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Posted By EC
Hello all,
This is really aimed at NHS staff ( i know there are a few on here). We have recently had a new cleaning product put in place as part of the NHS Scotland National procurement. Our organisation is rolling out the product and I happened to look at the MSDS for the chemical.
The control measures state that the individual using the product should wear full plastic overalls taped with PVC wellingtons and have an emergency shower close by. Now obviously this is not feasible in a hospital and when contacting the company they quickly sent out amended MSDS that reflect single use rather than the bulk manufacture of the product.
It also states that the material should not be mixed with combustible material as it may cause fire. This is causing problems as the protocols for blood spillages mean that the spill should be contaied in with paper towels allowed to soak up and then granules sprinkled on top to allow it to soak up. The whole lot is then cleared up into a clinical waste bag.
Has anyone in the NHS addressed these issues. I have contacted the company in question for a further MSDS for the granules, but again they sent out a MSDS that did not reflect the task.
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Posted By Ron Hunter
MSDS are not intended or required to reflect any particular task - that is for a COSHH Assessment to consider.
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Posted By EC
That is correct, you take into account usage. However these are the manufacturers recommendations when using this product and i think it would be hard to mitigate opting for a lesser level of protection or disposal methods. when the company has supplied it for a particular product.
I look to the MSDS to provide me with the information to base the assessment on, Im not skilled to say at what quantity would cause a fire risk, nor when does the need for an emergency shower become obsolete. Do you say after one tablet or two or three? If the company supplies a MSDS to a hospital for a product where the process requires 1 tablet in a litre of water and that is the PPE requirement, would you not question it also.
I can just imagine nurses walking around the ward using this general purpose disinfectant wearing a Plastic overall, wellies with a decon shower at hand.
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Posted By Jay Joshi
MSDS's are written to cover the entire range of use, from a few millilitres/grams to hundreds of litres /tonnes.
It is by the COSHH assessment where you determine the control measures based on the routes of exposure, the quanitities involved etc.
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Posted By SteveS
Surely the manufactures of this product are selling/marketing this substance for a specific purpose. Is it not the manufactures responsibility to supply clear instructions for its intended purpose i.e. 'normal use' from which a COSHH assessment can be made?
Or am I being too naive?
Steve
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Posted By EC
This is where i agree with Steve.Manufactures have a responsibility to provide you with accurate data on the products intended use, or all MSDS would list that you should wear full breathing apparatus when using the product and then say its up to you to decide the level you wish to implement.
If the manufacture puts on the MSDS that you need a FFP3 mask your clearly not going to say, that I think ill just provide a FFP1.
The Chip regulations clearly state that the manufacture shall provide MSDS that have proportionate information relating to that preparation, and the user shall provide safety information relating to that product. In my mind that means relating to the packaged product you are buying, not the hazards associated when making the product in bulk.
This seems to happen a lot in the NHS that MSDS are sent out with such unworkable information that the companies seem to be just trying to protect themselves. Examples are Pumice stone, the MSDS says do not allow in contact with skin.
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Posted By Fiona Cowan
What product is it, we might be using it?
Regards
Fiona
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Posted By EC
I wasnt going to post the Company name as i was not use that it would be allowed.
The product is called Actichlor (in tablets and granules) and us now the national procurement selected product for dealing with blood spillages.
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Posted By Ron Hunter
Too add further to the discussion, many suppliers/manufacturer do produce "spurious" MSDS. In some cases the information provided is just wrong. In many instances, the product is non-hazardous!
Have you identified any hazardous constituents?
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Posted By Chris Packham
There seems to be a misunderstanding about MSDS here. MSDS are written to comply with CHIP not COSHH, i.e. for supply as opposed to use. In fact, para 13 of the ACoP for COSHH specifically cautions against relying upon the Approved Supply List as the source for hazard information and this is what most MSDS will be based on.
Suppliers have a duty beyond the MSDS to provide information that will allow the product to be used safely for the purpose for which it was supplied. This is enshrined in section 6-1 of the Health and Safety at Work etc. Act 1974. (Note 1974 - this isn't something new!)Unless your supplier is providing this information he is not compliant with the Act.
In order to comply he will probably need to be made aware of this and to be provided with appropriate information about how you are using his product. Hopefully he will then be able to comply.
Another caution about MSDS. Do not rely upon risk phrases for a COSHH risk assessment. The most common causative chemical for occupational skin disease is water (wet work). I have yet to see a risk phrase for water! Disregard the advice in the COSHH ACoP that you can base your risk assessment on risk phrases. Not for skin!!!
Chris
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Posted By Mike Grey
Having worked in the NHS i too have experience of this product and some of the hazards its use poses.
It was used as a cleaning solution when carrying deep cleans in order to control the spread of infection.
As with most NHS Trusts it was introduced before a COSHH assessment was carried out and the health and safety team were left to sort the problems out after ill health among staff caused concerns. The product was supplied in tablet form.
Once the COSHH assessment process was initiated i found the suppliers very helpful. They provided staff training around the dilution and use process. They provided exposure monitoring against the WEL and provided support through attendance at staff meeting and posters for further information.
Once the controls were identified the product proved very effective and staff fears were reduced.
What i would say to any procurement department within the NHS is to assess the product before use by looking at the MSDS, carrying out a COSHH assessment with input from users and suppliers. Suppliers are keen to get onto the NHS preffered suppliers list, the financial benefits are huge, and they will provide lots of support.
Comments ref the contents of an MSDS
are correct in that under legislation they need only provide the information within the 16 section that would guide you to assess the risks within your own operations. They are not required to do the assessment for you but as i have said this supplier may go a little further if approached.
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