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Chemical Use versus Chemical Handling and storage ??
Rank: Forum user 
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I am looking for clarification on whether both the two following scenarios are covered by COSHH Regulations. More specifically where does the requirement for COSHH Assessment stop and start and under whose responsibilty.
Scenario 1 - Chemicals being handled and stored in a warehouse, not classified as dangerous goods under ADR. Product remains appropriately packaged and contained for transit at all times including receipt, storage and despatch.
Scenarios 2 - Chemicals stored and used by a tenant, leasing part of our warehouse area. Our employees are exposed indirectly by proximity only. Chemicals are subject to heavy use daily.
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Rank: Super forum user
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1) NO COSHH assessment required as not in contact with chemicals but assessment of what to do in event of spillage/leakage and safe storage according to chemical properties required.
2) If you don't use the chemicals then COSHH assessment not required by you but by the tenant using them taking into account the exposure of your own employees if relevant.
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Rank: Forum user 
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Without more details, a quick summary would be to go to first principles ie Control of Substances Hazardous to Health.
Scenario 1 indicates no Substances H to H and even if they were, they are controlled by sealed containers - no issue.
Scenario 2 Unknown chemicals that may be H to H (the tenant has a duty to inform you of their status!) that our employees may be exposed to - IMHO your responsibility for the assessment but with the cooperation of the tenant.
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Rank: Forum user
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On 2nd thoughts, I agree with Claire re Scenario 2 but the tenant's cooperation is still needed and of course you and your workers must be informed of the outcome.
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Rank: Super forum user 
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Perhaps one of the most obvious examples of the requirement for effective co-operation and co-ordination in a shared workplace.
You keep chemicals (and there is a foreseeable risk of spillage).
Your tenant keeps and 'uses' chemicals on the same site and presumably in the same general area.
And if these chemicals were to come together..................?
I favour the pragmatic approach - less focus on what Regulations may or may not apply, more focus on identifying and managing the significant risks.
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Rank: Super forum user
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Firstly just because a chemical is not classified in the Approved Supply List as hazardous (i.e. has been allocated a risk phrase) this does not mean that it may not become hazardous under COSHH. Just take a look at paragraph (e) in the definitions of a substance hazardous to health. Even water, under certain circumstances, can be hazardous to health. This is further amplified in paragraph 13 of the ACoP which makes it clear that the Approved Supply List is not the definitive list. There are many chemicals that do not have risk phrases which, in contact with the skin, can result in damage to health. For example I can cite several chemicals, well known to dermatologists as common skin sensitisers, that are not classified as R43.
From my viewpoint (i.e. prevention of damage to health from skin exposure) both conditions require a risk assessment under COSHH. Of course, the first is very simple, since you would only be considering unusual conditions, such as leaking or punctured containers, etc., also the possibility that two, in themselves relatively harmless, chemicals might get mixed and the resultant reaction create a potentially hazardous situation. This is not a theoretical approach. I have had to investigate a case of a skin burn where just this happened.
In the second case I would expect the other party to cooperate in producing a risk assessment covering any risks to the health of your employees (and any others that might be affected) arising out of his use of chemicals. COSHH actually requires him to do this.
Chris
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Rank: Forum user
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Thank you all for your comments so far. Some additional info:
Scenario 1. Under Regulation 6 - COSHH I have been undertaking COSHH Risk Assessments on the stored substances, for some time with particular reference to controls covering correct storage, proper handling and exposure through spillage, (as per your comments).
Scenario 2 - Under DSEAR the fire brigade require us to keep up to date lists of all chemicals held on site. As we use the SYPOL COSHH database for assessments it seems to make sense that I use the same database to record the tenants stored products, (all eggs in one basket?).
A colleague challenged me that both my actions were overkill and not necessary as we do not 'use' any of the products. Have any of you any further comment to make ??
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Rank: Super forum user
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Neville
It is not a question of use but of exposure; if your employees can be exposed, the risks must be assessed.
LB
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Rank: Super forum user
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Agree with leadbelly. If your have chemicals on site then there will always be a risk of exposure, however unlikely. It is this risk that must be assessed, irrespective of whether you use the chemical(s) or not.
Just consider an incident where, due to a fork lift truck damaging a storage bay, resulting in chemical spillage, mixing of chemicals and resultant damage to health due to exposure to toxic chemicals generated by the mixtures. Would you wish to stand up in court and defend not having done a risk assessment?
Chris
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Chemical Use versus Chemical Handling and storage ??
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