Firstly, the fact that the safety data sheet states that the product is non-hazardous is irrelevant for COSHH. Definition (e) of the COSHH regulation 2(1) implies that any substance, even water, can become a substance hazardous to health depending on how it is present and used at the workplace. Incidentally, the safety data sheet is required to comply with CHIP not COSHH and paragraph 13 of the ACoP for COSHH indicates that it is not the definitive source of hazard data for COSHH risk assessment.
Secondly, a substance can change during use. A classic example of this is a metalworking fluid that contains a 'preservative' to prevent bacterial contamination. This may quite legally not be shown as a skin sensitiser on the safety data sheet, but in all probability be what we know as a 'formaldehyde releaser'. Thus it may result in allergic contact dermatitis when skin contact occurs during use. In fact, under the 1% rule it may not appear on the safety data sheet at all!
I am all for simplification, but not at the risk that workers are then exposed to situations where damage to health can occur. The HSE will confirm that the most common cause of occupational contact dermatitis, in terms of numbers affected is 'wet work', i.e. excessive exposure to water or wet objects.
Also with regard to safety data sheets, note what the HSE has stated: “HSE’s experience suggests that a large proportion of SDSs do not provide adequate or correct information on hazards and exposure controls.” – from Topic Inspection Pack, Work Related Contact Dermatitis, Skin Disease Programme.
This same document also states: “Nevertheless, product suppliers have a legal responsibility under the Health and Safety at Work Act to provide adequate information about any risks to health or safety of the users and about any conditions necessary to ensure that the products can be used safely” Take a look at section 6-1 of the Act on this one! A safety data sheet may be compliant with the requirements for CHIP but not mean that the supplier has fulfilled his obligations under the Act.
I am all for simplification, but not at the risk that workers are then exposed to situations where damage to health can occur. The HSE will confirm that the most common cause of occupational contact dermatitis, in terms of numbers affected, is 'wet work', i.e. excessive exposure to water or wet objects.
Just keep in mind that it is not what the chemical is, but how it is used, the actual/potential for worker exposure, and the consequences of such use that are the key factors. In other words, COSHH risk assessment is not substance, but task based.
Chris