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echoj7  
#1 Posted : 06 November 2019 10:23:10(UTC)
Rank: New forum user
echoj7

I am in the process of revamping our COSHH assessments to make them easier to understand but to be more task specific. What I am seeking on advice on is the difference between a COSHH Assessment and a COSHH Risk Assessment. What I mean by this is my goal is to keep the assessment to relatively simple, clean and easy to read but introduce a task based assessment in the form of a mini risk assessment. Now we have RA's for the task but what I want clarity on is if its possible to combine the two. 

For example;

We have a Risk Assessment for cleaning windows which mentions all the hazards, risk and controls for that task inlcuding use of chemical products with control measures referencing the COSHH assessment.

We have a MSDS and COSHH Assessment for the product used to clean the windows, and all the information that goes with it (PPE, Hazards etc) within this assessment I have wrote a small task based risk assessment. 

Is their a way to combine these two documents without losing the detail or becoming to bogged down in detail? 

A Kurdziel  
#2 Posted : 06 November 2019 11:58:23(UTC)
Rank: Super forum user
A Kurdziel

We have to say this again. There is no such thing as COSHH assessment for a substance.  What is a required is risk assessment looking at the risks arising from the use of potentially hazardous substances and deciding what controls to apply ie the same as any other risk assessment.  They should be process or task based.

So in the case of substances used to clean windows it would consist of:

  1. Identifying the substances of concern
  2. Look at the hazard that they pose by looking at the SDS
  3. Look at how substances are used taking into account, the amount this is being used, the concentration and dilution and how it is being used.  Look at how it is being stored, how it is being diluted and what it is being used for.
  4. Identity the routes of exposure: inhalation, ingestion, skin contact etc
  5. Decide of the best controls assuming PPE as the least  effective control (substituting the substances for something less harmful is the best)
  6. Establish how you will make sure that people apply the controls and that the  controls work
  7. You may need to look at health surveillance of some sort ie is there any evidence of people developing skin problems due to exposure to the substances. You don’t need an OH person to do this very basic form of health surveillance, just ask people if they think they are having problems. If there is evidence that they are, they you can get OH involved.
  8. Make sure that everybody understands why they need to do this and what the issues might be
  9. Review and update as necessary  

 

thanks 4 users thanked A Kurdziel for this useful post.
CptBeaky on 06/11/2019(UTC), jmaclaughlin on 06/11/2019(UTC), Zyggy on 06/11/2019(UTC), Mersey on 18/11/2019(UTC)
chris.packham  
#3 Posted : 06 November 2019 12:33:16(UTC)
Rank: Super forum user
chris.packham

Whilst I agree largely with AK’s comments there are one or two points that I would make.

Firstly, basing a COSHH risk assessment on the SDS can easily result in an invalid risk assessment. The SDS will only show those chemicals that have been assigned a hazard statement. There are many chemicals that have not been so identified, thus will not appear on the SDS, but should contact with the skin occur can result in damage to health. For example, there are over 4,900 chemicals recognised as skin sensitisers, only a small fraction of which will have been identified as H317.  The risk assessment must include all chemicals present during the task.

Secondly, as indicated, it is not what is purchased that should be the basis of the risk assessment, but what is present during the task. In using chemicals we frequently change their properties (contamination, mixing, reacting, etc.) and thus potentially change the hazard. Determining the real hazard is often the most difficult element in any COSHH risk assessment.

A regards health surveillance I would recommend you consult the relevant section of the ACoP (6th edition) for COSHH. This sets the goal posts for when risk assessment is required. For example, should gloves be worn to protect against chemicals (and water is a chemical) then health surveillance is required. This must be done by a competent person, so just asking the individual whether they have had problems might not be adequate for COSHH compliance.

Chris

thanks 2 users thanked chris.packham for this useful post.
Zyggy on 06/11/2019(UTC), Mersey on 18/11/2019(UTC)
A Kurdziel  
#4 Posted : 06 November 2019 12:48:42(UTC)
Rank: Super forum user
A Kurdziel

Yes

Chris is right –a lot of SDS’s are just poor. The European Chemical Safety Agency reckons that, last time they looked something like 50% were wrong or inadequate which is why they are using REACH to try to improve them but for most people most of the time they are all we have, as we don’t have the knowledge and understanding to second guess what the hazardous nature of the substances actually is.

Of course the SDS basically describes the hazardous nature of the subs not the risk they pose as they are being used.

Roundtuit  
#5 Posted : 06 November 2019 14:42:27(UTC)
Rank: Super forum user
Roundtuit

When e-SDS (extended SDS) are issued these are meant to include exposure scenarios the supplier is aware of within their supply chain. Unfortunately e-SDS are rarer than hens teeth and tend to be quite generic with their considerations as the supplier only knows their substance or mixture not every other product a customer uses.

chris.packham  
#6 Posted : 06 November 2019 15:27:10(UTC)
Rank: Super forum user
chris.packham

Yes, but take a look at the Health and Safety at Work etc. Act 1974.

Section 6 contains the following:-

(4) It shall be the duty of any person who manufactures, imports or supplies any substance for use at work- (a) to ensure, so far as is reasonably practicable, that the substance is safe and without risks to health when properly used ; (b) to carry out or arrange for the carrying out of such testing and examination as may be necessary for the performance of the duty imposed on him by the pre- ceding paragraph ; (c) to take such steps as are necessary to secure that there will be available in connection with the use of the substance at work adequate information about the results of any relevant tests which have been carried out on or in connection with the substance and about any conditions necessary to ensure that it will be safe and without risks to health when properly used.

Earlier this year a company was prosecuted for not managing their use of chemicals adequately. Fine was £250K. Their supplier was also prosecuted for non-compliance with section 6(4). Fine was £300,000.

How many suppliers are aware of this section? How many purchasers insist on section 6(4) information?

thanks 5 users thanked chris.packham for this useful post.
A Kurdziel on 06/11/2019(UTC), Zyggy on 06/11/2019(UTC), mihai_qa on 07/11/2019(UTC), chris42 on 07/11/2019(UTC), jmaclaughlin on 07/11/2019(UTC)
Roundtuit  
#7 Posted : 06 November 2019 16:14:34(UTC)
Rank: Super forum user
Roundtuit

Interesting given there are very few true "substance" users in the workplace with the majority of chemical exposure being to "mixtures" (aka preparations under DPD).

Chris do you have a link to the prosecution case?

Zyggy  
#8 Posted : 06 November 2019 17:17:41(UTC)
Rank: Super forum user
Zyggy

Many years ago whilst in the gas industry I attended one of the best courses I have been on, organised by one ..Chris Packham!

The information I gleaned from it has proved invaluable when dealing with COSHH over the years & there is still a misunderstanding of what is required as succinctly put by AK.

As for Section 6 requirements, I was heavily involved in the purchasing side of things whilst at British Gas, not writing the cheques, but looking at the H&S aspects of what we bought & I was amazed at how many times I had to invoke this Section to ignorant suppliers!

Perhaps it should be mandatory for all new starters entering our profession to attend one of Chris's courses :-)!
chris.packham  
#9 Posted : 06 November 2019 22:01:29(UTC)
Rank: Super forum user
chris.packham

If you look at the Act you will find the only definition of 'substance' as:

'substance " means any natural or artificial substance, whether in solid or liquid form or in the form of a gas or vapour ; '

There is nowhere in the Act anything that I could find that eliminates the application of 'substance' to a mixture of chemicals. It appears that 'substance' is merely used in the Act to differentiate between 'article' and chemical.

Roundtuit  
#10 Posted : 06 November 2019 22:18:34(UTC)
Rank: Super forum user
Roundtuit

Problem is a substance can be that or a substance could be an article under the REACH definition - even more so with the additional regulations where a requirement to report SVHC's ( Substances of Very High Concern) under forthcoming waste regulation is one example
thanks 1 user thanked Roundtuit for this useful post.
chris42 on 07/11/2019(UTC)
stevedm  
#11 Posted : 07 November 2019 12:52:23(UTC)
Rank: Super forum user
stevedm

Think you need to re-read the definitions....and article is : An object which during production is given a special shape, surface or design, which determines its function to a greater degree than does its chemical composition. Examples of articles are a car, a battery and a telephone

https://www.hse.gov.uk/reach/definitions.htm#article

Roundtuit  
#12 Posted : 07 November 2019 13:34:48(UTC)
Rank: Super forum user
Roundtuit

https://echa.europa.eu/documents/10162/23036412/articles_en.pdf/cc2e3f93-8391-4944-88e4-efed5fb5112c

The examples given on the HSE web site are "complex objects" - page 22 of the ECHA guidance

Page 79 gives a very good schematic for Aluminium processing showing how it is possible to transition from a Natural material to a substance then to a mixture before finally producing an article.

mikecarr  
#13 Posted : 07 November 2019 15:06:29(UTC)
Rank: Forum user
mikecarr

Originally Posted by: A Kurdziel Go to Quoted Post

We have to say this again. There is no such thing as COSHH assessment for a substance.  What is a required is risk assessment looking at the risks arising from the use of potentially hazardous substances and deciding what controls to apply ie the same as any other risk assessment.  They should be process or task based.

So in the case of substances used to clean windows it would consist of:

  1. Identifying the substances of concern
  2. Look at the hazard that they pose by looking at the SDS
  3. Look at how substances are used taking into account, the amount this is being used, the concentration and dilution and how it is being used.  Look at how it is being stored, how it is being diluted and what it is being used for.
  4. Identity the routes of exposure: inhalation, ingestion, skin contact etc
  5. Decide of the best controls assuming PPE as the least  effective control (substituting the substances for something less harmful is the best)
  6. Establish how you will make sure that people apply the controls and that the  controls work
  7. You may need to look at health surveillance of some sort ie is there any evidence of people developing skin problems due to exposure to the substances. You don’t need an OH person to do this very basic form of health surveillance, just ask people if they think they are having problems. If there is evidence that they are, they you can get OH involved.
  8. Make sure that everybody understands why they need to do this and what the issues might be
  9. Review and update as necessary  

I'n not an expert on COSHH but if you go by some SDS you wouldnt use anything. Got a can of  adesive remover that you can buy at screfix and it says to wear suitable respaitory equipment WT£ we only want to remove some tape from a floor!!!



Roundtuit  
#14 Posted : 07 November 2019 15:29:04(UTC)
Rank: Super forum user
Roundtuit

Which is why you do your own assessment for use in your work environment rather than relying solely upon supplier information.

https://press.hse.gov.uk/2019/05/23/two-companies-fined-after-floor-layer-fatally-exposed-to-toxic-substance/

Prosecution Chris referred to at #6.

Contractor HASAW Section 2 for failing to assess

Supplier HASAW Section 6 for failing to provide

thanks 1 user thanked Roundtuit for this useful post.
A Kurdziel on 07/11/2019(UTC)
chris.packham  
#15 Posted : 13 November 2019 08:33:00(UTC)
Rank: Super forum user
chris.packham

Further to my earlier posting on this thread perhaps an additional comment regarding a COSHH risk assessment might be helpful. I still find many relying on the safety data sheet for the information on the chemical hazard. Whilst this may be a starting point consider what happens when you use the chemical during a task. It is almost inevitable that you change it in some way. The current ACoP for COSHH recognises this.

“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.”

So any COSHH risk assessment has to start with the task and consider all chemicals/materials used during the task and what happens to them during the task. From this the real hazard can be determined and the risk assessment based on this. There are plenty of case studies where this has not been done with the subsequent exposure creating damage to health. So perhaps the question to ask is: “Does my risk assessment really reflect what happens during the task and the consequent hazard?”

thanks 2 users thanked chris.packham for this useful post.
SNS on 13/11/2019(UTC), A Kurdziel on 15/11/2019(UTC)
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