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Mr Curious  
#1 Posted : 02 December 2021 11:12:32(UTC)
Rank: Forum user
Mr Curious

Good morning all,

Our business sources a range of different raw materials. Our team forwarded the information regarding one such material that is excempt under REACH and as such, the supplier did not send us an SDS. Do we need to still create a COSHH assessment although we have no other source of information? I suspect we do as it is a substance but still have no other info. Should I address the very basic risks, i.e. being a powder product without know anything about it and/or the levels of protection required?

I've done some reading in the HSE website and although this scenario is referenced, there is no guidance on whether we need to complete a COSHH assessment or not. 

Thank you for your time.

peter gotch  
#2 Posted : 02 December 2021 11:53:49(UTC)
Rank: Super forum user
peter gotch

Hi Mr Curious

First Q is does the material meet the definition of "substance hazardous to health" as set out in COSHH Reg 2

“substance hazardous to health” means a substance (including a preparation)—

(a) which is listed in Part I of the approved supply list as dangerous for supply within the meaning of the CHIP Regulations and for which an indication of danger specified for the substance is very toxic, toxic, harmful, corrosive or irritant;

(b) for which the Health and Safety Commission has approved a maximum exposure limit or an occupational exposure standard;

(c) which is a biological agent;

(d) which is dust of any kind, except dust which is a substance within paragraph (a) or (b) above, when present at a concentration in air equal to or greater than—

(i) 10 mg/m3, as a time-weighted average over an 8-hour period, of inhalable dust, or

(ii) 4 mg/m3, as a time-weighted average over an 8-hour period, of respirable dust;

(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;

On the basis of what you have written unlikely to fall within sub-paragraphs (a) to (c) but may be caught by (d) or the catch-all (e) which is why for example water is subject to COSHH.

Will get more complicated if you process the material such that it creates other substance(s) hazardous to health either as an end product or as an intermediary.

Good luck, Peter

Roundtuit  
#3 Posted : 02 December 2021 12:46:49(UTC)
Rank: Super forum user
Roundtuit

If it is a powder form then you would have to consider dust exposure.

However is the supplier statement correct? A lot of the early exemptions back in 2006 no longer apply.

As more data has become available over time the classification of hazards associated with substances has changed e.g. under ATP 14 the pigment Titanium Dioxide has acquired Carcinogen 2 / H351 based upon aerodynamic particle size

thanks 2 users thanked Roundtuit for this useful post.
A Kurdziel on 02/12/2021(UTC), A Kurdziel on 02/12/2021(UTC)
Roundtuit  
#4 Posted : 02 December 2021 12:46:49(UTC)
Rank: Super forum user
Roundtuit

If it is a powder form then you would have to consider dust exposure.

However is the supplier statement correct? A lot of the early exemptions back in 2006 no longer apply.

As more data has become available over time the classification of hazards associated with substances has changed e.g. under ATP 14 the pigment Titanium Dioxide has acquired Carcinogen 2 / H351 based upon aerodynamic particle size

thanks 2 users thanked Roundtuit for this useful post.
A Kurdziel on 02/12/2021(UTC), A Kurdziel on 02/12/2021(UTC)
Mr Curious  
#5 Posted : 02 December 2021 13:20:42(UTC)
Rank: Forum user
Mr Curious

Thank you both, my way of thinking is the same. The substance is a raw ingredient (cereal). I believe I'll need to create a COSHH assessment anyway and populate it based on experience of handling such (similar) products.

Best regards,

A Kurdziel  
#6 Posted : 02 December 2021 14:19:31(UTC)
Rank: Super forum user
A Kurdziel

Cereal will be included as producing dust. How much dust depends on what you do with it. Note that, there  is a  difference between respirable and inhalable dust. Inhalable dust consists of the larger particles which may get to the back of your throat but often coughed out again while the respirable faction gets right into your lungs and is likely to stay there. How much of each type of dust is produced needs measuring by a competent person.  I am assuming that this cereal is intended for human consumption, so it won’t include any products dressed with herbicides etc. I am also assuming that the product has been carefully stored and  that there is no fungi growing on it-fungi being a source of mycotoxins.    

chris.packham  
#7 Posted : 03 December 2021 10:34:53(UTC)
Rank: Super forum user
chris.packham

Yes, you will still need to do COSHH risk assessment. COSHH covers all chemicals, even water, where exposure during the task could raise a risk of damage to health by any (or more than one) route of exposure might raise a potential for damage to health. Note - during the task. 

“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.” - COSHH ACoP (6th edition), para. 10

So even if there is no safety data sheet (and there are thousands of chemicals that are skin sensitisers, for example, that will never appear as such on a safety data sheet) you need to consider what happens when you use the material, what risks might then arise and how you will manage them.

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