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Svick1984  
#1 Posted : 19 October 2018 11:58:51(UTC)
Rank: Forum user
Svick1984

Hi all, I'm wondering if somebody can help me with a query I have regarding MSDS's; I know that on section 2 of MSDS' the idea is that it denotes all the details on the hazards of the chemical and the potential effects and symptoms resulting from using them and section 16 denotes 'other information' gives any other information relevant to the chemical (including full text of hazard statements). What is confusing me, is whilst section 2 denotes some hazard statements, it doesn't include them all (where section 16 basically lists many more). Example; I am looking at a MSDS for a particular product, and whilst section 2 lists the following hazard statements (H315, H317, H318, H335, H417), in section 16 it lists aforementioned hazard statements but also the following (H301,302, 311, 312, 314, 319, 331, 332, 335, 351 etc etc). Why is this? Surely if it's applicable they would all be mentioned in Section 2? And if they aren't applicable, why are they listed? It's a bit concerning because some of them are fairly serious hazard statements (for example, H351 suspecting of causing cancer) and completely changes my risk assessment from general ventilation, selecting PPE etc to much more detailed engineering controls. Have I misinterpreted the MSDS or is there a reason why all hazard statements/risk phrases are not mentioned in Section 2? Thanks for your help in advance.    

A Kurdziel  
#2 Posted : 19 October 2018 12:42:23(UTC)
Rank: Super forum user
A Kurdziel

Look at post “SDS Question... - Conflicting sections within the SDS Sheet??”, from few days ago. Same question and I think the same answer applies. In essence Section 2 covers the safety of the product (which might be a mixture of ingredients) as used and Section 16 will mention all of the components which may not pose a risk as they are in small concentration but it might be useful to know depending on what for or how you are using the product.

Roundtuit  
#3 Posted : 19 October 2018 17:30:19(UTC)
Rank: Super forum user
Roundtuit

One of the things I check is that Section 16 tallies with the content of Section 2 & 3

Some times I find there are more actual H statements (not number of statements) listed in 16 than appear in 2 and/or 3 which then provokes some awkward questions back to the provider of the SDS

"Can you tell me why Section 16 lists H412 that does not appear in either Section 2 or 3?"

Roundtuit  
#4 Posted : 19 October 2018 17:30:19(UTC)
Rank: Super forum user
Roundtuit

One of the things I check is that Section 16 tallies with the content of Section 2 & 3

Some times I find there are more actual H statements (not number of statements) listed in 16 than appear in 2 and/or 3 which then provokes some awkward questions back to the provider of the SDS

"Can you tell me why Section 16 lists H412 that does not appear in either Section 2 or 3?"

Svick1984  
#5 Posted : 22 October 2018 13:19:15(UTC)
Rank: Forum user
Svick1984

Originally Posted by: Roundtuit Go to Quoted Post

One of the things I check is that Section 16 tallies with the content of Section 2 & 3

Some times I find there are more actual H statements (not number of statements) listed in 16 than appear in 2 and/or 3 which then provokes some awkward questions back to the provider of the SDS

"Can you tell me why Section 16 lists H412 that does not appear in either Section 2 or 3?"

Exactly this; I'm confused as to why all H statements mentioned in section 16 aren't mentioned in 2 and/or 3. I'm trying to complete RA's (using the HSE's COSHH E-tool) and I'm stuck on completing some of them because I don't know whether to include H statements mentioned in section 16 or not. A Kurdziel - If the concentrates are so small, why mention them? For me, if they are mentioning them, then they are acknowledging there is a risk there - no matter how small - and therefore surely should be mentioned in section 2 as well??

pseudonym  
#6 Posted : 22 October 2018 14:02:31(UTC)
Rank: Forum user
pseudonym

‘All things are poisons, for there is nothing without poisonous qualities. It is only the dose which makes a thing poison.’ So said a fella going by the name Paracelcus a long time ago. 

Consider something like a bottle of coke - look carefully and it might contain phosphoric acid - not something I'd like to drink, but its use is fine in the bottle of coke bcause of the end concentration is so low. Now back to Safety Data Sheets - there might be a valid reason for including the 'H' statements for the ingredients of a product - perhaps incompatibility on disposal or on spill clean up? The 'H' statements are all listed because perhaps if you ended up flushing 100litres down the drain you might breach your environmental permit for instance

thanks 1 user thanked pseudonym for this useful post.
A Kurdziel on 22/10/2018(UTC)
chris.packham  
#7 Posted : 22 October 2018 14:41:37(UTC)
Rank: Super forum user
chris.packham

I would be cautious about conducting risk assessments for COSHH based purely on the safety data sheet, despite that this is the approach that COSHH essentials takes. Indeed the ACoP for COSHH actually does not recommend this approach. If you consult the latest edition of the ACoP this is what you will find:

Paragraph 10 - 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.

This is in accordance with the actual COSHH regulations. Regulation 2(1) includes the following:

“(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

There are thousands of chemicals that have never been assigned a Hazard Statement that can cause damage to health, particularly where skin exposure is concerned. For example, in his book on  patch testing Anton de Groot lists 4900 chemicals knows to dermatologists as skin sensitisers. Only a small percentage of these will have been assigned H317 and appear as such on a safety data sheet. The most common cause of occupational contact dermatitis is exposure to water. When did you last see water on a safety data sheet.

Risk assessments for chemical exposure must start with the real hazard when the chemical is used, not what is on the safety data sheet. Otherwise you could well end up with an invalid risk assessment.

thanks 1 user thanked chris.packham for this useful post.
A Kurdziel on 22/10/2018(UTC)
Roundtuit  
#8 Posted : 22 October 2018 14:51:56(UTC)
Rank: Super forum user
Roundtuit

Originally Posted by: Svick1984 Go to Quoted Post
Originally Posted by: Roundtuit Go to Quoted Post

One of the things I check is that Section 16 tallies with the content of Section 2 & 3

Some times I find there are more actual H statements (not number of statements) listed in 16 than appear in 2 and/or 3 which then provokes some awkward questions back to the provider of the SDS

"Can you tell me why Section 16 lists H412 that does not appear in either Section 2 or 3?"

Exactly this; I'm confused as to why all H statements mentioned in section 16 aren't mentioned in 2 and/or 3. I'm trying to complete RA's (using the HSE's COSHH E-tool) and I'm stuck on completing some of them because I don't know whether to include H statements mentioned in section 16 or not. A Kurdziel - If the concentrates are so small, why mention them? For me, if they are mentioning them, then they are acknowledging there is a risk there - no matter how small - and therefore surely should be mentioned in section 2 as well??

You do not use Section 16 it is purely explanatory.

Section 2 is what you purchase to handle i.e. the object of your assessment

Section 3 details what hazardous substances it contains above their notifiable threshold if it is a mixture.

The Classification Labelling & Packaging Regulations set the rules

thanks 2 users thanked Roundtuit for this useful post.
JohnW on 23/10/2018(UTC), JohnW on 23/10/2018(UTC)
Roundtuit  
#9 Posted : 22 October 2018 14:51:56(UTC)
Rank: Super forum user
Roundtuit

Originally Posted by: Svick1984 Go to Quoted Post
Originally Posted by: Roundtuit Go to Quoted Post

One of the things I check is that Section 16 tallies with the content of Section 2 & 3

Some times I find there are more actual H statements (not number of statements) listed in 16 than appear in 2 and/or 3 which then provokes some awkward questions back to the provider of the SDS

"Can you tell me why Section 16 lists H412 that does not appear in either Section 2 or 3?"

Exactly this; I'm confused as to why all H statements mentioned in section 16 aren't mentioned in 2 and/or 3. I'm trying to complete RA's (using the HSE's COSHH E-tool) and I'm stuck on completing some of them because I don't know whether to include H statements mentioned in section 16 or not. A Kurdziel - If the concentrates are so small, why mention them? For me, if they are mentioning them, then they are acknowledging there is a risk there - no matter how small - and therefore surely should be mentioned in section 2 as well??

You do not use Section 16 it is purely explanatory.

Section 2 is what you purchase to handle i.e. the object of your assessment

Section 3 details what hazardous substances it contains above their notifiable threshold if it is a mixture.

The Classification Labelling & Packaging Regulations set the rules

thanks 2 users thanked Roundtuit for this useful post.
JohnW on 23/10/2018(UTC), JohnW on 23/10/2018(UTC)
JohnW  
#10 Posted : 23 October 2018 17:14:09(UTC)
Rank: Super forum user
JohnW

Svick, exactly as Roundtuit says, ignore Section 16 in your COSHH assessment - as pseudonym says, if we used Section 16 for labelling then we wouldn't drink Coke.

But please say if the explanations here are understood?

chris.packham  
#11 Posted : 24 October 2018 06:57:48(UTC)
Rank: Super forum user
chris.packham

Whilst I am not saying ignore the safety data sheet, what I am saying is that you need to look beyond it if you want to ensure a valid risk assessment. In the first place how accurate are they? In a wide ranging study the ECHA stated that 52% of those they examined were 'deficient'. Furthermore, we purchase chemicals to use. In the process it is almost inevitable that we change then (contamination, mixing, reacting, diluting, oxidising, etc.). As a result we frequently change the hazard present when a task is being carried out. It is this hazard on which we need to base the risk assessment, not what is on the safety data sheet. So the risk assessment starts with what we are doing (the task), what chemicals are being used during the task. How they are being used and what hazard arises out of this use. Then what exposure occurs to this new hazard and the potential consequences. In my work I see many risk assessments based on safety data sheets that are simply incorrect and some that are actually putting health at risk.

pseudonym  
#12 Posted : 24 October 2018 10:29:55(UTC)
Rank: Forum user
pseudonym

I once used 'painting a door' as an analogy to try to explain COSHH etc:

You would sand the old paint off the door - potentially exposing you to paint / wood dust, then you would apply filler to any cracks etc (potentially exposing you to filler), then an undercoat (paint) then clean your brushes (solvent cleaner), after a bit you would end up applying the final coat (more paint) and finally clean up afterwards - solvents etc - what I tried to emphasise was that when cleaning the brushes etc you'd be exposed to paint AND solvent, when sanding down it would be wood dust AND whatever else was on the door etc ..

Got to admit though I still doubt if they got my point!

chris.packham  
#13 Posted : 24 October 2018 11:35:11(UTC)
Rank: Super forum user
chris.packham

pseudonym - And the solvent would contain chemicals, possibly toxic, from the paint and take these into and through the skin to reach internal organs that the paint on its own would not! That's the point about the 'real' hazardd during the task.

I agree, however, than many either do not get the point - or perhaps prefer to look the other way.

Roundtuit  
#14 Posted : 24 October 2018 11:57:43(UTC)
Rank: Super forum user
Roundtuit

Or they get led on a particular path thanks to the limitations of market "solutions" including those offered by the regulator e.g. Risk phrases should have ceased to appear on an EU SDS at 1st June 2017 so why does the HSE e-Tool not flag attempts to input out of date information?

Roundtuit  
#15 Posted : 24 October 2018 11:57:43(UTC)
Rank: Super forum user
Roundtuit

Or they get led on a particular path thanks to the limitations of market "solutions" including those offered by the regulator e.g. Risk phrases should have ceased to appear on an EU SDS at 1st June 2017 so why does the HSE e-Tool not flag attempts to input out of date information?

JohnW  
#16 Posted : 24 October 2018 17:47:52(UTC)
Rank: Super forum user
JohnW

An example of a COSHH assessment that requires knowledge of the use of a material are 'cutting oils', these are used in CNC machines to cool/lubricate the cutting tool. Of  particular importance are those which are diluted with water before use. They are sold as a 'concentrate'.

In the MSDS of the concentrate Hazard Statements and symbol warn of eye irritation and skin irritation, but make no mention of the added hazard when diluted with water and when used in the machine - a mist is created which may cause asthma after repeated exposure.

The cutting process (2000 -20000 rpm) takes place when the CNC cabinet is closed, usually protected by an interlock, which contains the mist until the cabinet is opened. The higher speeds will have created mist droplets which persist/linger around and can exit as a cloud in the operator's breathing zone and circulate into the factory. Droplets 0.3 - 3.5u are suspected of causing asthma, and can contain bacteria. For this reason the HSE inspectors are insisting all older CNC cabinets be retro-fitted with an LEV to reduce mist in the cabinet and prevent a cloud of mist exiting when the door is opened.

Oh sorry, that explanation is long. But this is the explanation I have to provide to clients to explain why they or similar companies have had Improvement Notices, and why the hazard will be included in the COSHH assessments and also in the machine PUWER and Risk Assessments.

MSDS from Kuwait Oils, Quaker Chemicals and others make no mention of respiratory hazard of the diluted substance used in CNCs.

Edited by user 24 October 2018 19:31:56(UTC)  | Reason: typos

Roundtuit  
#17 Posted : 24 October 2018 19:07:43(UTC)
Rank: Super forum user
Roundtuit

Because an SDS as mandated by the various global interpretations of GHS is prepared relative to the product as supplied and shipped - not as used in a particular country, industry, business.

That is why EU legislation clearly states an SDS it is to allow an employer to conduct an assessment.... not just issue an SDS instead of.

What we are now meant to be seeing in Europe are e-SDS - extended documents that also consider hazards associated with uses notified to, and considered by the supplier of the substance or mixture. Suppliers are not required to "guess" what an end user may use their product for, and in future if an e-SDS specifically precludes how a product is currently used within your business you will have no claim or defence unless you can demonstrate you did communicate back along the supply chain.

Roundtuit  
#18 Posted : 24 October 2018 19:07:43(UTC)
Rank: Super forum user
Roundtuit

Because an SDS as mandated by the various global interpretations of GHS is prepared relative to the product as supplied and shipped - not as used in a particular country, industry, business.

That is why EU legislation clearly states an SDS it is to allow an employer to conduct an assessment.... not just issue an SDS instead of.

What we are now meant to be seeing in Europe are e-SDS - extended documents that also consider hazards associated with uses notified to, and considered by the supplier of the substance or mixture. Suppliers are not required to "guess" what an end user may use their product for, and in future if an e-SDS specifically precludes how a product is currently used within your business you will have no claim or defence unless you can demonstrate you did communicate back along the supply chain.

chris.packham  
#19 Posted : 25 October 2018 07:44:50(UTC)
Rank: Super forum user
chris.packham

Re the comment on the metalworking fluid (WMF). Water-mixed metalworking fluids almost always contain a biocide to prevent bacterial spoilage. We had a case of a client's employee developing dermatitis from exposure to the WMF. Test showed allergy to formaldehyde, the biocide then in use. Employer sourced a different WMF with no formaldehyde shown on data sheet. Machine cleaned - filled with new WMF. Dermatitis returned. Examination showed that WMF contained a biocide that was a formaldehyde releaser. Formaldehyde not shown on safety data sheet as not in product as supplied, so not recognised as hazard in new risk assessment! It isn't what you buy, its what you use that matters! Actually questionnable whether supplier was complying with section 6-1 of Health and Safety at Work etc. Act.

JohnW  
#20 Posted : 25 October 2018 09:52:30(UTC)
Rank: Super forum user
JohnW

Chris, yes a good point mentioning biocide. In my experience the MWF suppliers will usually provide bacteria monitoring as part of their service, or provide clients with dip-slides and a small incubator to do the testing in-house, and given a visual chart to compare. They are also provided with a biocide additive to dose the MWF sump as required. Following what you have said, I will review any biocide COSHH assessments that I have done.
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