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Ashley30225  
#1 Posted : 23 September 2011 14:07:08(UTC)
Rank: Forum user
Ashley30225

Hi,

Can any one clarify some coshh for me..

I have been tasked with a coshh risk asssessment review, and i want to keep it simple and not waste unnecessary reosurces doing unnecessary things if i do not have to by law.

I believe you only need to do the assessment on hazardous substances.

For example i am reviewing some safety data sheets on gear oils.

The MSDS sheets states that this product is not classed as hazardous etc and there are no risk or safety phrases identfied on the sheet.

Therefore, i would class this as not requiring any more time on it...

The technicians who use the oils for commercial vehicle service etc have all the PPE etc.

Any comments

Kind Regards

Ian
teh_boy  
#2 Posted : 23 September 2011 14:24:16(UTC)
Rank: Super forum user
teh_boy

Depends :)

as you say the CoSHH regs require us to risk assess substances that may harm our heath and the ACOP identifies these as:

1) identified under CHIP as having a haz symbol or R, S phrase
2) listed in EH40
3) Otherwise thought to pose a risk to health (so covers everything depending on use!)

CoSHH assessments MUST assess the process and use - not just a cursory glance at the MSDS.
I agree that pouring clean vegetable oil once a month from one container to another is unlikely to cause any issues.

Spraying hot oil all over a machine for 12 hours a day and we might start to expect to see skin / respiratory problems!

Skin problems are the hardest to deal with as skin reactions will vary from individual to individual, also the cleanliness of the oil etc will play apart! (Chris Packham is the best person to help here!)

Also we need to consider the health effects of the used oil! and this starts to get more difficult!
http://www.hse.gov.uk/pubns/guidance/mw02.pdf

Now before I close off - you contradict yourself as you say the oil is non hazardous, but then say they all have the correct PPE?
What's the PPE for if there is no hazard?

I assume you are correct and limited time might be needed for this review, but you need to be sure! MSDS are also notorious for being wrong, I always check against this list as well.... http://esis.jrc.ec.europa.eu/

I hope that helps - I don't think anyone will be brave enough to say don't assess it further with out knowing the full story :)
bob youel  
#3 Posted : 23 September 2011 14:44:32(UTC)
Rank: Super forum user
bob youel

Undertake such assessments in the 'as use & as exposed' situation as against just assessing the data sheet as big differences can exist between actual exposure and the risk rating of a particular substance in its manufactured / supplied situation
chris.packham  
#4 Posted : 23 September 2011 15:18:01(UTC)
Rank: Super forum user
chris.packham

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





teh_boy  
#5 Posted : 23 September 2011 15:30:44(UTC)
Rank: Super forum user
teh_boy

I think we all agree,

Its a good Friday when a master agrees with me :)

I think I can go on holiday smiling now - teaching NEBOSH cert on day one back - so maybe not, HSG65 as reading material on the beach? :)
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