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#1 Posted : 08 October 2003 11:35:00(UTC)
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Posted By Mick Mann What guidance is available for a company blending small volumes of hazardous substances with non-hazardous substances? At what point do they no longer need to identify the product as hazardous?
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#2 Posted : 08 October 2003 12:04:00(UTC)
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Posted By Paul Leadbetter Mick You need to check the CHIP Regs and the Approved Supply List for thresholds. Paul
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#3 Posted : 08 October 2003 13:12:00(UTC)
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Posted By Stephen Ashton Oooops - somebody has stepped into the minefield.... Mick, a simple (and simplistic) answer your question is to check out the 'idiot's guide to CHIP' - accessible through the HSE website. And, yes, I know we are supposed to be helping each other on this forum, but... A rather more brutal answer would be - if you don't already know the answer you shouldn't be doing it, if you can't find the answer, you shouldn't start doing it, and if you can't understand the answer when you get it, then you shouldn't even think about doing it.... A more helpful response may be.... 'it depends' .... do you want to mix and use on site? what are the hazards of the individual components? what are the physical states of the components, the physical properties of the mixture, the harmful properties of the mixture, the environmental impacts of the mix - Do you want to supply in the UK or EU or internationally - will the mixture be carried by road, rail, inland waterway, sea or air? Is the mix already on the 'approved list', is the mix or any of it's components banned or restricted for supply? How much will be made / stored / supplied..... Having answered all the above - consider relevant legal standards and requirements CHIP, COSHH, DGSO, ADR, CDGR, IMDG, IATA, COMAH, EIDC, EINECS plus all the council directives (esp 99/45/EC as amended by 2001/60/EC etc....) And then consider whether the mix (or components present in sufficient quantities) are to be used as pesticides... or food additives... or pet foods / animal feedstuffs, or explosives.... and consider all the relevant etc etc and then.... and voila - you will have the 'right answer'. Alternatively, employ a competent person (or consultant (yes, I know we have a poor rep at present on this forum but still...)) to get the 'right answer' for you. And then (possibly) get somebody else to explain what the right answer means in practice for your particular circumstances. Sorry, its been a bad week. Steve
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#4 Posted : 08 October 2003 13:34:00(UTC)
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Posted By John Donaldson Unless you have someone in your company with a chemical background and a good knowledge of the legislation, this is really one for the experts. Having been involved with a paint manufacturing plant in the past I do know the calculations can be complex. As Steve says there are so many different issues, legislation and guidance to be taken into account. Very easy to get it wrong.
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#5 Posted : 08 October 2003 15:22:00(UTC)
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Posted By Mick Mann Many thanks to Paul and John for their constructive responses. Stephen - who needs it?
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