IOSH forums home
»
Our public forums
»
OSH discussion forum
»
What constitutes a hazardous substance for risk assessment according to COSHH?
Rank: Super forum user
|
“(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” - COSHH Regulation 2 (1) Interpretation
Paragraph 10 of the 6th edition of the Approved Code of COSHH states:
Employers should regard a substance as hazardous to health if it is hazardous in the form in which it may occur in the work activity. A substance hazardous to health need not be just a chemical compound, it can also include mixtures of compounds, micro-organisms or natural materials, such as flour, stone or wood dust.
Paragraph 35 includes the following concerning what substance hazards are come under these regulations:
When deciding whether the substances used or produced in the workplace are covered by COSHH, employers should also consider the following:
Different forms of a substance may present different hazards, eg substances may not be hazardous in solid form but may be hazardous when ground into fine powder or dust that can be breathed into the lings.
Nanoparticles (ie particles less than 100 nanometers) may be more toxic than larger particles of the same chemical substance.
Impurities in a substance can make it more hazardous, eg crystalline silica is often present in minerals which would otherwise present little or no hazard.
Some substances have a fibrous form which may present a potentially serious risk to health if the fibres are of a certain size or shape.
Some substances have a known health effect but the mechanism causing it is unknown, eg certain dusts of textile raw materials cause byssinosis.
Exposure to two or more substances at the same time or one after the other may have an added or synergistic effect
Epidemiological or other data eg reports of illness to new and emerging agents, indicate that a biological agent that does not already appear in The Approved List of biological agents could nevertheless cause a hazard to health.
One-off emergency situations arising out of the work activity, such as a dangerous chemical reaction or fire, could foreseeably produce a substance hazardous to health.
'Wet work' is one of the most frequently and consistently reported causes of irritant contact dermatitis. 'Wet work' is the term used to describe tasks involving prolonged or frequent contact with water, particularly in combination with soaps and detergents
Paragraph 67 states:
“It may be necessary to collect information on the properties and attributes of substances hazardous to health from a variety of sources to fully inform the assessment process.”
This makes it clear that relying on the safety data sheet for a COSHH risk assessment is not the correct approach. So anyone whose risk assessments for COSHH are based solely on the safety data sheet should urgently consider whether they might be of questionable validity!
Chris
|
|
|
|
Rank: Super forum user
|
And your point is?
It is well known just relying on an MSDS (of doubtful accuracy) is not good practice as a source of information for CoSHH/chemical health risk assessments.
There are many other reputable chemical/hazardous material sources of information / referrence books etc.
As for the CoSHH ACOP extract, just a standard HSE/UK approach to h&s - put a nice woolley catch all phrase/paragraph in there - just in case!! So, if they really wanted to the HSE could try it on
|
|
|
|
Rank: Super forum user
|
My point is very simple.
I frequently encounter employers where the risk assessments have been based exclusively on the safety data sheet. Indeed, there are several organisations which purport to provide COSHH risk assessments via the Internet. You send them your safety data sheets and they provide you with your risk assessments (note - no reference to how used, factory visit etc.). Several of these (including some large, well recognised health and safety consultants) exhibit at health and safety exhibitions offering this type of service. And how often do we see reference, even on this forum, to COSHH Safety Data Sheets.
Furthermore, the previous ACoPs for COSHH have indicated that the risk assessment can be based on the safety data sheet, this new edition has undergone a significant change.
So whilst many involved with COSHH and risk assessment may recognise that the risk assessment should not be based exclusively on the safety data sheet, there are still many out there that do not!
Chris
|
|
|
|
Rank: Super forum user
|
I think the confusion will continue and data sheets will remain the standard and sometimes only source of reference used.
I often come across employers who don't understand the difference between data sheets and CoSHH assessments - thinking them to be one and the same thing. "I'm using it as described on the tin, why do I need to do an assessment when I have this data sheet".
Or employers who do assessments that are simply a transfer of data from the data sheet - almost a copy and past exercise.
Can anyone think of any legal cases / HSE actions that relate to a lack of CosHH assessment or poor CosHH assessment?
JJ - what are the reputable sources you use?
|
|
|
|
Rank: Super forum user
|
Example:
Epoxy impregnated carbon fibre mat used in aerospace.
Claim for allergic contact dermatitis due to handling the mat
Investigation showed no release of the sensitiser (R43) from the mat
Further investigation showed a different cause (non-occupational) for the skin condition
However:
When for a different process the mat was softened with a solvent the sensitiser in the mat did become bioavailable. Incidentally, precautions for protection against the solvent had adequately controlled this potential exposure.
Client had not identified that different uses presented different hazards and this was also not covered by the safety data sheet as it dealt only with the mat as supplied.
Often the most difficult part of any risk assessment for skin exposure to chemicals is determining the real hazard arising when the chemical(s) is/are used. In many cases it is difficult to establish this as reference works usually only cover individual chemicals and not consequences when used/moxed. reacted etc.
Chris.
|
|
|
|
Rank: Super forum user
|
With regard to prosecutions, it seems that these are mostly on the basis of non-compliance with COSHH. There are plenty of these, for example some years ago the Photo-Me case, where a fine of £100,000 was imposed. The company did not have adequate control of exposure resulting in several cases of occupational contact dermatitis. Lack of adequate control arose due to the inadequacy of the risk assessments and consequence inadequate controls. So whilst the prosecution was not directly as a result on poor risk assessment this was the initial fault that led to the skin problems.
Chris
|
|
|
|
Rank: Super forum user
|
Chris
Further to the point you made at #5, would REACH use scenarios have highlighted the differing risks from the two uses of the same material?
LB
|
|
|
|
Rank: Super forum user
|
The problem with exposure scenarios under REACH is that the regulation does not address the problem of two different substances from two different manufacturers/importers. It is not clear whose responsibility it is to address the often complex issue of materials from different suppliers being mixed. Remember that REACH at present is only concerned with individual substances and does not cover mixtures.
Those exposure scenarios that I have seen have been singularly unhelpful. In some cases the downstream user, being the formulator, has simply attached several suppliers exposure scenarios to his safety data sheet, leaving the unfortunate end user to try to interpret the different guidance from the different substance providers. A discussion with representatives of the ECHA at an international skin conference in Amsterdam in June did little to enlighten me on this
Frankly, in my view it is a mess that will do little to help the end user, particularly SMEs. Some of the exposure scenarios that I have seen have been unintelligible even to me.
I prefer to fall back on section 6-1 of the original Health and Safety at Work etc. Act 1974. I take the view that in 1974 we passed an act that, if correctly applied, is superior to REACH.
Chris
|
|
|
|
Rank: Super forum user
|
Chris
For those of us who do not have your erudite knowledge on COSHH, sensitisers and so on, we tend to rely on the warning labels on the substance to identify whether it's a COSHH substance - that was your original opening gambit BTW. Unfortunately this approach tends to have identify almost everything as a COSHH product including Tippex, which I have never done a COSHH assessment for and don't intend to either.
Ray
|
|
|
|
Rank: Super forum user
|
Ray
I, too, have never done a risk assessment for Tippex. However, I have also never visited the factory where it is manufactured and where it could be an issue requiring risk assessment due to the quantity present!
By contrast I have on several occasions had to do a risk assessment in environments where there has been significant skin contact with water, and in the NHS with excessive hand washing.
This is often the crux of the problem. There are thousands of chemicals that are not listed as hazardous (i.e. no risk phrase allocated) and will thus not appear on the safety data sheet or package labelling, but where skin exposure can lead to occupational dermatitis. There are others, e.g. MCI/MI, which are often present at below the critical concentration for them to appear on the safety data sheet but which can cause allergic contact dermatitis at much lower concentration. Perhaps this is why I so often encounter risk assessments that are not based on the true hazard of the chemical(s) as used.
Chris
MCI/MI? Methylchloroisothiazolinone/Methylisothiazolinone, used as a preservative in cosmetics and water based paints. In one study significant levels of release as a vapour were occurring several days after the paint had been applied, sufficient in a closed room to cause an allergic contact dermatitis in someone already sensitised. This is a growing concern among the dermatological community!
|
|
|
|
Rank: Forum user
|
Get a life. Its been known for ever and a day that the safety data sheet will only provide information on the hazardous properties of the substances, any health effects associated with its use, how likely it is to get into the air or onto the skin, and what risk reduction measures should be used to control exposure to an acceptable level. The SDS doesn't.take into consideration how it is used, what quantities, what it is mixed with etc and therefore can only be used as an aid to the coshh assessment.
|
|
|
|
Rank: Super forum user
|
Racer
You say it has been known 'for ever and a day', and in that you are, of course, correct. The problem is that whilst in some circles it has long been known, in many others this has not been recognised. This is why those purporting to provide risk assessments based on the provision by the client of the safety data sheet and without a workplace visit can provide computerised risk assessments without even any knowledge about the client's operations. It is why so many of the risk assessments (in my case for skin exposure) that I encounter when first visiting a new client are of questionable validity.
It is also why occupational skin disease remains a significant cause of occupational ill health. Statistics in the UK are woefully inadequate. In other countries where they have better systems for identifying and recording this condition it is a major cause of occupational ill health. Statistics in Germany, for example, show that 35% of all recognised cases of occupational ill health were for skin disease. In Denmark it is the most common cause of occupational ill health. Yet when I looked in the workbook for the NEBOSH diploma the words 'skin' and 'dermatitis' did not appear in the index.
Chris
|
|
|
|
IOSH forums home
»
Our public forums
»
OSH discussion forum
»
What constitutes a hazardous substance for risk assessment according to COSHH?
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.