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jon joe  
#1 Posted : 18 May 2015 16:41:09(UTC)
Rank: Forum user
jon joe

New place I've started work at. They are sent Safety Material mData Sheets with any Chemical brought on Site. They don't have any formal COSHH Risk Assessment, but use Hazard Labels instead.....Is this enough???
leadbelly  
#2 Posted : 18 May 2015 16:59:19(UTC)
Rank: Super forum user
leadbelly

As the point of the risk assessment is to assess the risks from how the substances are used (information which is not included in the SDSs, of course), the SDSs and hazard labels are almost certainly insufficient. If you don't have the necessary expertise in-house, you should find an occupational hygienist to help you: http://www.bohs.org/OHServices-directory/ LB
toe  
#3 Posted : 18 May 2015 20:57:29(UTC)
Rank: Super forum user
toe

Do you use these chemicals? or just have them stored in a warehouse for example and then they move on to suppliers.
jon joe  
#4 Posted : 18 May 2015 23:08:31(UTC)
Rank: Forum user
jon joe

Toe wrote:
Do you use these chemicals? or just have them stored in a warehouse for example and then they move on to suppliers.
yes the Company use these materials, and quite often...the mill can be horrible but a Safety Consultant who is hired by the company, has stated the Labels are fine...I have looked at Sypol, heard they are a good company for helping to assess the risks...if you've had any dealings with them?
toe  
#5 Posted : 18 May 2015 23:55:16(UTC)
Rank: Super forum user
toe

Hi, thanks for getting back so quickly. Yes I have heard of them, but never used their software. I am not a great fan of using software for conducting COSHH risk assessments, these are better completed on site where the environment, people, storage, the way they are used, etc. are all taken into consideration. If you are considering using software for your assessments take a look at the HSE free site see link below. http://www.hse.gov.uk/coshh/essentials/
PG71  
#6 Posted : 19 May 2015 01:51:54(UTC)
Rank: New forum user
PG71

Jon Joe, you must also make sure that these SDS's are in compliance with the new CLP labelling and packaging system : http://www.hse.gov.uk/ch...ion/labelling-packaging/
Ron Hunter  
#7 Posted : 19 May 2015 12:29:16(UTC)
Rank: Super forum user
Ron Hunter

Perhaps we lack full context here. There is often no need for a separate assessment (another piece of paper) just to satisfy COSHH. It is perfectly reasonable in some circumstances to conclude that it is sufficient to follow the instructions on the container/tin etc. (the consultant's reference to labels perhaps?) particularly where products are low volume containers (i.e no real problems with spillage) ,aerosols etc. The whole TASK Risk Assessment could reference these simple controls and obviate the need for any separate "COSHH" assessment. Even for a more complex task, COSHH considerations can also be included in the TASK R/A Either way there should be apropriate supervision to ensure controls are followed. I'd look at things from first principles before considering (IMO added complexity of) Sypol etc.
Billibob  
#8 Posted : 19 May 2015 13:01:51(UTC)
Rank: Forum user
Billibob

A number of years ago we had a visit from the HSE regarding COSHH assessments and their view was that because this was a "specialist" area using the general risk assessment for COSHH does not always work especially where you are using some complex substances. To address this issue and ensure that assessments are updated and available we went down the electronic route and purchased the SHE Enterprise software (after looking at different software) because we wanted to put all our risk assessments onto an electronic system (e.g. activity risk, workplace risks, manual handling, DSE, COSHH, Fire etc). We also wanted the facility to allow people to put hazards onto the system without having to log in and also general viewing access (so again you don't have to log in). In addition we have designed our own risk assessments to include on the system and with the Assure version we have been able to put our own structure onto the system to make it easier to find (over 3000 assessment on currently). I would say if you are looking for an electronic assessment system ask do you just want COSHH or other assessments?
A Kurdziel  
#9 Posted : 19 May 2015 13:03:33(UTC)
Rank: Super forum user
A Kurdziel

As Ron has said the duty is to assess the risk- simply giving people sight of the SDS or the label is not enough. How complex the RA is depends on the overall work. For simpler industrial process where the risk from substances is marginal then you can just capture the COSHH bit in the main document. By marginal I mean something like a painting job where you can basically tell staff to rely in the manufacturer’s instructions but if the process is more complicated or using the substances in way not specified by the manufacturer , eg in chemical process then you definitely need some sort of in-depth assessment.
A Kurdziel  
#10 Posted : 19 May 2015 13:09:12(UTC)
Rank: Super forum user
A Kurdziel

As to the software mentioned, I have never understood how you can create a suitable and sufficient COSHH assessment remembering that the assessment has to be TASK specific. All it can do is take out various precautions mentioned in the SDS and tell you to apply them, without establishing whether they may or may not be appropriate.
jon joe  
#11 Posted : 19 May 2015 15:29:02(UTC)
Rank: Forum user
jon joe

The Software from what I've ben told by a friend who uses it at the Company he works, the Software asks specific questions regarding quantities being used, ventilation, how often being used etc. I would have thought this should be enough, and as long as the information given in the COSHH SHeet, make judgement on what procedures should be put in place, or updated.... Ron...Some of the Mixes being used (and im very new at my job), are quite hazardous...dust is also an issue in the Warehouse, so I think COSHH RIsk Assessment is defiantly needed....Was thrown off, when the Safety Consultant told me otherwise
Roundtuit  
#12 Posted : 19 May 2015 20:14:20(UTC)
Rank: Super forum user
Roundtuit

Having the life experience of seeing the introduction of the COSHH regulations I would challenge any "software" to supply a suitable and sufficient assessment - like ALL desktop studies these work on the management perspective of what is perceived (quantity, time, handling etc.) to happen rather than the physicality of what TRULY happens in the real world. Try it - take your last management approved RA and then watch three separate operatives undertaking the exact same task individually - production outcome the same but methods employed to achieve the goal uniquely different especially where multiple shifts / operatives are employed (unless you are lucky enough to have that holy grail of a workforce capable of the Standard Job). e.g. wear eye protection - Which type? The corporate mandated light eye protection, that wholly suitable for the task being undertaken or the purchasing departments "one size fits all". Oh and PG71 you are both forgiven and at the same time admonished - date line 19th May 2015 and the suppliers of mixtures may still provide an MSDS with orange pictograms Risk & Safety phrases. Manufacturers must change at the end of this month HOWEVER for materials already in the supply chain (affecting the majority of users) with distributors mixtures can be supported with these "old" classifications until June 2017! From a one size fits all philosophy an absolute disaster as some MSDS will have Risks phrases whilst other SDS have Hazard statements (and effective 1st June 2015 there are no longer direct read across tables R** = H*** available as classification must be from first principles). Put that in your software and get a sensible outcome.
Roundtuit  
#13 Posted : 19 May 2015 20:14:20(UTC)
Rank: Super forum user
Roundtuit

Having the life experience of seeing the introduction of the COSHH regulations I would challenge any "software" to supply a suitable and sufficient assessment - like ALL desktop studies these work on the management perspective of what is perceived (quantity, time, handling etc.) to happen rather than the physicality of what TRULY happens in the real world. Try it - take your last management approved RA and then watch three separate operatives undertaking the exact same task individually - production outcome the same but methods employed to achieve the goal uniquely different especially where multiple shifts / operatives are employed (unless you are lucky enough to have that holy grail of a workforce capable of the Standard Job). e.g. wear eye protection - Which type? The corporate mandated light eye protection, that wholly suitable for the task being undertaken or the purchasing departments "one size fits all". Oh and PG71 you are both forgiven and at the same time admonished - date line 19th May 2015 and the suppliers of mixtures may still provide an MSDS with orange pictograms Risk & Safety phrases. Manufacturers must change at the end of this month HOWEVER for materials already in the supply chain (affecting the majority of users) with distributors mixtures can be supported with these "old" classifications until June 2017! From a one size fits all philosophy an absolute disaster as some MSDS will have Risks phrases whilst other SDS have Hazard statements (and effective 1st June 2015 there are no longer direct read across tables R** = H*** available as classification must be from first principles). Put that in your software and get a sensible outcome.
chris.packham  
#14 Posted : 19 May 2015 22:50:26(UTC)
Rank: Super forum user
chris.packham

The safety data sheet is not the correct starting point for a COSHH risk assessment. We buy chemicals to use for a purpose. Frequently the use changes the characteristics of the chemical and thus the hazard. In any event the safety data sheet will generally only include those chemicals that have been assigned a hazard statement (or previously a risk phrase). There a literally thousands of chemicals that in contact with the body can cause damage to health that have not been identified as hazardous, i.e. have not been assigned a risk phrase, and will therefore not appear on the safety data sheet. As has already been mentioned, the risk assessment has to be task based. You need first to identify what happens during the task, what chemicals are used and how they are used. You can then determine what the real hazard is and then what exposure there is. From that you can decide what the risk is. Without a workplace visit this is simply not possible, so the computer based risk assessments can frequently provide you with what appears to be a risk assessment but is totally invalid. Firstly have a careful read of the relevant sections in the sixth edition of the ACoP for COSHH. This makes it clear that the safety data sheet is not an adequate basis for a risk assessment. Just to support this, I have recently received a copy of de Groots' latest book on patch testing for skin sensitisation. It lists 4,350 chemicals which dermatologists consider skin sensitisers, only a tiny fraction of which will have been listed as H317. As a final note, the most common cause of occupational contact dermatitis is 'wet work', i.e. exposure to water and the wearing of chemical protective gloves. When did you see either of these mentioned in a safety data sheet? Chris
chris.packham  
#15 Posted : 19 May 2015 22:55:05(UTC)
Rank: Super forum user
chris.packham

Just as an addition comment to my posting consider the following: A study by the European Chemicals Agency (ECHA), the organisation responsible for REACH, found that of 1,181 companies they inspected in 29 countries, mostly ‘downstream users’, i.e. formulators, regarding compliance with REACH, 52% were producing safety data sheets described in the study as ‘deficient’. ECHA – REACH-EN-FORCE2 So could you rely upon the information in the safety data sheet anyway, even assuming that this is the correct approach? Chris
aud  
#16 Posted : 19 May 2015 22:57:34(UTC)
Rank: Super forum user
aud

Billibob Did I read you right - 3000 risk assessment records?
A Kurdziel  
#17 Posted : 20 May 2015 10:19:20(UTC)
Rank: Super forum user
A Kurdziel

aud wrote:
Billibob Did I read you right - 3000 risk assessment records?
Is that a record? I bet you have one for every substance that you use or might use... My last employer (research) had hundreds but they had begun to reduce the number to something more manageable. One team lost 65 COSHH assessments due to a computer glitch so they replaced them with 5 better assessments. It's not the number the counts it's the quality.
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