Posted By jmc Hi Chris All I do for My company is call the manufacturer and they have all the coshh sheets on there data base`s then when main contractors ask for it I already have it Easy peasy, pick up the phone or go to there web site`s some manufacturing company`s have coshh sheets for You to download Hope this helps JMC

Posted By Chris Packham I agree with Dave. It is a common mistake to think that you can do a COSHH assessment based on safety data sheets. These are written for CHIP and only tell you what you have purchased, not what you are using. I have seen numerous COSHH assessments where reliance upon the safety data sheet has either meant that a significant hazard has not been identified or that, based on what is in the safety data sheet, excessive and expensive measures to control an apparent risk have been taken that were completely unnecessary. The safety data sheet will list all constituents with risk phrases. It will not tell you whether any of these are bioavailable, i.e. represent a hazard. For example, stainless steel contains both nickel and chrome. Nickel is our most common skin sensitiser and chrome is well known for chrome ulcers and allergic contact dermatitis. Yet stainless steel is unlikely to cause these problems, simply because none of the nickel or chrome will be released, i.e. is not bioavailable. (There is a simple check for this.) Nor does the safety data sheet cover all hazards. If you wish to check on this take a look at item (e) in the definitions of a substance hazardous to health in the COSHH Regulations. Under certain circumstances even water (which doesn't have a risk phrase as far as I am aware) can become a substance hazardous to health. The reality is that most suppliers simply do not meet their legal obligations under section 6-1 of the Health and Safety at Work etc. Act 1974, i.e. to provide sufficient information that their product can be used safely for the purpose for which it was supplied. Frequently I have to remind them of this, which sometimes produces interesting responses! Assessing the risk of damage to health arising from the use of chemicals can be much more complex than many realise. Simplistic approaches can lead to significant risk - and damage. Chris

Posted By Chris Packham Just to add to this: In a plant using pre-impregnated carbon fibre mat, the safety data sheet showed the impregnant to consist largely of a potent skin sensitiser. The workers had been manipulating the material using thin gloves woven from a synthetic yarn and providing no chemical protection at all. This was causing considerable concern and consideration was being given to quite expensive methods to control the potential exposure. These could also have affected the output of the workers, a further cost element. Laboratory testing showed that the sensitiser was not contaminating the gloves, i.e. was not bioavailable, so no change to the working practice was required. However, in a different operation, where the mat was treated with a solvent, this did cause release of the sensitiser, requirint appropriate control measures. Incidentally, this was also news to the supplier, who had not considered any of this. Chris

Posted By Chris Duffy Thanks Folks. Good information and response yet again from the forum.. With regards to the point there seems to be no real answer to the question and no real solution to actually keep small to medium businesses compliant within a sensible budget. Why do they make up these Regulations that no one can afford to comply with and shall never obey. Why dont we make up Regs and Acts that people can actually comply with rather than Advisors and Consultants talking to Directors and Managers on a day to day basis informimg them of Regs/ ACOP's etc with no hope of them ever playing the game....i.e.. Site Waste Management Regs... Has any Consultant ever kept a straight face when you tell them about that one...

Posted By Chris Packham I just wish you were right! Unfortunately, most of my clients call me in not when then don't have a problem (and wish to avoid one) but when they do and are hoping that in some way I can turn the clock back. As someone who has specialised for the past 30 years in the prevention of damage to health from workplace skin exposure it is commonplace for me to be called in only to find that what the company has done to deal with the problem has actually contributed to the dermatitis. Examples are:- 1. A CMIOSH recommending that a barrier cream can be used a protection against hydofluoric acid. 2. A chemical company of considerable size where every glove had to be rejected as unsuitable for the purpose. 3. An improvement notice issued by a HSE inpsector recommending the wrong glove. I could go on, and on, and on. Yes, in some cases the risk assessment can be simple, but there are many pitfalls for those who do not appreciate how complex this can be. I seem to remember a saying about: "Fools rush in..." and "A little knowledege if a dangerous think". Perhaps this is why at the recent conference of the European Society of Contact Dermatitis statistics from Germany and Denmark showed that 60% of all cases of ill health were skin related. In the U.K. we have no real statistics, but the study commissioned by the HSES on dermatitis among printers showed just how great the underreporting is. Chris

Posted By Chris Packham I work in other countries as well. In the U.K. our legislation is reasonably practicable, in that it sets basic concepts and leaves it to us how to interpret it to fit the actual conditions in the workplace. In other countries, e.g. Germany, it is actually much more prescriptive. Not that this necessarily achieves better standards. In my experience, having worked in many countries, not just in Europe, but in the USA, Australia, South Africa, Australia, Malaysia, etc. the standards we achieve in practice are as good as any and better than many. This does not mean, of course, that they are not capable of improvement. We can do better and it doesn't have to add to operating costs. Chris

Posted By John A Wright Chris D, I think you're being overly pessimistic, though I have to admit encountering just as many problem SME's as reasonably good ones, it was just your suggestion that 'everyone' ignores regs that got to me. I wrote on another thread about one company who stubbornly refused to remove an outside padlock from their only other fire exit. They still haven't, so I refuse to visit them again till they do. And that is a reg easy to comply with. Chris P, I can imagine what you have seen over 30 years, and my experience is small in comparison. Until recently I also dealt only with the big auto companies and their parts and paint suppliers so I was generally with companies who understood solvents and gloves. John W

Posted By Chris Packham JMM Caution with COSHH essentials. It relies upon risk phrases. Many chemicals that can cause occupational skin disease do not have risk phrases. I can demonstrate that it is quite easy to obtain a risk assessment for skin exposure using COSHH essentials that misses the real risks and could land the employer in trouble. Chris

Posted By JMM Chris Would'nt disagree with you but we should not dismiss it. It is better than nothing at all and some of the suggestions made in this thread are worrying to say the least regards

Posted By Chris Packham A chemical is a hazard. It isn't until it is used that a risk occurs. Thus any risk assessment for COSHH must be task based. If you start with the task, then ask "What chemicals are present during that task?" I find that I need to work backwards, starting with what is present during the task, then attempting to identify the hazards that the chemical - as used - really represents. The safety data sheet is then only one part of the total information I need. What has happened as a result of my use? Could this have increased, decreased or changed the hazard? Since there are so many different tasks, even in a relatively small workplace and since, in my experience, even nominally identical tasks may result in variations in the chemicals actually present and the extent and nature of exposure, certainly when considering skin exposure I find that observation will show significantly different risks. Thus I have reservations about any "system" or "database" that will give me the answers I need. Just as a simple example, a degreasant may not cause any problem in the summer (relatively insignificant risk) but, since the skin in the winter produces up to 30% less of the natural oils (sebum) that it needs to provide an effective barrier, the risk of skin damage becomes greater in the winter (relatively significant risk). Perhaps the following illustrates the point:- "All of the severe cases occurred between November and April and 79% of the milder cases occurred during the winter months." Study by University Hospitals Case Medical Center, Cleveland, USA - presented at 66th meeting of American Academy of Dermatology. Chris

Posted By Chris Packham TomP The point I have been trying to make throughout this thread is that risk phrases are not enough for a risk assessment. This is actually covered in para. 13 of the ACoP for COSHH. Thus, even if a constituent is not listed in the safety data sheet, it may still represent a potential hazard, particularly in my field of skin exposure. You mentioned soap. A major problem in healthcare at the moment is skin problems (irritant contact dermatitis) due to excessive washing as a result of the concern about C. difficile. The soaps used are all listed as "mild" and do not include any constituents with risk phrases. So yes, even soap needs to be risk assessed, although in most circumstances there will be no significant risk. Incidentally, EH40 is only relevant for inhalation exposure, not even airborne. It is possible to have airborne exposure below the WEL and still cause an allergic skin reaction. There are no exposure limits for skin exposure, simply because it is technically impossible to produce them. Yes, this presents a problem, even for me. When is skin exposure sufficiently minimal that there is no significant risk of damage to health? Unfortunately, whilst I would love to see a simple approach, my experience has been that in all too many cases, the simple approach results in my becoming involved in dealing with the subsequent problem. I only wish it were not. Chris

Posted By Peter Farrell Like everything it's as complicated as it needs to be. I agree that you cannot go soley on what the Data sheet says. An example is that they have the WEL on and people then over complicate so that the person using the chemical then either does not read or does not understand the assessment. Look at the task, how long are you using it for, were is it being used etc. The data sheet will give you the type of PPE to be worn, but you still need to be sensible. An example is that we use loctite to prevent nuts from being taken of the bolts. 2 second job, once a week. We therefore do not look and say a mask must be worn, eye protection and a certain type of glove. we work with the task and ensure that the person knows what he is working with. If the job took longer we would look then at different levels of protection.