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#1 Posted : 12 March 2008 11:38:00(UTC)
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Posted By Ronan Can someone please verify for me whether a product needs to be included in a coshh assessment if it says on the MSDS sheet it is not dangerous according to Directive 1999/45/EC??? Perhaps a silly question but i thought i would seek clarification.
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#2 Posted : 12 March 2008 11:42:00(UTC)
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Posted By The toecap I stand to be corrected but surely the coshh assessment is there to prove that the measures you have in place demonstrate you have been duley diligent in proving it doesn't constitue a danger
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#3 Posted : 12 March 2008 11:51:00(UTC)
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Posted By Paul Leadbetter Ronan That directive is concerned with classification, packaging and labelling of substances and preparations, I think. A substance classed as non-hazardous under the legislation arising from this directive may contain substances assigned WELs (in the UK) and which could give rise to a risk to the health and safety of those exposed. Therefore, even those materials classed as non-hazardous may still require a COSHH assessment, depending on the constituents and the circumstances of use. Paul
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#4 Posted : 12 March 2008 12:03:00(UTC)
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Posted By Chris Packham How do you define a substance hazardous to health? COSHH states that it can be any substance depending upon its toxicological and chemical properties and the way it is present or used at the workplace. (See regulation 2(e)) Thus irrespective of what appears on the safety data sheet you need to include ALL chemicals in your COSHH assessment. Of course, many you can rule out immediately, either due to their limited toxicity or limited exposure, but you cannot ignore them. After all, wet work, i.e. exposure to water, is the most common cause of occupational contact dermatitis. Remember also that WELs only refer to inhalation exposure. It is perfectly possible to be below the WEL and to elicit a contact dermatitis reaction due to airborne exposure, e.g. to the face. When it comes to skin exposure you need to look beyond the MSDS to what you are actually using in the workplace and the hazards that this represents. These can be very different from those on the safety data sheet for the individual products you have brought into the workplace. Relying upon risk phrases can result in risk assessments that are simply wrong and in working practices that (a) would be putting your workforce at risk and (b) represent non-compliance with COSHH. Chris
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#5 Posted : 12 March 2008 12:10:00(UTC)
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Posted By Ronan Thanks folks!
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#6 Posted : 12 March 2008 13:17:00(UTC)
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Posted By MP Just out of interest, what is the preparation? MP
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#7 Posted : 12 March 2008 16:04:00(UTC)
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Posted By GeoffB4 We provide salt cellars in our staff canteen and I've insisted an encapsulated A4 COSHH assessment is taped to it. It states that high levels of salt can raise blood pressure, and the medical details of how it is caused. However, the encapsulated A4 seems to also raise the blood pressure - so we are bringing in a consultant to advise us on the next step. It's been mentioned we should think of closing the canteen - as in accordance with the COSHH regs the first step should be to try to eliminate the risk. We've done the same next to each water tap, to make sure people limit the times they wash their hands (danger of dermatitis). Of course this doesn't affect the people who don't wash their hands.
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#8 Posted : 12 March 2008 16:17:00(UTC)
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Posted By Chris Packham Geoff I didn't think it was Friday! Chris
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#9 Posted : 12 March 2008 16:53:00(UTC)
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Posted By GeoffB4 You're right Chris, but sometimes when I sign into this forum I get the feeling it is some form of twilight zone, a middle earth feeling, where reality is pushed into the background.
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#10 Posted : 12 March 2008 17:03:00(UTC)
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Posted By Chris Packham Geoff I can understand your feeling. My problem is that as someone who has concentrated on skin problems in the workplace now for nearlly 30 years, I still see situations where people have simply not recognised some of the basic facts that I keep expounding on this forum. (It can be incredibly frustrating when people just don't want to face up to reality because it doesn't fit their pre-conceived ideas.) Take the case of a food processing plant with 200 workers and 20 cases of dermatitis, many of which were sufficiently serious that they were off work (10 % of workforce!). HSE jumping all over the employer. No chemicals with risk phrases in that workplace. Causes of dermatitis were an extremely cold working environment (3-5 deg C), very low humidity, hands either wet or in occlusive gloves for most of the working day and frequent hand washing. Client had simply assumed as no risk phrases, then no problem! Incidentally, I ran the scenario through COSHH essentials. You get zero risk! This is just one example. I could give you many more. Chris
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#11 Posted : 13 March 2008 09:04:00(UTC)
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Posted By Chris G I think I'd get a low risk on a COSHH assessment for that scenario too. However since it is work environment (heat & humidity) rather than a substance causing the problem I would expect it to be recognised and controls put in place through the convential risk assessment rather than COSHH. Chris G.
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#12 Posted : 13 March 2008 09:59:00(UTC)
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Posted By Chris Packham Chris The problem is that you cannot separate environmental and chemical effects when considering skin. For example, increases in temperature, and especially humidity, will increase the rate at which chemicals penetrate the skin, and hence the potential for systemic effects. Low temperature and humidity will reduce skin barrier properties, making the skin more susceptible to irritant contact dermatitis. When considering risks from workplace exposure of the skin we need always to take a holistic approach. Even psychosomatic elements must be included, particularly when investigating a suspected case of occupational skin disease. Chris
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