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Monopoly  
#1 Posted : 01 May 2020 16:34:18(UTC)
Rank: Forum user
Monopoly

Hello 

A bit of advice trying to understand safety data sheets please. This is an extract from one for a product giving advice around the use of respiratory equipment:

Respiratory protection  - No specific recommendations. Respiratory protection must be used if the airborne contamination exceeds the recommended occupational exposure limit. Use chemical cartridge protection with appropriate cartridge. If ventilation is inadequate, suitable respiratory protection must be worn. Wear a respirator fitted with the following cartridge: Combination filter, type A2/P3

In section 8 it lists the chemicals in the product that has LTELS and STEL , for example:

XYLENE Sk Short-term exposure limit (15-minute): WEL 100 ppm 441 mg/m³ Long-term exposure limit (8-hour TWA): WEL 50 ppm 220 mg/m³ PETROLEUM GASES, LIQUEFIED; PETROLEUM GAS Long-term exposure limit (8-hour TWA): WEL 1000 ppm 1750 mg/m³ Short-term exposure limit (15-minute): WEL 1250 ppm 2180 mg/m³

How do you work out if an exposure limit has been breached? The STEL for xylene is 100 ppm , how can this be measured? Should there be information with the product that says typicallly so many parts of the product will be in a millions parts of contaminated air over a certain period time when being used?

peter gotch  
#2 Posted : 01 May 2020 16:52:36(UTC)
Rank: Super forum user
peter gotch

Monopoly

You can't assess the likely exposure (let alone start measuring it) until you know what the use of the product is.

The Safety Data Sheet will also have guidance on use. In this case, it's probably a spray can (hence the liquefied petroleum gas carrying xylene, an organic solvent), so the SDS probably says something along the lines of "Use in a well ventilated place", then what to do if that's not practical.

With the right people on board, you might be able to hazard a guess as to potential levels of the toxic, asphyxiating and flammable content of the air when the product is used. 

You might be able to hazard a guess from e.g. knowledge built up by typical users doing typical tasks.

Roundtuit  
#3 Posted : 01 May 2020 18:40:05(UTC)
Rank: Super forum user
Roundtuit

Originally Posted by: Monopoly Go to Quoted Post
Should there be information with the product that says typicallly so many parts of the product will be in a millions parts of contaminated air over a certain period time when being used? 

FFS (and just for a change I do not mean Fat Finger Syndrome) an SDS is prepared for the material as it is supplied to market.

IT IS NOT a COSHH assessment which is what you are eluding towards.

The manufacturer/supplier has absolutley NO knowledge of your facility, NO knowledge of what you are doing with it and NO knowledge of any control measures you may or may not have in place e.g. LEV.

Given this lack of knowledge HOW do you propose they can advise as you have written?

BTW we are discussing your use, in your workplace, with your controls - what about every other user of the product in their unique workplace, with their distinct controls? Get the feeling we may have wildly different numbers in such circumstances (as Peter mentioned using indoors/outdoors/well ventilated area - that is three different numbers for your individual use alone).

It was the biggest mistake HM Gov ever made by revising CHiP in the same year that COSHH launched with so many (primarily construction) fools perceiving an (M)SDS to be their COSHH assessement.

An SDS provides some but not all information. There are other sources including dare I say occupational exposure testing to determine for example if your use in your workplace exceeds the current exposure limits. From all these sources you derive your workplace assessment.

Sorry your post lit the blue touch paper of so many disagreements with self righteous consultants adamant I must provide a COSHH sheet when they actually meant an SDS. Never got an apology when they could not provide a link to the regulation they thought they were quoting.

Roundtuit  
#4 Posted : 01 May 2020 18:40:05(UTC)
Rank: Super forum user
Roundtuit

Originally Posted by: Monopoly Go to Quoted Post
Should there be information with the product that says typicallly so many parts of the product will be in a millions parts of contaminated air over a certain period time when being used? 

FFS (and just for a change I do not mean Fat Finger Syndrome) an SDS is prepared for the material as it is supplied to market.

IT IS NOT a COSHH assessment which is what you are eluding towards.

The manufacturer/supplier has absolutley NO knowledge of your facility, NO knowledge of what you are doing with it and NO knowledge of any control measures you may or may not have in place e.g. LEV.

Given this lack of knowledge HOW do you propose they can advise as you have written?

BTW we are discussing your use, in your workplace, with your controls - what about every other user of the product in their unique workplace, with their distinct controls? Get the feeling we may have wildly different numbers in such circumstances (as Peter mentioned using indoors/outdoors/well ventilated area - that is three different numbers for your individual use alone).

It was the biggest mistake HM Gov ever made by revising CHiP in the same year that COSHH launched with so many (primarily construction) fools perceiving an (M)SDS to be their COSHH assessement.

An SDS provides some but not all information. There are other sources including dare I say occupational exposure testing to determine for example if your use in your workplace exceeds the current exposure limits. From all these sources you derive your workplace assessment.

Sorry your post lit the blue touch paper of so many disagreements with self righteous consultants adamant I must provide a COSHH sheet when they actually meant an SDS. Never got an apology when they could not provide a link to the regulation they thought they were quoting.

chris.packham  
#5 Posted : 01 May 2020 22:33:40(UTC)
Rank: Super forum user
chris.packham

Keep in mind that the safety data sheet only provides what is very limited data about the chemical product that you have acquired and only ‘as supplied’. It’s use for assessing a risk in a workplace is very limited. It is not a complete list of all constituents but only of those formally classified as hazardous, i.e. have been assigned a hazard statement. As COSHH 2(1) indicates, there are many chemicals not so classified that can become a hazard depending on how they are used or are present in the workplace. Safety data sheets are also often of questionable reliability. In one study the European Chemicals Agency found that 52% of the safety data sheets they examined were considered ‘deficient’.

I find also that many are not aware of the requirement placed on the supplier under the Health and Safety at Work etc. Act 1974 in section 6-4(c). The requirement placed on the supplier is quite different to that for the safety data sheet. The 6th edition of the ACoP for COSHH contains the following:

Paragraph 57 - The risk assessment should consider the work activity, including:

all the substances hazardous to health (including biological agents, and simple asphyxiants) arising from the work (used, produced, synthesised, created as waste or by-products, or released from processes or during accidents, incidents and emergencies);

A COSHH risk assessment based purely on the information in the safety data sheet runs the risk of being invalid.

A Kurdziel  
#6 Posted : 04 May 2020 08:48:15(UTC)
Rank: Super forum user
A Kurdziel

What Chris, Pete and Roundtuit have said is spot on but I’d go further. You need to do a proper risk assessment as required under COSHH so you look at the job you are doing ( a risk assessment  is always for a process not just a substance) and taking everything into account (above and beyond just the SDS)   decide  if the substances that you are using are appropriate. To often people are told to use a product ‘X’ because they have always used ‘X’.  Then they are expected to create a safe system of work around that substance rather than selecting the right product for your process.

So what are you using? How long for? How many air changes are there in the room you are working in? Is it practicable to increase these? Can the process be enclosed? Is skin exposure an issue( that will keep Chris happy!)?

Kate  
#7 Posted : 06 May 2020 05:37:09(UTC)
Rank: Super forum user
Kate

I'm going to try to give a factual, direct and non-judgemental reponse.  The OP signalled a wish to understand and I don't think deserves any criticism for that.

Sometimes there is an "extended Safety Data Sheet" which is much longer and includes "exposure scenarios" which are essentially generic risk assessments for the foreseen uses and usage conditions of a substance based on measurements in workplaces.  Where you can get this (you usually can't), it can be a starting point for your own specific risk assessment. 

The standard (16 section) SDS not only does not but should not contain this kind of information.  Its format is prescribed by law (REACH) and it is not intended to provide this information. 

The way that measurements are taken is typically by an operator wearing a pump and filter for a period of time so that the filter collects the contaminant from the air, followed by lab analysis of the filter.  You would engage the services of a qualified occupational hygienist to do this and invest a lot of time and money.  But this isn't usually considered necessary for a common use of a product where you would instead identify and follow industry good practice.

As others have said, the SDS is of limited use in risk assessment.

chris.packham  
#8 Posted : 06 May 2020 07:12:10(UTC)
Rank: Super forum user
chris.packham

Perhaps in the context of measurements for substances in the workplace the following is relevant:

“However, there is no scientific method of measuring the results of the body’s exposure to risk through dermal contact. Consequently no dermal exposure standards have been set.” - from “Occupational skin diseases and dermal exposure in the European Union (EU-25):policy and practice overview - European Agency for Safety and Health at Work

So demonstrating ‘compliance’ when considering risk assessment and exposure management for skin in the working environment is simply not an option since there is no standard (other than the vague requirement to ‘adequately control’, whatever that means for skin) to comply with.

Although skin exposure measurement is not a realistic option, skin condition measurement is and can be used to detect skin damage due to damage from irritant chemicals in contact with the skin whilst this is still asymptomatic.

Kate  
#9 Posted : 06 May 2020 07:40:48(UTC)
Rank: Super forum user
Kate

Chris, you say that skin exposure measurement is not a realistic option, but I have seen this done as part of preparation for REACH registration.

The method was to have an operator wear an inner glove under their protective glove for a specific time while doing specific tasks, and then collect the inner glove and carry out lab tests to measure the contaminant on it.

Do you see this as not valid?

chris.packham  
#10 Posted : 06 May 2020 08:12:15(UTC)
Rank: Super forum user
chris.packham

Kate,

In the context of a risk assessment for workplace skin exposure totally irrelevant. It is to complex an issue to explain on this forum but if you would like a detailed explanation PM me your e-mail address and I will send you a document explaining why.

CptBeaky  
#11 Posted : 07 May 2020 09:33:15(UTC)
Rank: Super forum user
CptBeaky

My favourite SDS of the moment. We have just got hold of a new batch of alcohol based hand sanitiser gel for when we reopen.

Skin Contact : Drench skin in running water for 10 minutes ....

This is why SDSs are all but useless. Surely the manufacturer can understand that skin contact with an alcohol gel is part and parcel of using the gel. If everytime someone used it they then had to run their hands under water for 10 minutes, then it would not be fit for purpose.

thanks 2 users thanked CptBeaky for this useful post.
Kate on 07/05/2020(UTC), A Kurdziel on 07/05/2020(UTC)
A Kurdziel  
#12 Posted : 07 May 2020 10:34:51(UTC)
Rank: Super forum user
A Kurdziel

SDS are not totally useless but you have to understand what they are about.

To a large extent, for suppliers they are a tickbox exercise, which is why alcohol is described as harmful to the skin, which of course it is, but then so is repeated exposure of the skin to water. They only describe hazards, not the risk, so it does not tell you what is the risk of using a substance for your processes, with your people, in your location?

Neither does it distinguish between someone who is storing a 100 tonnes of alcohol wipes and someone who is only using them a couple of times a day to sanitise their hands.

Finally the suppliers rely on information that is provided to them by third parties. If that is poor, out of date or just none existent, it is not surprising that the SDS is of limited use.

chris.packham  
#13 Posted : 07 May 2020 10:37:28(UTC)
Rank: Super forum user
chris.packham

How about the safety data sheet that I have for a non-solvent degreasant? The list of constituents starts with 'hydrocarbon solvent'!

My world is full of myths and misinformation. I have an article published in a reputable journal that contains the following statement:

“The onset of occupational skin diseases can, in many cases, be entirely prevented, or the extent of damage mitigated, simply by adopting the right skin care regime.”

Presumably it doesn't matter if  my worker puts their hand into the sulphuric acid tank since I have their magic products in my washroom.

chris.packham  
#14 Posted : 08 May 2020 07:32:03(UTC)
Rank: Super forum user
chris.packham

Kate - your example of a test is what is done to measure glove performance. It is a requirement under REACH that the safety data sheet specifies the type of glove suitable for the chemical (including, would you believe the manufacturer) and the length of time before permeation ( transfer of chemical through glove at a molecular level, invisible and undetectable by the wearer) occurs. What you describe is exactly how the test is done to determine this so that it can be shown on the safety data sheet. The measurement of the amount found on the inner glove is needed as part of the test.

As it happens this test is also meaningless when deciding which glove to wear and how long it will work for as in the first place the EN test is flawed as it measure performance at the wrong temperature and many other factors will affect the glove's performance when it is actually used. There is a technique available to measure gloves under actualy conditions of use. You would be surprised what one finds when this is done!

thanks 1 user thanked chris.packham for this useful post.
Kate on 09/05/2020(UTC)
Kate  
#15 Posted : 09 May 2020 09:16:05(UTC)
Rank: Super forum user
Kate

Thanks, Chris.  I don't though understand how what I described wasn't "under the conditions of use" as the operators were asked to go about their usual tasks when wearing the test gloves (this was in a chemical manufacturing plant).

It's rare that I see a glove recommendation on a SDS other than "impermeable gloves", which, of course, don't exist.

chris.packham  
#16 Posted : 09 May 2020 12:50:51(UTC)
Rank: Super forum user
chris.packham

Kate

With the additional information this is exactly what I mentioned when I wrote of  'in-use testing'. However, as a measure of skin exposure it does not really provide any useful information. To explain why I state this would require a far more lengthy explanation that I could give on the forum. As I wrote earlier, if you would like more on this just PM me an e-mail address and I will send you a more detailed explanation about skin exposure measurement that I am sure will satisfy you. 

Chris

chris.packham  
#17 Posted : 09 May 2020 21:29:55(UTC)
Rank: Super forum user
chris.packham

As an addendum to my post of this afternoon perhaps I should add that the invitation to request a copy of the document mentioned applies to anyone on this list.

Monopoly  
#18 Posted : 11 May 2020 11:21:48(UTC)
Rank: Forum user
Monopoly

Thank you all for the responses. 

I am fairly new to health and safety and lack practical on the job experience.I  have passed the NEBOSH cert. and currently studying for the diploma, but have sometimes struggled to get a "how to apply this in the real world" answer from the course. 

I am aware that an SDS is not a COSHH risk assessment but was just trying to get my head around introducing control measures where WELS and STELS are included in the saftey information  

benek84  
#19 Posted : 13 May 2020 20:36:49(UTC)
Rank: Forum user
benek84

Thank you for all comments, very useful. My question or asking for opinion.. Do you prefer separate coshh assessment for each substance on designated form or do you include coshh in workplace risk assessments?
chris.packham  
#20 Posted : 13 May 2020 20:46:45(UTC)
Rank: Super forum user
chris.packham

With a very small list of exceptions a COSHH risk assessment has to be specific to the task. To start with, the chemical hazard will depent on the way in which the chemical(s) is/are used and the changes that may occur that can affect the real hazard as used. Note what the current ACoP for 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.” - COSHH ACoP (6th edition), para. 10

You may need to combine more than one of the three routes of exposure (inhalation, ingestion, skin) in order to properly assess the total risk of damage to health.

If you need more PM me with an e-mail address and I will send you more on this.

thanks 1 user thanked chris.packham for this useful post.
A Kurdziel on 14/05/2020(UTC)
Kate  
#21 Posted : 14 May 2020 05:12:56(UTC)
Rank: Super forum user
Kate

It's got to be a separate COSHH assessment for each use of substances (note the plural).

If you mix two substances together, then you need a single assessment to account for the hazards of the mixture.

If you have two very similar substances which are used as alternatives to each other, a single assessment may be able to cover both.

A Kurdziel  
#22 Posted : 14 May 2020 08:55:45(UTC)
Rank: Super forum user
A Kurdziel

The COSHH risk assessment  has to be task based. This might mean if you use a substance differently in two separate tasks then you need two assessments. As you are likely to be using more than one substance in a task they should all be part of the assessment. But there might also be circumstances when you are using a class of similar compounds/substances and the effective controls are the all same so one assessment might be sufficient. 

chris.packham  
#23 Posted : 14 May 2020 09:54:50(UTC)
Rank: Super forum user
chris.packham

You need to identify the real chemical hazard that is present when the task is carried out. 

We purchase chemicals to use for a purpose. In using them it is common that we change them (contamination, mixing, reacting, oxidising, heating, etc.) and thereby change their properties and hazard. This is reflected in para 10 of the ACoP for COSHH. 

COSHH also includes those chemicals that have not been assigned a hazard statement (regulation 2(1)(e)) and thus do not need to be shown on the safety data sheet. These may be, or become, a hazard to health. After all, water (in the form of wet work or occlusion from gloves) is the most common form of occupational contact dermatitis. The most comprehensive and widely recognised list of skin sensitisers (Patch Testing, Anton de Groot Publishing) lists 4900 chemicals only a minority of which will have been classified as H317. Unlikely that the others will appear as sensitisers on the safety data sheet.

As I have learned from experience, identifying the real hazard for which I need a risk assessment can sometimes by quite difficult.

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