Posted By Chris Packham Tom If you consult the ACoP for COSHH you will find that the definition for a substance hazardous to health contains sub-paragraph (e) which, effectively, means that any substance can be a substance hazardous to health under certain conditions. Thus even water can fall into this category. This is correct, since according to statistics from those countries that do have proper data wet work is the most common cause of occupational contact dermatitis. Yet if you then consult para 35 of the ACoP it suggests that you can do a risk assessment based on risk phrases! Since when did water have a risk phrase? There are literally thousands of chemicals without a risk phrase that can cause occupational skin disease. COSHH Essentials also relies upon risk phrases. I can show you a risk assessment for a workplace with 200 employees where, since there were no chemicals with risk phrases, COSHH Essentials does not record a risk. In practice 10% of the workforce had contact dermatitis! I always worry about the simplistic approach to risk assessment, particularly in my own special area of interest (skin). It is so easy to get it wrong! As far as who is liable, I know of no case law that covers this, but who knows... Chris