The risk phrases in section 16 are normally the ones that apply to the ingredients, not to the whole preparation. So yes you are right, the reason it doesn't have any risk phrases or Xn/Xi classification is that these ingredients are present in too small quantities. However this of course doesn't make it completely harmless so I would agree with assessing it - although the control measures are not likely to be onerous, you may still not want to be sticking your arms in it, etc.

Whilst agreeing with the forgoing replies I would include the section 16 in your assmt outcome just in case there's a reaction to the product in use. This way it shows you have considered potential hazards.

Badger

Your assessment is not just of the substance but also how it will be used and what effects it will have on the user etc. etc.

If during your assessment, as above, you decide it is low hazard then that is your finding. Don't worry too much about phrases as it is the whole ball game that is important.

What is important is to carry out the assessment, if you come out with low risk that's good, keep your records.

The usual can of worms often discussed on this Forum? If the Product isn't hazardous for supply, why does it have a MSDS. The answer of course being that customers continually ask for it!
So many of these MSDS are inaccurate, misleading and sometimes downright wrong.
For the avoidance of doubt, you could try asking the supplier if any of the harmful/irritant constituents can become bio-available during use. You also need to be wary of any constituents that are sensitisers.

Jim

If any of the ingredients are sensitisers, even traces could elicit a reaction in someone already sensitised so you do need to consider the ingredients as well as the mixture.

LB

Firstly, keep in mind that the safety data sheet is to comply with CHIP and may not be relevant for COSHH. Take a look at para 13 of the COSHH ACoP on this. Take a look also at section 6-1 of the Health and Safety at Work etc. 1974 Act to see what your supplier should be providing you with.

For your COSHH risk assessment what you need to assess is the hazard of the substance 'as used' and not 'as supplied'. The two can be very different.

There are hundreds of substances that do not have risk phrases and thus will probably not appear on the safety data sheet, but that in contact with the skin can result eventually in the development of contact dermatitis.

There are also substances known to dermatologists as common sensitisers that have not been classified as R43. They probably won't be on the safety data sheet either, but might be in your product.

Wet work, e.g. exposure to water, is one of the more common causes of occupational contact dermatitis.

There is also the issue of bioavailability. Nickel and chrome are common sensitisers, but in chrome-nickel-steel (aka stainless steel) they may be so tightly bound that they will not cause an allergic response, even in someone already sensitised.

Remember - it is the hazard that arises when you use the chemical that is what you need to risk assess, and this may not be what is on the safety data sheet.

Chris