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Posted By JWG
May seem a silly question, but please can someone advise.
Does a shop have to have a COSHH register for the domestic cleaning products that it sell? (I know they must have one for that they use)
I would say not because staff are not exposed (unless there is a spillage, but then the spill procedure should take into consideration an array of foreseeable substances).
Thanks in anticipation...
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Posted By Stephan
They will need to be in your fire risk assessment so you potentially need them on the COSHH register perhaps in a generic form if they are low risk items but specifically if they are high risk. If high risk perhaps you should source alternatives
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Posted By GeoffB4
Stephan
I don't really understand the relevance of your remark relating to fire and COSHH?
This is a retail environment where people make a living selling what others want to buy - so again your reference to alternatives seems to me not to be valid
My answer to the original question is a generalised no if we are talking about generally available domestic products sold in supermarkets corners shops and the like.
Geoff
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Posted By Ron Hunter
Given this is a shop I would hope there aren't any "high risk" items on your shelves. Neither are domestic cleaning products a particular fire risk (although aerosols are).
I haven't come across the term "COSHH Register" and I suppose this might translate to an Inventory of Hazardous Products.
The real question though, is what purpose would it have?
You seem to have spillage covered however this is an aspect of COSHH for you to apply over and above the products you actually 'use'. Reference to a Register or inventory would ensure that a correct spillage procedure was applied to each hazardous product?
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Posted By Pete Longworth
I think I agree with Geoff here. These are off the shelf items that can be bought anywhere. They aren't primarily intended for use in a work environment, they are domestic products.
If they were being used by employees for cleaning purposes as part of their duties then maybe they should be included in a COSHH register, but as items on general sale, then I would say no they shouldn't.
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Posted By Stephan
Geoff
Maybe
I have over reacted but there is always a risk, perhaps a yob might spray some chemical in your eye --- who knows. The products may also be flammable
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Posted By Chris Packham
"An employer shall not carry out any work which is liable to expose any employee to any substance hazardous to health unless he has:-
(a) made a suitable and sufficient assessment of the risk . . ."
COSHH Regulation 6(1)
What would be the situation were an employee to handle a container of a chemical, say bleach or oven cleaner, that was leaking and got the chemical on their hands?
So in my opinion a simple risk assessment and the subsequent measures, probably regarding hand rinsing in such an emergency, first aid, etc. (as the risk will almost certainly be very low) would be advisable, if only so that in the event of an incident or during a visit by the local authority inspector you could demonstrate that you had complied with COSHH.
Chris
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Posted By GeoffB4
Chris - they would wash their hands, just like anybody else would!
I don't understand your comment. Unless you are saying every shopkeeper from Land End to .... etc has to carry out COSHH assessments on every substance they sell?
A bit outside the spirit of the regs, don't you think?
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Posted By Chris Packham
Geoff
I had to help a client where someone lifting a box of cleaning chemical (bleach) down from a shelf had spilt some, not just on their hands but on face (including eyes) and saturated their clothing, i.e. whole body exposure. The result was what could only be described as fairly extensive chemical burn on sensitive parts of their body!
Fortunately with goodwill on all sides and prompt and appropriate treatment we were able resolve the situation without too much difficulty, but it does raise the question: "What if the employee had decided to be difficult and possibly even to report the incident to the HSE?"
Yes, I probably am going further than most, but this is based on my experience in my particular field. Unfortunately I usually only get called in by employers when they have a skin problem, not before. It is frequently the case that the chemical in question was not one that they thought "hazardous" and an operation where they did not appreciate the potential for exposure. Chemicals that are clearly hazardous tend to be regarded with caution, it is the others that so often cause the problem.
Chris
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Posted By GeoffB4
I don't know the definitive answer to that Chris, but I suspect no enforcement action would be taken by anybody. I'm happy to be corrected if you can point me to some precedent.
The action to take in the case you mention would be immediate washing with water - but if we are going to now look for the MSDS and the assessment before taking action then we have lost the plot.
I fully accept persons actually working with hazardous substances require consideration. But to take it to the extent of every shop in the UK being required to provide COSHH assessments on products they sell, and for staff to wear goggles and gloves as they put them on the shelves (just in case) is a little OTT - don't you think?
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Posted By Chris Packham
Geoff
I am not suggesting that in a shop they need to risk assess every chemical. What I am suggesting is that it would be prudent for the shopkeeper to consider a generic assessment, i.e. what chemicals are we handling, what might these do if in contact due to spillage, etc., how can I ensure that working practice reduces any such risk and what would I do in an emergency.
If you think that this is OTT, you should have seen the skin reaction of the poor worker whose case I cited. That employer now does take this seriously and has the appropriate generic risk assessment and suitable measures in place.
The retail/service sector is actually one of the worst areas for occupational skin disease. Hairdressers and beauticians (and increasingly aromatherapy specialists) are the by far the worst occupations of all for occupational skin disease, closely followed by bakers and pastrycooks! Hairdressing is actually such a problem occupation that it is one of HSE's primary areas of concern at the moment.
Chris
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Posted By GeoffB4
Chris, you said:
So in my opinion a simple risk assessment and the subsequent measures, probably regarding hand rinsing in such an emergency, first aid, etc. (as the risk will almost certainly be very low) would be advisable, if only so that in the event of an incident or during a visit by the local authority inspector you could demonstrate that you had complied with COSHH.
Is this not the same as saying every shop has to do a COSHH assessment on all the substances they sell? And if higher risk substances are being sold eg bleach, that proper control measures such as goggles and gloves need to be worn?
Your reference to dermatitis is for people using susbtances at work - not the general handling of substances which is the topic of this discussion.
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Posted By Chris Packham
If you refer to COSHH Regulation 2(1) it does not limit itself to chemicals actually used in a particular task. COSHH merely uses the word "expose".
In my view (and I checked this out with a lawyer specialising in health and safety matters) this would apply to someone handling a box of bleach and dropping this so that they were exposed.
So in effect what I am saying is that technically and applying COSHH strictly, a shopkeeper with potentially hazardous chemicals would need to consider the risk of exposure and how this could be prevented.
Chris
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Posted By Paul Leadbetter
Every COSHH assessment should consider normal operations, maintenance and emergencies.
For a shop, normal sales operations are very low risk as substances are all in sealed containers, and maintenance doesn't really apply to substances on sale. However, any container can be dropped, resulting in splashing and, depending on the substance, inhalation. These risks must be considered and appropriate control measures (spill kits, gloves, etc.) made available.
Paul
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Posted By GeoffB4
Thanks Crim, it's clear the HSE concern is the use of substances in this particular example of a Convenience Store.
No doubt this will rumble on but I would ask contributors to look at the spirit of the regulations. Just like a conversation with George Galloway, there seems to be a problem with separating intent from reality.
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