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I am trying to process a COSHH risk assessment for some solder wire which contains rosin flux. (CAS 8050-09-7) When our purchasing department requested the SDS from the manufacturer, they were sent the US version from 2021. The UK supplier (RS components) has a DL link to another sheet specific to the UK from 2024. What's confusing is that the UK version does not have an H334 hazard ratings, or a serious health hazard label - both of which are included on the US version. The content is listed as >=2,3 - <=3,7 % for UK and 1-5% for US. From my limited understanding, despite H334 not being listed under annex VI of the CLP for 8050-09-7 anything with >1% rosin should be self-classified by the manufacturer as a serious health hazard and H334 based on its well-known status as a respiratory sensitiser (CLP Article 4(3) & CLP annex 3.4.3) I'd be interested in people’s thoughts on this. Just a bad SDS, or manufacturer trying to deliberately down-rate the substances to make it more appealing to those not in the know?
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Rank: Forum user 
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As you have already identified, Rosin is not classified as a Respiratory sensitiser (H334) in CLP, but rather as a skin sensitiser (H317). As such, no classifications of mixtures containing Rosin are required to be classified as H334 due to the presence of Rosin. As the concentration of Rosin is above 0.1%, the solder wire will retain its H317 classification and still be a Cat 1 skin sensitiser. In this case, the EU compliant version is consistent with the requirements of CLP (as you would expect) and the US version isn't. The whole point of REACH and CLP was to ensure consistent, evidence based classification of substances and their mixtures. The same robust approach is not applied in the US. Having said all that, for the purposes of COSHH, you should still reduce the risk of exposure via inhalation to as low as reasonably practicable, as the mixture of different vapours released is known to be high risk. In practice, the lack of a H334 should have no impact on the level of control applied. Hope it helps.
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 3 users thanked antbruce001 for this useful post.
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Originally Posted by: antbruce001  As you have already identified, Rosin is not classified as a Respiratory sensitiser (H334) in CLP, but rather as a skin sensitiser (H317). As such, no classifications of mixtures containing..... ....Hope it helps. Thanks that is helpful. Part of my issue is that my employer is of the opinion that unless it explicitly states in law, in black and white that they have to do something (i.e. spend money) on H&S, they won't - 'anything more than the minimum is a waste' is the direct phrase they like to use. All the other rosin containing solder wires I have reviewed contain the H334 code on the UK data sheets, which makes it simpler to justify substitution or stricter controls because of the official classification as a sensitiser. As this doesn't it becomes a real headache for me to try and justify to people with that attitude to safety. For reference, we use flexi-arm type LEV, which is well known to be subject to human factors. I can guarantee that if I go downstairs now, 90% of them won’t have the nozzle at the correct distance 'because it gets in the way' and the production manager will just pull a face and say he’s told them before. We have no health surveillance and no air sampling - so from my perspective the current controls are inadequate. People are being exposed. And yes, this is backwards, I am retrospectively trying to do assessments for things that have been in use for months or years (inherited situation) Rant over, are you able to expand or support this part of what you said? I’m assuming ACOP L5 para. 58 & para 143? Originally Posted by: antbruce001 Having said all that, for the purposes of COSHH, you should still reduce the risk of exposure via inhalation to as low as reasonably practicable, as the mixture of different vapours released is known to be high risk. In practice, the lack of a H334 should have no impact on the level of control applied.
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Dan, the problem with Rosin is not the material itself, it is what it becomes during use. Rosin decomposes thermally into other materials that are respiratory sensitisers. The incorrect use of the provided flexible arm LEV system is not a COSHH issue. It is linked to both the Safety Culture (including internal enforcement of H&S requirements) and the training of the operators in the risks and required controls relating to soldering (not just what they should be doing, but importantly why!). Here's some information which supports your correct approach to the matter. Health Risks from Soldering1. Key HazardsSoldering processes—particularly soft soldering with lead-based alloys and fluxes—can present several health risks: Inhalation of fumes: Thermal decomposition of flux (often rosin-based) releases colophony fumes, containing aldehydes and isocyanates, which are respiratory sensitisers. Lead exposure: Solder wire or components may contain lead, risking ingestion or inhalation of lead dust or vapour. Skin contact: Irritation or dermatitis can result from flux or cleaning chemicals. Burns: Contact with hot equipment or molten solder can cause thermal injuries.
Application of COSHH in the UKUnder the Control of Substances Hazardous to Health Regulations 2002 (COSHH), employers are legally required to assess and control exposure to hazardous substances, including those generated by soldering. 2. COSHH Requirements for Soldering ActivitiesCOSHH Risk Assessment: A suitable and sufficient assessment must identify: The substances involved (e.g. colophony, lead, flux constituents). The exposure routes and potential health effects. Who may be exposed and how often. Existing and necessary control measures.
Substitution: If reasonably practicable, replace hazardous flux (e.g. colophony-based) with a less hazardous alternative. Engineering Controls: Local Exhaust Ventilation (LEV) is the primary control to prevent inhalation of fumes. General ventilation is not sufficient. LEV must be suitable, maintained, and tested every 14 months (as per COSHH Regulation 9).
Health Surveillance: Required for substances that can cause occupational asthma (e.g. rosin-based flux). Must be implemented where there is a reasonable likelihood of disease, even if controls are in place.
Personal Protective Equipment (PPE): Training and Information: Workers must be informed of the hazards. Must be trained in safe working practices, correct use of LEV, and emergency procedures.
Relevant Guidance and StandardsHSE EH40: Workplace exposure limits (WELs) include: Colophony fume: WEL = 0.05 mg/m³ (8-hr TWA), STEL = 0.15 mg/m³ Lead (inhalable dust): WEL = 0.15 mg/m³
HSE Guidance Note INDG249: Controlling Fume from Soldering – COSHH Essentials Guidance. COSHH Essentials Sheet SR7: Provides a task-based control strategy for soldering.
Edited by user 10 June 2025 07:36:10(UTC)
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Sorry to say this Bruce but that fact that people are not using the LEV correctly IS a COSHH issue: it’s, as Dan’s boss might say, in “black and white”, COSHH Reg 8(1) which says that they employer shall (absolute duty there) “… take all reasonable steps to ensure that it(the control) is properly used or applied as the case may be.” and in 8(2): “ Every employee shall make full and proper use of any control measure, …” so you can tell the boss about those two breaches. It does not really matter what the SDS says about individual substances in the solder. What you should be looking at is the overall risk that the activity poses in your workplace to your employees. Based on that you should best applying the best control which is clearly some sort of LEV, but the controls must actually work and employees should be trained to appreciate the risks and told to comply with the controls.
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Originally Posted by: antbruce001 Dan, the problem with Rosin is not the material itself, it is what it becomes during use. Rosin decomposes thermally into other materials that are respiratory sensitisers. (snip)
Thanks antbruce. Where did the information you posted come from? I cannot see that text in any of the HSE guides. Youw own work, or antoher third party?
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Rank: New forum user
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Originally Posted by: A Kurdziel Sorry to say this Bruce but that fact that people are not using the LEV correctly IS a COSHH issue: it’s, as Dan’s boss might say, in “black and white”, COSHH Reg 8(1) which says that they employer shall (absolute duty there) “… take all reasonable steps to ensure that it(the control) is properly used or applied as the case may be.” and in 8(2): “ Every employee shall make full and proper use of any control measure, …” so you can tell the boss about those two breaches. It does not really matter what the SDS says about individual substances in the solder. What you should be looking at is the overall risk that the activity poses in your workplace to your employees. Based on that you should best applying the best control which is clearly some sort of LEV, but the controls must actually work and employees should be trained to appreciate the risks and told to comply with the controls. I'm inclined to say it is both a direct COSHH issue and a general culture problem. To my mind, and following ACOP L5, the likelihood of disease and the severity of it if it occurs determines to what extent human factors in a control measure can be tolerated. If the effect 'may' occur and is acute and minor (H335), then user adjustable LEV seems reasonable. When the effect is probable and the result is chronic and irreversible, then to me the LEV should be a fixed unit, either enclosed or downdraft. That way the only major human factor is failing to turn it on - which is much easier to train and police. I am very much aware of the lack of operator training the company has in place, which extends far beyond LEV use. Sadly, trying to reverse years, even decades of poor practice, especially as someone new to the field, is a monumental task.
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Hi Dan You are NOT alone!! Of course, not using adjustable LEV appropriately IS a COSHH issue but as you yourself point out it's almost certainly part of a broader problem of "culture" in the organisation. Possibly that culture is more likely to be better addressed on what seem like simpler issues than those where you might wish to quote hazard classifications from an SDS and then try to explain that the risks are not just with the materials being used but the byproducts of the processes for which they are used. So, the bosses want to do the bare mimimum prescribed by law but in the UK very little is set in stone in "prescriptive" [DO THIS] or "proscriptive" [DON'T DO THAT] RULES. Instead almost all the legislation asks you to do what is reasonably practicable. ...and at the end of the day it is up to the bosses to justify that they have demonstrated that the organisation recognises the relevant duty and has done what is necessary to get to the threshold of what is reasonably practicable. You might need to remind them of Section 40 of HSWA. AND perhaps ask people at every level of the organisation what level of risk of harm they are prepared to tolerate and WHY. So, at the sharp end operatives are not using the LEV properly as it "gets in the way". So perhaps you need to accompany the production manager whose job includes MANAGING the workers who report directly or indirectly to them to discuss why the LEV gets in the way, evaluate the reasons given and look for solutions. Good luck, Peter
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Hi, With regards to Kurdziel comments; Yes - of course it is a COSHH issue in the strictest of terms, but I never said employees don't have legal duties under COSHH. Clearly they do, as you correctly point out. However, blaming employees for being allowed to not use equipment correctly/safely does not address the problem. From Dan's description, what we have here is a 'routine violation', and as such is the result of a poor safety culture due to line management not enforcing the use of the safe system of work and employees not truly appreciating the risks they are exposing themselves to. If the HSE found this situation, it would be the company in court, not the employees. Dan - the text is something I pulled together myself from multiple sources. Cheers.
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The thing that’s interesting about section 8 of COSHH that it is a prescriptive duty : employers shall ensure that employees use the LEV correctly; not “yeah we mention it during inductions but what can you do we have a business to run and we don’t have time to actual manage or supervise our employees, let alone train them…” approach.
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