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#1 Posted : 12 March 2009 15:29:00(UTC)
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Posted By bereznikov Hi everyone, I work at a Lower Tier COMAH chemicals manufacturing plant, and in line with the COSHH Regs we undertake LEV systems examination and testing by a competent external contractor every 14 months. Whenever we organise this, we also schedule our occupational exposure monitoring to be done during the same visit (usually over a couple of days). As far as my understanding goes, the recommended frequency of such monitoring by the COSHH ACoP is explained by being needed to be reviewed at "regular intervals". We have never had any Exposure Limit's exceeded. My question is: Does conducting the occupational exposure monitoring every 14 months rather than annually (i.e. 12 months) make any difference as to us complying with the Law? All comments are very welcome, Thanks, bereznikov
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#2 Posted : 12 March 2009 16:02:00(UTC)
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Posted By David Bannister If you stick to the 14 month schedule you will be sampling in different seasons of the year. Temperature, humidity, pressure will all change and each affects the concentrations of airborne substances. Seems like a good idea to me. If you are not measuring anywhere near WELs and the specific substances don't require it, do you still need to carry on measuring?
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#3 Posted : 12 March 2009 16:09:00(UTC)
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Posted By bereznikov Thats a very good point about the seasonal variations in atmosphere, thanks for that. I personally don't think we need to be doing the occ exp monitoring so often as we have pretty thorough control measures on site already. However, I'm a mere 'Adviser' and the company enjoys having a 'Belt, Braces and Parachute' approach to health and safety, so for that reason it need organising. Thanks again for your advice David
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#4 Posted : 12 March 2009 16:51:00(UTC)
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Posted By Fred Pratley By "testing", do you mean levels in air and sorbent badges on individuals or do you also do personal medical surveillance - lung function and skin checks etc. If you are doing medical surveillance that screens for known effects from the chemicals that you use, then your argument for reducing levels in air testing is valid. However, if the company is happy to continue and you have medical surveillance, I would leave well alone!
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#5 Posted : 13 March 2009 08:25:00(UTC)
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Posted By bereznikov Hi Fred, haha, i think that after considering all, i agree with you. The Occ Exp monitoring is personal and static. We also do the badges for one specific airborne substance as part of normal operations, and a medical surveillance programme is in place for all staff. But, like you said, i guess if the management want it, then ok! :-) Thanks Fred
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#6 Posted : 13 March 2009 08:53:00(UTC)
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Posted By garyh I have a lot of experience in this area. It can be quite complicated. Without knowledge of the substances, likely exposures and tasks it is hard to say. testing every 14 months could be way short of the mark - do tasks, exposures not change during this time? I would expect more frequent testing, and targeting high exposure tasks. Hope this helps.
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#7 Posted : 13 March 2009 09:27:00(UTC)
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Posted By bereznikov Hi gary, Thanks for the reply. The types and quantities of chemcials processed are pretty continuous throughout the year. Through a programme of assessment and implementing and maintaining control measures over the past decade, exposure has been cut down to a minimum level, with all previous (5 years) Occ Exp monitoring being found to be way way below any of the relevant WEL's. The remaining areas of risk pose only a small level of risk, but we continue to have these areas/activities as the focus of the Occ Exp monitoring. With all this in consideration, i am really warming to the idea of coinciding our 14-monthly LEV examination visits with the Occ Exp monitoring, as this gives the benefits mentioned in a reply above, of taking into account seasonal variations in temperature, humidity, air pressure, etc etc. Thanks for the reply
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#8 Posted : 13 March 2009 11:02:00(UTC)
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Posted By A Campbell Berez, We do the same.... confirms exposure levels have not increased and also acts as a comfort blanket for employees to see visible proactive monitoring.
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#9 Posted : 13 March 2009 12:08:00(UTC)
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Posted By garyh Sounds great, however I would guard against complacency......why not throw in a few random checks?
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#10 Posted : 13 March 2009 12:20:00(UTC)
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Posted By bereznikov Definitely, I think making any monitoring programme set in stone and too rigid and foster complacency.
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#11 Posted : 21 March 2009 17:15:00(UTC)
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Posted By Jane Bastow Your LEV inspections although required no later than every 14 months 'should be regarded as an annual exercise' - HSG258. The exposure monitoring intervals should be based on a Risk Assessed interval - if they have been consistently substantially below the WEL and your processes have remained constant and your LEV is effective then you should be able to relax the frequency or introduce a reduced rolling program. The comment regarding 14 monthly testing of LEV to account for different weather conditions etc is an old chestnut. The 14 months is a historic legacy from when the only time that boiler examinations could be done was the 4 day Easter shut down (moveable feast). Effective, well designed, well maintained, LEV is effective all year round or there is a problem with the design or the maintenance. Make up air and local ventilation issues vary with the seasons - but the LEV designer would have known that. The log book, the manual and maintenance instructions and the training given to the operators would all explain the importance of make up air, controlling local draughts, and personal fans etc. Assuming of course that the LEV was designed, and the supplier understood their obligation to supply a log book, maintenance instructions, operator training and a manual with this level of detail.
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