Rank: Super forum user 
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Hoping someone may eb able to shed some light, couple queries in relation to Safety Data Sheets.
Product A has been "classified" as Extremely Flammable R12. The SDS then goes on to provide a list of the ingredients contained within Product A which includes Naphtha, R65 Harmful. Naphtha forms 3% or less of the overall product. Would Product A be classed as "Harmful" and therefore a COSSH assessment should be undertaken? (and if so, why would this not be stated in the "hazard classification” section).
Product B has not be classified as having any risk phrases but the ingredient section of the SDS states that Product B contains no more than 5% of a R22 / R41 chemical and no more than 10% of a R36 chemical. Would Product B be deemed hazardous?
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Rank: Super forum user
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R12 Extremely Flammable, as such would not trigger a CoSHH assessment. Flammability is nothing to do with COSHH.
If I recall correctly, the classification of substances is determined by consulting the Approved Supply List document, I think these were part of the CHIP (Chemical Hazard Information and Packaging Regs)
However these documents change frequently and may possibly be superceeded by REACH.
A product/chemical doesn't have to be classed as 'Harmful' etc to trigger off a COSHH assessment. There is a catch all phrase in the wording of the CoSHH regs to catch just about anything, that may cause ill health as a result of exposure.
CoSHH is also about the way substances are used, not just their inherent properties.
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Rank: Super forum user
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JJ Prendergast wrote:R12 Extremely Flammable, as such would not trigger a CoSHH assessment. Flammability is nothing to do with COSHH.
If I recall correctly, the classification of substances is determined by consulting the Approved Supply List document, I think these were part of the CHIP (Chemical Hazard Information and Packaging Regs)
However these documents change frequently and may possibly be superceeded by REACH.
A product/chemical doesn't have to be classed as 'Harmful' etc to trigger off a COSHH assessment. There is a catch all phrase in the wording of the CoSHH regs to catch just about anything, that may cause ill health as a result of exposure.
CoSHH is also about the way substances are used, not just their inherent properties. Thanks JJ, I'm aware that flammable materials do not trigger a COSHH assessment, which is why I gave it as an example. These substances are all very low risk, it's in a retail environment, but I'm just interested to find out for definite the meaning of the SDS. In the example I gave, 3% of the flammable substance is a chemical that is harmful, I'm wondering if this means the substance its self is deemed harmful, or (as my common sense approach would say) that the harmful ingredient is in such low quantities that the overall product is not deemed harmful. Using the reasonably practicability benchmark and the use if my common sense interpretation is correct, this doesn’t need to be subject to a COSHH assessment. If I'm wrong, then we'll document the assessment and put very basic controls in place commensurate to the risk.
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Rank: Super forum user 
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Jake
To raise awareness for my shopfloor personnel I've taught them 'anything with a hazard warning label - black and orange is to be flagged up and checked for a CoSHH assmt'. Where there's no assmt then a msds is sought and an assmt is produced whether its harmful or just flammable. Other products are checked as well but with this system I'm receiving good feedback and educating them at the sharp end at the same time.
Badger
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Rank: Super forum user
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'To raise awareness for my shopfloor personnel I've taught them 'anything with a hazard warning label - black and orange is to be flagged up and checked for a CoSHH assmt'.'
The problem here is just about every substance now carries a hazard warning label - for example, even Tippex! I've never done a COSHH RA for Tippex and don't intend to start now.
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Rank: Super forum user
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The point you need to consider is what the real hazard is when the chemical is used. The safety data sheet provides only limited information, usually only about those substances that have been allocated a risk phras - or now a hazard statement according to the CLP Regulations. It only provides information on the product as supplied and not as used. In use it may be contaminated, mixed with others, reacted oxidised, etc., etc., and the real hazard may be very different from that on the safety data sheet.
Just take a look at two items. The first is definition (e) in regulation 2(1) of COSHH (see below). The second is paragraph 13 of the COSHH ACoP. These explain why the safety data sheet is only one source of information for a risk assessment according to COSHH.
“(e) which, not being a substance falling within sub-paragraphs (a) to (d), because of its chemical or toxicological properties and the way it is used or is present at the workplace creates a risk to health” In essence, any chemical can become a substance hazardous to health. Note that the key is "...how it is used or is present at the workplace..."
In reality there are thousands of chemicals that have never been classified as hazardous, i.e. have never born a risk or safety phrase, but that, for example, in contact with the skin could cause occupational contact dermatitis. The most common cause of occupational irritant contact dermatitis is wet work, i.e. excessive skin contact with water.
Two statements by the HSE as guidance for their inspectors:
“HSE’s experience suggests that a large proportion of SDSs do not provide adequate or correct information on hazards and exposure controls.”
“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.”
From:- HSE – Topic Inspection Pack, Work Related Dermatitis
The latter refers to section 6-1 of the Health and Safety at Work etc. Act 1974.
Some time ago I presented at IOSH regional meetings on this aspect of risk assessment. If you are interested I have the handout for this presentation and if you PM me with your e-mail I will happily send you this.
Chris
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Rank: Forum user
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Again this is the difference in understanding the differences between CHIP / CLP/ REACH which requires/ed a MSDS and COSHH.
MSDS are in relation to the 'supply' of a product - it is for the information on storage and transport and basic information on the generic use of the product.
However, COSHH is about the assessment of the hazards of the 'specific use' of the product, of which the information on the SDS is only one very small part.
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Rank: Super forum user
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The classification is based on thresholds/bands, hence when susbtances or even preparations (Individual ingredients) are mixed to form a preparation, the thresholds then related to the preparation. Due to the "dilution" , it is possible that even when individual ingredients had specific risk phrases, the preparation may have different or no risk phrases. Most of the health related risk phrases are to with Lethal Concentration (LC) or Lethal Dose (LD 50) values . CLP/GHS uses the terms Hazard Statements instead of Risk Phrases. These values are expressed as mg/kg
For example
R27 Very toxic in contact with skin :-Acute toxicity results: LD 50, dermal, rat or rabbit: < 50 mg/kg
R24 Toxic in contact with skin :-Acute toxicity results: LD,50 dermal, rat or rabbit: 50 < LD50 <400 mg/kg
R21 Harmful in contact with skin:- Acute toxicity results: LD50 , dermal, rat or rabbit: 400 < LD50 <2000 mg/kg
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Rank: Super forum user
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The question of dilution as mentioned already is an interesting one. Dilution may reduce irritancy or not, depending on how the substance's pH is affected. However, with at least one chemical (2-butoxyethanol) dilution with water will actually increase skin update and the potential for systemic effects. (Study by Erlangen University presented at an occupational health conference in Innsbruck some years ago.)
Another point to consider is the effect of enzymes in the stratum corneum on a chemical absorbed into the skin. For example, methanol is not normally considered as a sensitiser. However, enzymes in the skin can in some cases metabolise methanol and one of the metabolites is formaldehyde, a potent sensitiser. Of course, this will not be shown on the safety data sheet! I have had a case where a worker, sensitised to formaldehyde, actually reacted with an allergic contact dermatitis to methanol. Neither the employer nor the GP could understand this until the metabolism was pointed out to them.
Chris
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Rank: Super forum user
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Thanks for the replies chaps.
All points taken on board. I'm relatively familiar with COSHH and the assessment process, it was a specific query regarding the interpretation of the SDS, this hasn't come up before as all the other chemicals / processes I've assessed there has been no doubt about the hazardous nature of the substance!
I think the last post by Jay confirms what I thought regarding the substance.
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