Hi All,

We have several raw materials that we use as part of our food manufacturing process that under section 2 of the SDS, are not classified as dangerous/hazardous. Would a COSHH risk assessment still be required?

Morning Steve 40.

As HSSnail indicates there are lots of substances hazardous to health within the definition of that term which you will not usually find an SDS for.

I have seen an SDS for dihydrogen oxide advocating the use of water in the event of inadvertent contact. 

Whether that SDS was produced as a joke or not is unclear but if you haven't already sussed dihydrogen oxide (formulation H2O - note the 2 should be in subscript but this platform doesn't do subscript) is water which is responsible for a huge proportion of skin disorders as a result of workplace exposure. 

Then there are all the byproducts of processes, so that even if the input materials are chemically inactive, what is produced during wo rk may be nasty. Example, burning off paint.

....and all those things such as the asthmagens that HSSnail mentioned.

Whether you should do a specific COSHH assessment is a matter of judgement. Perhaps you can adequately cover the COSHH issues in a general risk assessment. Nothing in COSHH says that a COSHH assessment has be entitled "COSHH assessment".

The SDS describes the hazardous nature of various products( and as people have pointed out not all products require an SDS)  COSHH is about managing the risk posed by exposure to hazardous substance irrespective anything in the SDS. The flour example is a good one. Flour is a foodstuff and as such does require an SDS to be provided but if flour is being used on a  large scale, such as a commercial bread making operation it creates a risk to people who might be exposed to flour dust.  COSH expects the employer to identify and manage that risk. Too many people that that COSHH is just about looking up the SDS and transcribing the relevant bits onto the COSHH form.  That is not a risk assessment. 

So what you need to do is:

• Look at the hazardous  nature of the substances, with the SDS being the starting point
• Look at the form that the substance take; is it a fine respirable dust-note in COSHH Reg there is definition of “substance hazardous to health”  which states that at (d) that any inhalable or respirable dust might be hazardous substance irrespective of what it consists of.  
• Ask does the process you are using ( all risk assessment relate to a process)  create and spread this dust
• How many people are exposed to this has
• How often does this exposure happen and how long for
• What controls do you use-noting the hierarchy of controls with PPE at the bottom and are they effective at reducing the exposure

That’s what you need in your COSHH risk assessment.

I once got someone to do a COSHH risk assessment for sprinkling mustard powder(about 500 g at a time)  onto grass  to force earthworms to the surface. The mustard powder came from a supermarket in a  yellow tin and surprise surprise there was no SDS with it, but the main ingredient was wheat flour, followed by colorants   and mustard which contains Allyl isothiocyanate. If you were to buy pure Allyl isothiocyanate it would come with an SDS because it is no longer a food stuff just a nasty chemical(read the SDS it is quite scary!) . So because rather than  putting it on their sausages they were scattering it about I suggested they do the COSHH risk assessment cos it might have ended in their eyes or being breathed in.  The optimal solution was goggles and a disposable face mask.