Hi 

Recently seen a practice in my workplace and would like advice.

Workplace - Train Maintenance Depot

Undertakings - Train Movements, Engineering Works and Cleaning of train carriages

Recently seen the cleaners decanting cleaning chemical from one source to another. Usually from the original container (with correct labelling) to a smaller bottle in spray form (presume this makes the job easier) Ive seen this happen with more than one type of cleaning chemical. Nothing too hazardous. 

The bottle they decant too is always plain with no labelling. Just wandering is this a breach of COSHH or CLP or at least agaisnt good practice?

Steve

CLP is about chemicals in the supply chain - as you are the end user not a problem

COSHH is about your control practices to protect employees here you do have an issue as with no label how do they know what is inside and therefore how to behave (someone puts it down and someone else picks it up later) - I remember the old TV infomercials warning parents not to decant items such as bleach in to pop bottles even with the original label removed.

In laboratories the equipment suppliers are very good with pre-printed dispensing bottles for common reagents and chemicals bought in bulk.

Bulk purchasing will suit those behind the finances but it would be worth investing in labelling for these point of use dispensers even something as simple as the relevant hazard pictogram and a dymo tape of the products name.

As you are cleaning trains I presume at some stage the public will be on board - for that occassion when one of these dispensers accidentally gets left behind and Johnny's mum is trying to work out what the little darling has just sprayed in their face absolutely essential.

You cannot say it will never happen - hospitals where they count equipment before, during and after surgery still have too many never events where something is left in the patient.

Best practice is to avoid decanting (with associated risks of spills and exposure) by buying the chemicals in containers suitable to use them from directly. 

Second best practice is as you say to label the containers decanted into with chemical name and hazard pictogram.  Keeping the labels legible can be difficult, especially if the chemical is one that dissolves ink.

Brilliant advice by all. Thanks.

Any follow up advice on the safest way to decant?

Regards

For this scenario today I have seen what is probably the best practice observed in a small company who use a common lubricant (two letters two numbers).

Lots of employees require this simultaneously so a single dispenser pack is not practical but the cost of purchasing suitable size dispensers (and their subsequent disposal) is expensive given the volume of product used.

So talking with the manager today they buy in bulk and decant BUT they also occassionally purchase a new dispenser pack to replace the ones where the manufacturers labelling has become obscured.

Quick check on line and this seems very common with cleaning chemicals - there is the consumer pack which we pay through the nose for at the supermarket whereas industrial/professional user can bulk purchase the same material and significantly reduced cost and packaging.

Regarding decanting whether a 205 Ltr drum or a 5 Ltr pack there are plenty of powered or pump dispensers available to assist - without any association a couple of examples

https://www.lowcostcleaningsupplies.co.uk/hand-pump-5ltr-dispenser

or

https://www.amazon.co.uk/Contico-Standard-Closure-Dispenser-Containers/dp/B00AZZ73SC

Move in to laboratory suppliers and you can get selectable transfer volumes so less strokes to fill.

It all depends on what pack you purchase and what is the convenient pack size for use.

In a lab setting decanting of reagents is almost inevitable. People do not like to share reagents as they worry about cross contamination due to “double dipping”. They also make up specific mixtures for specific purposes and they’re supposed to label them properly once they have been made up.

As to cleaners decanting cleaning products: it is not a problem except that people might not know what is being decanted and could easily mix up the substances being used and if they do not have the product information (as required under CLP) they might underestimate the risk posed by the products.  So decanting is OK as long as the containers they are decanting into are properly labelled containers with all relevant information.

Originally Posted by: chris.packham

May I add to AK's excellent post that no-one should be permitted to mix chemicals unless they have had adequate training and know what they are doing. There was a prosecution not long ago for a fatality. Employee was asked to clean the changing room. In the process it appears he allowed the toilet cleaner and floor cleaner to come together. The resulting reaction produced chlorine resulting in his death. One assumes that laboratory workers will know what they are doing, but is this assumption always valid? Perhaps a check might avoid some unexpected and unpleasant surprises!

Chris

The Mad Scientist is not entirely a fictional charcter!