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Martin#1  
#1 Posted : 30 November 2011 15:18:05(UTC)
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Martin#1

I'm updating our Health & Safety Policy and I'm looking at Hazardous Substances, its an office based risk and staff are not exposed to ANY Hazardous Substances, how do I best write this into our Health & Safety policy? I don't want to put down that its not applicable! any help/advice would be much appreciated Thanks Martin
MB1  
#2 Posted : 30 November 2011 15:22:32(UTC)
Rank: Super forum user
MB1

I would think that there is a distinct difference of putting the fact you do not have any hazardous substance in your workplace. It would be far more effective to put in place a system IF such substances do come into the workplace... How would this be managed, assessed and communicated?
CW  
#3 Posted : 30 November 2011 15:28:01(UTC)
Rank: New forum user
CW

Cleaning fluids such as bleach?
Martin#1  
#4 Posted : 30 November 2011 15:32:38(UTC)
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Martin#1

MB1 wrote:
I would think that there is a distinct difference of putting the fact you do not have any hazardous substance in your workplace. It would be far more effective to put in place a system IF such substances do come into the workplace... How would this be managed, assessed and communicated?
I just don't want to write too much detail on a section that isn't applicable (and wont be read by employees) to the company
Martin#1  
#5 Posted : 30 November 2011 15:33:52(UTC)
Rank: Forum user
Martin#1

CW wrote:
Cleaning fluids such as bleach?
we have a cleaning contractor who comes in at night when the office has no staff working, they bring their own cleaning materials and equipment
Heather Collins  
#6 Posted : 30 November 2011 15:36:53(UTC)
Rank: Super forum user
Heather Collins

Martin. How about: All chemical substances for use at work to be purchased by Purchasing Dept MSDS to be obtained before purchase All MSDS to be examined by H&S Manager COSHH assessment to be carried out if required All staff to be informed of COSHH findings and given necessary training All staff to implement the findings of COSHH assessments including PPE if required Job done.
MB1  
#7 Posted : 30 November 2011 15:37:44(UTC)
Rank: Super forum user
MB1

I just don't want to write too much detail on a section that isn't applicable (and wont be read by employees) to the company
How much detail you wish to put is up to you, but from a risk management and liability point of view it would be wise to put something in or is your business confident in updating & communicating at very short notice should a substance turn up and place you in a position that you need to react to? Even a short statement would suffice, providing you are confident you do not have any substance that come under the category of hazardous to someones health?
MB1  
#8 Posted : 30 November 2011 15:38:45(UTC)
Rank: Super forum user
MB1

Hmmm Heather's fingers beat me to it!
Ron Hunter  
#9 Posted : 30 November 2011 15:45:08(UTC)
Rank: Super forum user
Ron Hunter

Looking beyond COSHH, you may need to consider the risk of exposure to asbestos. Relevant arrangements should already be described in the Asbestos Risk Register for the premises.
Martin#1  
#10 Posted : 30 November 2011 15:49:00(UTC)
Rank: Forum user
Martin#1

Heather Collins wrote:
Martin. How about: All chemical substances for use at work to be purchased by Purchasing Dept MSDS to be obtained before purchase All MSDS to be examined by H&S Manager COSHH assessment to be carried out if required All staff to be informed of COSHH findings and given necessary training All staff to implement the findings of COSHH assessments including PPE if required Job done.
thanks Heather, that should do the job cheers
Heather Collins  
#11 Posted : 30 November 2011 15:56:57(UTC)
Rank: Super forum user
Heather Collins

Martin As Ron says I'd have a separate section for asbestos. In a post-1999 building this is pretty simple! Even in an older one it can be simply dealt with if you already know whether you have asbestos in the building or not. I have written very simple safety policies for several clients. It's always best to put something in rather than saying "not applicable" for a subject as wide as hazardous substances. After all you never know what the future brings. BTW - what happens the morning that your cleaners have left the bleach and the acid toilet cleaner out and one of your staff decides they can do a better job of getting rid of stains on the sink by mixing the two... Just saying!
Murray18822  
#12 Posted : 30 November 2011 16:39:25(UTC)
Rank: Forum user
Murray18822

Heather Collins wrote:
Martin. How about: All chemical substances for use at work to be purchased by Purchasing Dept MSDS to be obtained before purchase All MSDS to be examined by H&S Manager COSHH assessment to be carried out if required All staff to be informed of COSHH findings and given necessary training All staff to implement the findings of COSHH assessments including PPE if required Job done.
It's an office safety policy. It's stated that there are no hazardous substances. Why include arrangements for a hazard that does not exist. Keep a sense of proportion about an office policy.
malcarleton  
#13 Posted : 30 November 2011 16:56:27(UTC)
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malcarleton

I think Heather hit the nail on the head, nice job. Any substance coming on to our site is COSHH Assessed before issue to the shop floor and any electrical appliances brought in are registered, bar coded and PAT tested by our O&M contractors before onward issue. We have clearly written process documents that cover the actions required to ensure incoming parts, equipment and substances are A: What we asked for B: Fit for purpose and C: safe. Its better to plan ahead and have a system in place that allows you to bring items and substances into the workplace in a safe and controlled manner even if you don't hold any such items or substances at present,
Murray18822  
#14 Posted : 30 November 2011 17:01:45(UTC)
Rank: Forum user
Murray18822

And approaching the management of health and safety based on that logic is creates an unnecessary level of bureaucracy!!
malcarleton  
#15 Posted : 30 November 2011 17:21:13(UTC)
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malcarleton

I'm the Safety Engineer for my company, I advise my managers and my advice is always the same, to be proactive rather than reactive. Lets not get things out of perspective here, all that's needed is a simple document that describes a safe way of receiving goods and materials. I actually think the PAT testing area of things is more relevant to an office environment, but that's not the question that was asked, their are substances in offices that could be harmful if mishandled, toner cartridges for example.
Clairel  
#16 Posted : 30 November 2011 18:03:23(UTC)
Rank: Super forum user
Clairel

malcarleton wrote:
I'm the Safety Engineer for my company, I advise my managers and my advice is always the same, to be proactive rather than reactive. Lets not get things out of perspective here, all that's needed is a simple document that describes a safe way of receiving goods and materials. I actually think the PAT testing area of things is more relevant to an office environment, but that's not the question that was asked, their are substances in offices that could be harmful if mishandled, toner cartridges for example.
Actually most things in an office wouldn't really need PAT except for very infrequently. Most woul dbe low risk, double insulated etc. Heather, sorry to disagree but if you start saying that someone needs an MSDS for bleach then I think that is going OTT.
srichards  
#17 Posted : 30 November 2011 18:43:53(UTC)
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srichards

Clairel - how to you define what you need an MSDS for and what you don't, if you don't obtain them for all substances ? Something that isn't a risk for one maybe a risk for another. I've always obtained them for all substances used/stored on site and the first aiders knew where they were for emergencies.
chris.packham  
#18 Posted : 30 November 2011 19:22:51(UTC)
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chris.packham

In my opinion anyone stating that there are no hazardous substances in any workplace is being somewhat incautious. I recently went through an office specifically to identify what one might find. It is interesting when you actually go thorugh cupboards, desk drawers, etc. what you find. No safety data sheets, of course, but lots of interesting information on the packaging! For several reasons I cannot be more specific, but since someone has mentioned toner cartridges, just consider what had triggered the request for my involvement. On replacing a toner cartridge in a largish laser printer a cartridge had broken open and spilled a considerable quantity of the toner on to work surfaces, carpet etc. The toner contained both epoxy compounds and carbon black. Not hazardous? Cleaning actually required an outside contractor as a normal vacuum cleaner would not be appropriate. Remember also what section 7(1) of COSHH states. In reality any substance can become hazardous, given certain circumstances. The fact that no hazards are shown on the safety data sheet is irrelevant. So I would tend to agree with Heather on this one. Chris
Bob Shillabeer  
#19 Posted : 30 November 2011 21:44:31(UTC)
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Bob Shillabeer

I have been trying to avoid posting now for quite some time as there seems to be a lot of rubbish posted on this forum. The thing about a policy is just that it does not need to have everything in it. At the office I worked the safety policy was a single page of overall intent. The arrangements was the place the details existed. It is easier to manage and update as and when required to cover all new issues and to remove those that no longer applied. The safety policy was signed by the CEO while the arrangements were signed off by myself and the head of business management as the two key owners of the arrangements. Perhaps I will post more in future if there is some senseable topics to discuss.
Ron Hunter  
#20 Posted : 30 November 2011 22:56:56(UTC)
Rank: Super forum user
Ron Hunter

Good call from Chris on the carbon black in toner cartridge spillage. Carbon black is an excellent conductor and can make for an interesting "bang" if unwitting office staff attempt to clear up with the works vacuum. Spillage is a call out to the copier maintenance company. Whilst they're in, ask them to show a few trusted individuals how to change a cartridge properly. Thereafter ensure only they are authorised to change cartridges.
Heather Collins  
#21 Posted : 30 November 2011 23:02:09(UTC)
Rank: Super forum user
Heather Collins

Murray18822 wrote:
It's an office safety policy. It's stated that there are no hazardous substances. Why include arrangements for a hazard that does not exist. Keep a sense of proportion about an office policy.
Murray - This IS keeping a sense of proportion. Six lines about what you'd do if a hazardous substance did get brought onto site is hardly over the top is it? I wouldn't include arrangements for every hazard but this is such a general one that I think something needs to be said other then "not applicable". Claire - I don't advocate the OTT filing of MSDS for every substance on site. In this case whether an MSDS was available in the office would depend on how and where the bleach was stored and if it was accessible to the office staff. Never worked in an office where people went into the cleaners' cupboard and "borrowed" stuff during the day? I know I have! Bob - I assumed from Martin's original wording that he was talking about the policy arrangements rather than the policy statement itself which I agree could be a single page. You quite often hear people talk about their "safety policy" when what they mean is the policy statement plus organisation plus arrangements. That's what I am describing here. Please do feel free to start a sensible topic though so we can all join in the discussion.
Jane Blunt  
#22 Posted : 01 December 2011 07:35:33(UTC)
Rank: Super forum user
Jane Blunt

ron hunter wrote:
Good call from Chris on the carbon black in toner cartridge spillage. Carbon black is an excellent conductor and can make for an interesting "bang" if unwitting office staff attempt to clear up with the works vacuum. Spillage is a call out to the copier maintenance company. Whilst they're in, ask them to show a few trusted individuals how to change a cartridge properly. Thereafter ensure only they are authorised to change cartridges.
To add to this. I know a case where someone damaged their lungs and vocal chords while trying to clear up a spillage in the wrong way. The damage appears to be permanent. Therefore, while these cartridges are safe in normal use, the procedures need to allow for the case where something goes horribly wrong and 700g of toner lands on the carpet.
bob youel  
#23 Posted : 01 December 2011 07:43:57(UTC)
Rank: Super forum user
bob youel

If U are certain that specific things do not apply do not put them in at all! Put in a comment covering any none included areas e.g. "Only areas that apply are include herein" or something similar. If U put in everything that may apply to U as a just in case situation U will never stop - Your policy should only cover what is needed
Heather Collins  
#24 Posted : 01 December 2011 08:43:23(UTC)
Rank: Super forum user
Heather Collins

bob youel wrote:
If U put in everything that may apply to U as a just in case situation U will never stop - Your policy should only cover what is needed
I don't think anyone has suggested putting in "everything that may apply" Bob - where are you getting that from? I simply believe that some potential hazards are too common not to have a few brief words about them in the policy arrangements to cover the "what if". To me this would include a brief statement about chemicals, manual handling, machinery, fire, etc. In a normal low risk office work place I wouldn't bother with - e.g. lead at work, DSEAR, power presses, etc, etc. Of course as a consultant, writing the absolute bare minimum certainly ensures that the client has to keep calling you back to change things. That's why I don't do it! I like my clients to know that what I give them is going to be OK for their business in a year's time, not just today. And no before someone says it, this isn't just unnecessary padding as an excuse to charge more - I don't do that either!
Kate  
#25 Posted : 01 December 2011 08:49:39(UTC)
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Kate

Why not just say that your policy is not to expose the office staff to hazardous substances?
redken  
#26 Posted : 01 December 2011 08:55:20(UTC)
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redken

As a client knowing very little except that there is an awful lot of H&S stuff I would want my consultant to use proessional judgement to tell me that I did not need to be concrened about hazardous substances. Heather may think she is not OTT but I would not hire her as a consultant on the basis of her opinions in this post and others. But what do I know since the original poster seems very happy with her advice. Ken
redken  
#27 Posted : 01 December 2011 09:26:17(UTC)
Rank: Super forum user
redken

ron hunter wrote:
Good call from Chris on the carbon black in toner cartridge spillage. Carbon black is an excellent conductor and can make for an interesting "bang" if unwitting office staff attempt to clear up with the works vacuum. .
Is that a fact? Extract from ICBA guide on carbon black - Dry vacuuming, with appropriate filtration, is the preferred method for removing surface dust and cleaning spills. http://www.carbon-black....carbonblackuserguide.pdf I trust this is not too provocative!
Jane Blunt  
#28 Posted : 01 December 2011 10:11:11(UTC)
Rank: Super forum user
Jane Blunt

A useful link Redken. I would not rule out the possibility of an ordinary vacuum cleaner causing ignition, but what an ordinary vacuum cleaner will certainly do is to spray the dust out of its exhaust for people to inhale. Hence the need for 'appropriate filtration'.
David Bannister  
#29 Posted : 01 December 2011 10:32:03(UTC)
Rank: Super forum user
David Bannister

Jane, "appropriate filtration" is most apposite to me at present. At home I decided to vacuum the loose dust from a newly re-exposed concrete floor, stupidly expecting the standard bag and filters to do the job. Wrong! My house now has very fine concrete (silica?) dust everywhere, excessive throat clearing has resulted in sore throats and clothes have developed their own sandpaper feel.
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