concerns. No symbol or a statement that it's non-hazardous - it just gets included in a general risk assessment. Anything else has to have a COSHH assessment - but I have been known to lump things together (e.g. washing up liquid - does it really matter if it's Fairy or Aldi's own if the symbol, general info & use are the same?)

I'm a firm believer of action proportionate to risk - & its seems to go down better with my employer too.

Invictus  
#7 Posted : 14 May 2018 09:39:32(UTC)
Rank: Super forum user
Invictus

It has to be hazardous to have a R/A completed, I don't do it for household items and I do not do a R/A for all items unless marked as hazardous. It would be like doing a R/A for a bar of soap in case you got some in your eye.
Ian Bell2  
#8 Posted : 14 May 2018 10:12:46(UTC)
Rank: Super forum user
Ian Bell2

No it wouldn't. COSHH like many other safety regs has a 'catch all' element. Reg 2(e) covers the definition of a hazardous substance
Roundtuit  
#9 Posted : 14 May 2018 10:48:44(UTC)
Rank: Super forum user
Roundtuit

And when you look on the back of the washing up liquid - a not insubstantial GHS07 (exclamation mark) - the pictogram comes from the classification indicating hazard with the material.

Problem is locating the correct information to see "if" the professional version is the same as the domestic version is the same as the competitors equivalent

Consumer products provide their hazard information through labelling so tend to avoid the Hazard & Precautionary numbers and provide none of the additional information found upon the Safety Data Sheet which supports Professional/Industrial uses

BUT ensure if you are looking up an SDS on-line that you go to the manufacturer as many resellers posted documents but then fail to update with the current best available knowledge

Google "Fairy SDS" and the first result is non-compliant https://www.careshop.co.uk/img/cms/PFL5.pdf 

A Kurdziel  
#10 Posted : 14 May 2018 13:14:05(UTC)
Rank: Super forum user
A Kurdziel

The point of COSHH is the risk assessment. It is only by assessing the risk that you decide if something is safe. Just because a product is sold in B&Q does not mean this it is intrinsically safe.

It is also not just a matter of just looking at the SDS and copying what it says there. You have to look at what you are using it for. There  is a world of difference between using some oven cleaner for example at home a couple of times a year do your oven and someone using this caustic material day after day in a restaurant.

If someone was to get some of this stuff in their eye, then that could be a RIDDOR.

You can do also sorts of things at home that you would not allow at work.

chris.packham  
#11 Posted : 14 May 2018 13:14:42(UTC)
Rank: Super forum user
chris.packham

Not hazardous? Wet work, i.e. exposure to water and from wearing of gloves for longer periods, is the most common cause of occupational contact dermatitis. Water has long been known to dermatologists as a skin irritant.

Also how about the case of  a company actually manufacturing cosmetic products asked to clean a changing room using the normal cleaning products present. No training, no risk assessment. Mixed two of the cleaning products together. Outcome fatal. Prosecution followed. Company fined.

There are over 4,350 chemicals known to dermatologists as skin sensitisers. Only a small minority will have been classified as H317. Rest may not even appear on the safety data sheet!

Chris

A Kurdziel  
#12 Posted : 14 May 2018 14:04:03(UTC)
Rank: Super forum user
A Kurdziel

Originally Posted by: chris.packham Go to Quoted Post

Not hazardous? Wet work, i.e. exposure to water and from wearing of gloves for longer periods, is the most common cause of occupational contact dermatitis. Water has long been known to dermatologists as a skin irritant.

Also how about the case of  a company actually manufacturing cosmetic products asked to clean a changing room using the normal cleaning products present. No training, no risk assessment. Mixed two of the cleaning products together. Outcome fatal. Prosecution followed. Company fined.

There are over 4,350 chemicals known to dermatologists as skin sensitisers. Only a small minority will have been classified as H317. Rest may not even appear on the safety data sheet!

Chris

I was waiting for Chris to Join in!

Thanks

chris42  
#13 Posted : 14 May 2018 14:06:49(UTC)
Rank: Super forum user
chris42

http://www.yourlocalguardian.co.uk/news/10598237.Pub_worker_tells_of_creating_toxic_fumes_while_cleaning_urinal/

It not what you use its the way that you use it.

Invictus  
#14 Posted : 14 May 2018 14:09:42(UTC)
Rank: Super forum user
Invictus

Originally Posted by: A Kurdziel Go to Quoted Post

The point of COSHH is the risk assessment. It is only by assessing the risk that you decide if something is safe. Just because a product is sold in B&Q does not mean this it is intrinsically safe.

It is also not just a matter of just looking at the SDS and copying what it says there. You have to look at what you are using it for. There  is a world of difference between using some oven cleaner for example at home a couple of times a year do your oven and someone using this caustic material day after day in a restaurant.

If someone was to get some of this stuff in their eye, then that could be a RIDDOR.

You can do also sorts of things at home that you would not allow at work.

Only a half wit would try and use oven cleaner without the correct PPE but suggesting that all chemicals need a risk assessment is incortrect, it would be like doing one for tippex or lock tight when you use it every Preston guild.

Roundtuit  
#15 Posted : 14 May 2018 14:19:30(UTC)
Rank: Super forum user
Roundtuit

There is no legislation against being a half wit at home (except for Gas and certain aspects of electrical work)

Those who do conduct RA realise you can swop solvent based correction fluids for tapes eliminating the hazard and the spurious COSHH assessment

DHM  
#16 Posted : 14 May 2018 14:29:38(UTC)
Rank: Forum user
DHM

Thanks for all responses so far.

Can I try to get back to the point of my original posting which was requesting examples of prosecutions or accidents people have had whilst using domestic cleaning products at work.

Can anyone provide me with typical examples please?

Thanks

DHM

Roundtuit  
#17 Posted : 14 May 2018 14:38:36(UTC)
Rank: Super forum user
Roundtuit

Not prosecutions to cite but some examples are present in the HSE guidance doc

http://www.hse.gov.uk/pUbns/priced/hsg262.pdf

And a general, not generic RA for office cleaning

http://www.hse.gov.uk/risk/casestudies/pdf/officecleaning.pdf

chris42  
#18 Posted : 14 May 2018 14:45:31(UTC)
Rank: Super forum user
chris42

http://press.hse.gov.uk/2016/worker-dies-from-toxic-gas/

Charlie Brown  
#19 Posted : 14 May 2018 17:20:55(UTC)
Rank: Forum user
Charlie Brown

It takes minutes to do COSHH assesments so just do them and be content in the knowlege that the law is an ass.

Roundtuit  
#20 Posted : 14 May 2018 19:19:46(UTC)
Rank: Super forum user
Roundtuit

Well having started as a chemist I must be too critical with my approach:

Presented with an SDS the first thing I do is review its validity which takes those "couple of minutes" (looking at the document and making confirmation via the web / supplier).

Then I verify the information provided by the SDS is current and to "best available knowledge" checking sources such as ECHA registration dossiers and GESTIS along with competitor documents - yes GHS / CLP mean the information should be consistent but often it is not.

After that I consider what I have been told about how the product is intended to be used and where possible see it in use (not necessarily the same thing) within the work environment.

thanks 1 user thanked Roundtuit for this useful post.
A Kurdziel on 15/05/2018(UTC)
Charlie Brown  
#21 Posted : 14 May 2018 22:19:14(UTC)
Rank: Forum user
Charlie Brown

So there you are, a no brainer :)

Originally Posted by: Roundtuit Go to Quoted Post

Well having started as a chemist I must be too critical with my approach:

Presented with an SDS the first thing I do is review its validity which takes those "couple of minutes" (looking at the document and making confirmation via the web / supplier).

Then I verify the information provided by the SDS is current and to "best available knowledge" checking sources such as ECHA registration dossiers and GESTIS along with competitor documents - yes GHS / CLP mean the information should be consistent but often it is not.

After that I consider what I have been told about how the product is intended to be used and where possible see it in use (not necessarily the same thing) within the work environment.

chris.packham  
#22 Posted : 15 May 2018 10:09:14(UTC)
Rank: Super forum user
chris.packham

Not quite…

Firstly there is section 6-1 of the Health and Safety at Work etc. act 1974, part of which states:

It shall be the duty of any person who designs, manufactures, imports or supplies any article for use at work:-

(c) to take such steps as are necessary to secure that there will be available in connection with the use of the article at work adequate information about the use for which it is designed and has been tested, and about any conditions necessary to ensure that, when put to that use, it will be safe and without risks to health.

This is somewhat different from what is required for the SDS

Secondly, consider what the current ACoP for COSHH states in para 10:

Paragraph 10 - 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. A substance hazardous to health need not be just a chemical compound, it can also include mixtures of compounds, micro-organisms or natural materials, such as flour, stone or wood dust.

It isn’t the hazard on the safety data sheet that counts; it’s the hazard present when we use it for a particular task. That hazard can be different for different tasks.

nickpatience1  
#23 Posted : 18 May 2018 22:54:57(UTC)
Rank: New forum user
nickpatience1

Originally Posted by: Invictus Go to Quoted Post
Only a half wit would try and use oven cleaner without the correct PPE but suggesting that all chemicals need a risk assessment is incortrect, it would be like doing one for tippex or lock tight when you use it every Preston guild.

Not everyone is as informed as us, or able to tell what is right or wrong or empowered enough to tell their manager that they won't do something. Some workers are more vulnerable than others. Some employers try to be inclusive.

Some get it wrong.

https://www.healthandsafetyatwork.com/chemicals-coshh/tesco-fined-after-vulnerable-employee-burned-oven-cleaner

Edited by user 18 May 2018 22:57:20(UTC)  | Reason: to try to make link work

chris.packham  
#24 Posted : 19 May 2018 10:00:51(UTC)
Rank: Super forum user
chris.packham

And how many still base their risk assessment on the information on the safety data sheet? In fact, how many training courses on COSHH risk assessment still  use the safety data sheet as the basis for the risk assessment? How often do I encounter the view that 'as I am complying with the WEL I am compliant with COSHH'? Not so

As it happensmy copy of  the reference work on skin sensitisers (Patch Testing by Anton de Groot) mentions 4,350 chemicals recognised by dermatologists as sensitisers. Only a minority of these will have been classifie as H317 and appear as such on the safety data sheet - assuming they appear at all. So your safety data sheet lists 70% of the constituents as hazardous. Have you any idea what the other 30% are and what they might do for example in contact with the skin?

Now read para 10 of the current ACoP for COSHH. Does this even mention the safety data sheet?

Chris

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