Rank: Super forum user 
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Can someone help on my limited COSHH knowledge, after reading the guidance I remain confused:
Section 15 of the MSDS states if the product is classified as hazardous. If non-hazardous the product does not require a coshh assessment?
Even though section 2 and 3 lists ingrediants which may be hazardous and precuations to take?
This is where I get confused - parts 2 and 3 seems to say the product is a hazard and part 15 does not!!
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Rank: Super forum user
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I believe the section 15 part is in relation to the classification of the product under CHIP
This means that a chemical substance may contain lots of small parts of "hazardous materials" but the overall concentration or % of the final product is below the threshold for product to be classified as an irritant.
Whether or not this means the product will be hazardous or not to your employees would depend on quantity and duration of exposure and the hazards associated with the individual chemical components which make up the product, some of which may have an additive effect or even multiplicative effect.
Also even if a substance is classified as non-hazardous e.g. innert such as CaSiO2 or certain wood dusts, the concentrations in the work place may still exceed the limits stated in EH40 and may represent an irritant risk to those using them
Des
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Rank: Super forum user
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Martin,
There are several definitions of a hazardous substance contained in the COSHH Regulations. The one you need to consider is:
“(e) which, not being a substance falling within sub-paragraphs (a) to (d), because of its chemical or toxicological properties and the way it is used or is present at the workplace creates a risk to health”
COSHH Regulation 2 (1) Interpretation
In effect, any substance can become a hazardous substance depending on how it is used.
You also refer to the safety data sheet. I assume you have a copy of the ACoP for COSHH. Take a look at paragraph 13. This indicates clearly that the data on a safety data sheet it not necessarily sufficient for a risk assessment for chemical exposure under COSHH.
There are literally thousands of substances that do not carry risk phrases (or now hazard phrases according to CLP Regulation) but that can cause damage to health, particularly where skin exposure occurs. In fact, statistically wet work, i.e. skin contact with water, is the most common cause of occupational contact dermatitis. There are several well established and common sensitisers that do not carry R43 and therefore will not appear on the safety data sheet.
Remember that the safety data sheet is prepared for CHIP, not COSHH. It is a starting point, nothing more than that. It tells you about the product as supplied. When you use it you may well change the hazard. You need to identify the real hazard of the chemical as used, not as purchased and base your risk assessment on that.
Consider also the requirement under the Health and Safety at Work Act 1974:
It shall be the duty of any person who designs, manufactures, imports or supplies any article for use at work:-
(c) to take such steps as are necessary to secure that there will be available in connection with the use of the article at work adequate information about the use for which it is designed and has been tested, and about any conditions necessary to ensure that, when put to that use, it will be safe and without risks to health.
HASAW Section 6-1
Has your supplied met his obligations under the Act?
If you need more on this I have a handout for a presentation that I gave to an IOSH regional meeting on this topic that I will happily e-mail to you if you PM me your e-mail address.
Chris
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Rank: Super forum user 
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Hi Martin,
I know it may sound like a cop-out, but if a substance comes in with am MSDS then we assess it anyway. This may not be required in some cases, but at least we know we are covered and that the MSDS has actually been read thoroughly.
I would rather over-assess than miss something, just MHO.
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Rank: Super forum user
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Word of warning though, some if not a lot of MSDS are not worth the paper they are printed on, especially when it comes to the PPE/RPE and handling sections
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Rank: Super forum user
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Re the comment in the previous posting, take a look at these:
“Non-compliant MSDS may have been as high as 42%” - Keegel T, Saunders H, Nixon RL; Material safety data sheet accuracy: Reporting of skin irritants and skin sensitizers - Poster at OEESC, Stockholm, June 2005
In a study in the U.S.A. 150 safety data sheets were examined. 53% contained inaccurate information on the use of PPE. Only 37% contained accurate information on the health effects of the substances involved. - Kolp, Williams, Burtan, AIHAJ, 1995, 56, 178-
“HSE’s experience suggests that a large proportion of SDSs do not provide adequate or correct information on hazards and exposure controls.” – from Topic Inspection Pack, Work Related Contact Dermatitis, Skin Disease Programme
Last year I reviewed 50 MSDS for a client, only 1 was correct in all respects. Four were from different suppliers for the same substance. None of them had the same risk phrases and none agreed with the Approved Supply List!
Chris
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Rank: Super forum user
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Frightening stuff.
But apart from the MSDS and the label what do we have to work with?
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Rank: Forum user 
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Sections 3 and 4 of the MSDS should contain information about potential risks from entry routes into the body which are not necessarily linked to the hazard identification. Essentially; if it can cause harm/irritation/damage through inhalation/ingestion/eye contact or skin contact you will need to RA it under COSHH regardless of hazardous labels or classification. Chris Packham has quoted the relevant legislation.
Additionally, I have in front of me an MSDS for Binzel anti-spatter (used for welding operations). Its not classified as hazardous (specifically non-toxic) but if it comes into contact with eyes can still cause damage or at least discomfort. I do agree with the comments ref: MSDS unreliability. Its not stated anywhere on the Binzel MSDS but I guarantee you, toxic or not, if you ingest enough of that substance you wont feel peachy (wont taste so nice either).
If, like me, your no expert in chemistry or toxicology; the main resource you have is your experience in your industry, knowledge of how the substance is used and the processes its used in. Or the knowledge of your operatives perhaps?
Hope that helps a little....
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Rank: Forum user
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Martin,
Couple of things about COSHH generally.
You should not consider that COSHH is substance specific.
First, COSHH is more to do with your work operations and how those operations generate potential substance exposures than the substances themselves. The important word in the title is “control”.
Second, remember the basics. All substances are toxic, the dose crates the poison. In essence, if you wash dishes at home once or twice a day, it’s doubtful you suffer any effects from that. If you spend 8 hours a day washing dishes at work, you will suffer some degree of ill health. The fact that a substance is not classified as harmful does not mean it will not cause ill health with sufficient exposure.
If you consider both the above points correctly you should conclude that; 1. a COSHH assessment should be operation based not substance based, so the operation should be covered by one COSHH assessment, and not be governed by the number of substances used in the operation; 2. all hazardous substances should be considered to ensure that potential exposures should not cause ill health and that exposure to substances that are essentially non-harmful will not be significant enough to cause them to be harmful.
A COSHH assessment is a fairly specialised thing to do, but if you take the general approach above the purpose of the assessment becomes somewhat clearer.
Hope that helps.
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Rank: Super forum user
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Step back from the Safety Data Sheet and just consider section 6-1 of the Health and Safety at Work etc. Act 1974, from which I have quoted in my earlier posting. It is incumbent upon the supplier to provide this information. If has has not included it with the MSDS then he needs to provide it as additional information.
Of course, with REACH this should ideally be covered by the Exposure Scenarios that will accompany the MSDS - but I have my doubts whether this will really work.
As someone who spends considerable time on COSHH risk assessments I entirely agree with kd. It is the task that is important. If we had called it "Control of exposures arising out of work with chemicals that could result in damage to health" perhaps people would have become less hung up on data from MSDS and looked more at what was actually happening in that workplace.
Chris
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Rank: Super forum user
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All,
Thanks for your help. The key thing has to be the task.
I even have a simple example, although not work related - washing up liquid.
I have problems when using a certain brand of washing up liquid - oddly one of the more expensive brands. Repeated exposure causes cracking to my skin which is unsightly and painfull.
Prior to this discussion I might have been tempted to see this substance as not requiring an assessment but it is clear that I should establish the usage time of the product, the number of exposures and who is being exposed. It is possible I could be asking others to use this product who are even more sensitive to it than me.
Control measures for myself have so far been simply switiching brands or getting someone else to do the washing up.
My wifes suggestion of a dishwasher was rejected as it would entail a new kitchen and is therefore not reasonably praticable considering the risk!!!
Thanks again.
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Rank: Super forum user
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Martin,
Two suggested control measures you might consider in addition to changing the brand of liquid:
a) Long handled brush - minimises hand contact with the washing up water, and
b) Wearing a pair of rubber gauntlets to eliminate the actual contact. (Note, natural rubber latex gauntlets do not present any real hazard as regards latex allergy and are used widely in catering establishments for this very purpose)
Somewhat cheaper that reconstructing your kitchen and purchasing a dishwasher - although in an occupational setting this might be something that an employer would need to consider!
Chris
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Rank: Super forum user 
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Some good answers, Just thought I'd share a link to a poster that supports what Chris said. http://www.hse.gov.uk/skin/posters/contact.pdfTheir skin page has some reasonable resources and guidance..... *ducks* and waits for Chris to point out their errors :)
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Rank: Super forum user
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Actually, I have nothing against that poster. It makes some excellent points. It is when HSE appear to consider natural rubber latex gloves as suitable for thinners in a paint spray booth, and that a risk assessment based on risk phrases (soon to become hazard phrases), e.g. COSHH essentials, that I have concerns.
Chris
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