Hello, 

I am new to this forum and this is my first post! 

I was wondering if anyone could help me with the COSHH requirements for my workplace. 

We are a small warehouse which sells MDF board with a couple of bench saws which are only used by the customers (Trade only). We have suitable LEV in place that is fully compliant in all respects. The questions I have are as follows:

1. Do I need to complete a COSHH assessment for the wood dust?

2. Do I need the MSDS from each supplier for each type of board?

3. Even if the COSSH / MSDS aren't required for the wood dust potentially generated on our site, do we have to have the MSDS available for customers who purchase these boards from us?

I know MSDS are only required if the material contains harmful substances, but the only thing that might class as this is the formaldehyde content which is about 0.008% max. Is this enough to require a MSDS?

Thanks in advance

Your site, your LEV, your Risk & COSHH assessment.

Not sure about letting customers (even if they are trade) loose with the equipment - PUWER regulations require adequate training and instruction. Letting them cut timber does not transfer H&S liability only removes any miss-cutting disputes.

You will need to conduct an assessment for the generation (control and handling to disposal) of the dust.

You may also need to consider a Dangerous Substances and Explosive Atmosphere assessment to ensure the fine dust is not in itself an explosion hazard.

Current UK EH40 https://www.hse.gov.uk/pubns/priced/eh40.pdf - if there is any hardwood present as a mix the limit is 3mg/m3 8hr TWA otherwise 5mg/m3 8hr TWA.

Given REACH does not mandate a Safety Data Sheet for products deemed to be articles you may struggle to obtain supplier documents and similarly you may be exempt from providing such documents.

An SDS is required where a community workplace exposure limit exists so if your MDF has hardwood present then it would be required.

You will also need information from your suppliers about any chemicals applied to the timber - the Biocidal Product Regulation requires information to be passed along the supply chain when the product has been treated for example with pesticide or fungicide. More info https://echa.europa.eu

Be very wary of non-EU treated timber as any active substances in timber treatments must be of an approved type by a Member State (some products used elesewhere in the world are banned throughout Europe).

On top of that do not forget you need traceability from your supply chain regarding the source of the timber especially if you buy direct from oustide of the main UK distributors https://www.gov.uk/guidance/eu-timber-regulation-guidance-for-business-and-industry

Or you can eliminate all the COSHH/DSEAR issues by stocking and selling cut sizes only - simple economics as to why major chains eliminated their cut to size service.

glazarou

I share the concern already expressed about allowing your trade customers to use your bench saws (assuming these are powered circular or band saws).

Have supervised from a very long distance, one of our staff investigating a dust explosion in a factory making the product you are selling.

However, unless you have a VERY untidy warehouse, there is no way that in the UK you would have customers generating an explosible dust cloud from the simple sawing of MDF board. In the deep and distant past I sent several samples of such material for investigation by HSE's dust explosion lab. The sort of material you are dealing with invariably came back with "not explosible" as the result.

In contrast, during the manufacturing process, much finer dust can be generated and can build up on ledges and such places. Usually, it is the secondary explosion that is devastating, not the first little bang that lifts all the dust in other places.

Very unlikely to have hard wood as a significant component - it's MUCH too expensive. But the other airborne and skin exposure risks do need evaluation. 

The HSE link is quite frightening given it mentions Dichlormethane paint stripper.

Entry 59 on the REACH Annex XVII - restriction list:

https://echa.europa.eu/documents/10162/0ea58491-bb76-4a47-b1d2-36faa1e0f290

states even professionals should no longer use such products after 6th June 2012 

Roundtuit - the heavily cut resources in HSE are much too busy "enforcing" Covid-19 restrictions to be updating guidance that is only 8 years behind the times.