Posted By Bluemoon Why do risk phrases in sections 15 & 16 on MSDS's often differ? I am using this info to carry out coshh assessments, so which do I use - those in section 15 or those in section 16? Thanks

Posted By Chris Packham I know I keep on about this, but use caution when carrying out risk assessments for COSHH based on the safety data sheet. This will normally only list those substances that have risk phrases. This is not the same as those substances that can cause damage to health if contact occurs in the workplace. There are many substances that can do this that will not have a risk phrase. For example, at the recent conference of the European Society of Contact Dermatitis in Berlin several presentations showed how wet work is one of the most common causes of occupational contact dermatitis. When did water have a risk phrase? When did you last see water listed on a safety data sheets. SDS are written to comply with CHIP, i.e. hazard information and packaging for supply. What is needed for a risk assessment is hazard information relating to use. This can be very different from information on the SDS. This requirement is covered by section 6-1 of the Health and Safety at Work etc. Act 1974 which requires the supplier to provide adequate information "...about any conditions necessary to ensure that, when put to that use, it will be safe and without risks to health." My experience is that many suppliers are either unaware of this duty or choose to ignore it. I frequently have to point this requirement out to suppliers and persuade them to provide the additional information. If anyone wants more on this there is an item on our website (www.enviroderm.co.uk) on "When is a safety data sheet not a safety data sheet" that you can download for free. Chris

Posted By Ajay A Ambhorkar As per ANSI MSDS format Section 15. Regulatory information May be used to proved any additional information on regulations affecting the material. Section 16. Other information May be used to provide any additional information. [Comment: If you must include useless denials of responsibility, keep them confined to this section] Ajay A Ambhorkar CSP, GradIOSH, MIFireE

Posted By Ajay A Ambhorkar Regulatory Information This section provides the regulatory information for employers and regulatory compliance personnel. These regulations include: OSHA, TSCS, SARA, CERCLA, and CWA. Reportable quantities for spills, storage, and shipping can be listed also. Finally, international regulations and state and local regulations should be found in this section. Other Information This section is intended to be use for any addition important information not listed in other sections. This can include: references, keys/legends, creation and revision dates, and hazardous ratings such as the NFPA codes.

Posted By Chris Packham As I demonstrate in our courses, it is possible to do a risk assessment for skin exposure using COSHH Essentials and to end up with no risk (since no risk phrases) whereas a risk assessment using an approach tailored to skin exposure would indicate a significant risk. In fact the ACoP for COSHH actually contradicts itself. Item (e) in Regulation 2(1) states: "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." This obviously can include any substance, even water. Unfortunately, the ACoP then suggests that you can ignore this definition, since the method proposed for risk assessment is based purely on risk phrases. My particular interest (and hopefully expertise) lies in the prevention of damage to health from workplace skin exposure. Since most occupational skin disease will be irritant contact dermatitis and this is almost never to a single substance but chronic, cumulative exposure to many different chemicals ( a lot of which will not have a risk phrase allocated) I do not believe that you can use COSHH Essentials for skin exposure risk assessment. If you want more on this feel free to contact me direct. Chris

Posted By Bluemoon Descarte Thank you, you have answered my original question. I will now be able to complete my assessments the knowledge that I am using the correct r phrases. As for me using COSHH essentials, I suppose I will use it for each assessment, and then do additional assessments for those risks which are not covered. It does raise a issue though. Say you use the coshh essentials website for all coshh assessments (which it is designed to do). You cover all processes, implement control measures and train the workforce accordingly. An inpsector then turns up and issues a notice due to coshh assessments not highlighting risks to skin from prolongued wet work. As Chris has stated 'it is possible to do a risk assessment for skin exposure using COSHH Essentials and to end up with no risk (since no risk phrases) whereas a risk assessment using an approach tailored to skin exposure would indicate a significant risk.' Just a thought. Regards

Posted By Philippa Nobbs Section 15 lists the R and S phrases that apply to the product as a whole. Section 16 merely lists the R phrases whose numbers might appear in Section 2 for the individual ingredients. There is a fairly complex methodology for determining the classification for health and the environment for mixtures but for COSHH Essentials you should use the R phrases that appear in Section 15. Incidentally, R and S phrases aren't universal. They are part of a European Directive as is the content and layout of a Safety Data Sheet.