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pseudonym  
#1 Posted : 19 November 2021 11:51:31(UTC)
Rank: Forum user
pseudonym

Good morning, all.

In the past I've managed to have some success in getting my teams to use COSHH Essentials for their COSHH assessments, but now we will have a couple of compressed gases getting into the equation. How does anyone else assess the use of compressed gases in terms of COSHH.

Briefly (and without divulging anything confidential) we would be handling active pharmaceutical ingredients in various aerosol formats for sprays / inahalers etc, and the work would be around the mix of ingredients that go into the aerosol, which could include a variety of compressed gasses.

Any pointers towards how others have managed this would be really helpful.

Thanks. P

A Kurdziel  
#2 Posted : 19 November 2021 13:37:34(UTC)
Rank: Super forum user
A Kurdziel

Ok so you have a process which might lead to people being exposed to substances hazardous to health. COSHH requires that you manage this process using a risk assessment. The first step of  the risk assessment would be to identify all of the hazardous substances used in the process. Do you have SDS’s for the pharmaceutical ingredients and gases?  Do any of the substances have WELs as defined in EH40 is there any information “out there” about these substances?

Based on that you need to make a judgement call as to whether exposure to these substances constitutes a hazard to your employees. You then need to look at how the process will worsen the effect of the substances, creating a greater risk of exposure. Will it create an inhalation risk, absorption through skin or mucous membranes risks, an ingestion risk or even an injection risk.

Then you need to decide on the controls: do you need to completely isolate the process so nobody can come into contact with the substances? What would you do about  maintenance work when you may have to turn off some or all of the controls? If you can’t     completely isolate it will you be relying on LEV? Is it the right LEV for this purpose? Will you arrange for the LEV to have its statutory testing? Against what standard?  What administrative controls will you have? Will you enable and make staff wash their hands after working with these pharmaceutical products? Will you regularly check the gas lines from the cylinders for leaks? Will you have a low oxygen monitor in case an asphyxiant gas leaks out? Nasty gases often have a smell added but if these  gases are going to be used to deliver drugs, then you don’t want any sort of smell from them. Will you measure levels of hazardous substances  in the atmosphere in the work area? Will you carry out health surveillance of  staff working in this area?

Having considered everything will you tell employees to use PPE? Will you make sure that the PPE fits them and that they are wearing it correctly?

What will you do if it all goes wrong ; what the plan if there is a fire or a massive leak? What is the clean up procedure?

And of course finally how will you inform and train your staff so they do all of this  correctly?

 

As you can see COSHH is very easy! Sorry about the info dump, but it what comes out if I hear the word COSHH.   

   

pseudonym  
#3 Posted : 19 November 2021 13:50:48(UTC)
Rank: Forum user
pseudonym

OK, somewhat naively I'd hoped for a helpful response.

I'll try re-phrasing my question instead.

Having marshalled my troops and marched them up the metaphorical hill that is COSHH Essentials, I'm now looking at various scenarios where compressed gases may be used - COSHH Essentials does not readily accommodate compressed gases, so without asking my teams to sign up to a different risk assessment process for compressed gas involing tasks, how do / would other professionals deal with this.

I'd like to think that I have reasonale grip on COSHH, as good as many, but not some on this forum, so please no more telling me ehat COSHH is about, I'm sure it was well-meaning, but it didn't answer the question I asked, or thought that I had asked.

chris.packham  
#4 Posted : 19 November 2021 13:55:21(UTC)
Rank: Super forum user
chris.packham

As someone closely involved with COSHH for years I agree completely with AK. What is important is that the COSHH assessment is for the specific task. What happens during the task? What chemicals are used (and remember that they may not have or be on a safety data sheet)? What happens to them when they are used and what are the resultant hazards? These can be significantly different from what you started with and what is on that SDS. What is the actual/potential exposure to these hazards? Could exposure by different routes (inhalation, ingestion, dermal) be cumulative or synergistic? Could this affect the significance of compliance with the WEL? (Studies have shown that facial skin exposure at below the WEL can, with some chemicals, cause damage to health and thus require appropriate exposure management.) What is the risk of damage to health from the exposure? How will you manage this? How will you then monitor that your COSHH management strategies are working? (Health surveillance anyone?). What will you do if there is an unseen event that causes an unexpected exposure?

In my view COSHH essentials cannot do this. As is stated by HSE COSHH essentials can only create a generic risk assessment that cannot take into account the many variables that can occur during a specific task. 

Brian Hagyard  
#5 Posted : 19 November 2021 13:58:01(UTC)
Rank: Super forum user
Brian Hagyard

i use the same risk assessment documentation for a COSHH assessment as i would for any other assessment. COSHH esentials helps me identify the controls etc which i place on that form. It also allows me to include the safety risk frrom a presure realise/explsosion etc that COSHH does not cover.

Im lucky very fre of the "compressed gases" we have actualy have a "health Risk" just safety.

Hope that helps - as you say you are protecting confidentiality which makes a definative answer hard.

thanks 1 user thanked Brian Hagyard for this useful post.
pseudonym on 24/11/2021(UTC)
Kate  
#6 Posted : 19 November 2021 14:04:35(UTC)
Rank: Super forum user
Kate

COSHH Essentials is very basic and as you say is not set up to deal with compressed gases.

So you would need to go back to first principles for the COSHH assessments.  This probably means arranging some training for the people doing the assessments.

Having said that, most COSHH assessment training is rubbish so you would need to shop around for a good one.

There are also the various commercial online COSHH assessment services, but they are set up just to give you impressive-looking, lengthy documentation hiding a generic risk assessment that doesn't take your process into account.

I don't think there are any short cuts to this, which is why you may find all of the responses unhelpful.

thanks 5 users thanked Kate for this useful post.
chris42 on 19/11/2021(UTC), Roundtuit on 19/11/2021(UTC), pseudonym on 19/11/2021(UTC), peter gotch on 19/11/2021(UTC), A Kurdziel on 23/11/2021(UTC)
pseudonym  
#7 Posted : 19 November 2021 15:05:58(UTC)
Rank: Forum user
pseudonym

Thanks Kate,

My point was (perhaps not very well made) that I can get my teams to use COSHH Essentials (for all it flaws) to carry out COSHH Assessments - there are too many other things that need my attention to allow me to carry out all the COSHH Assessments (and surely if a RA is to be done the best people are those who carruy out the task - provided they have the competence and skills?)

Having got them to use COSHH Essentials I was hoping that someone may have found a way around this - another format for these assessments (or revisiting all the existing ones and redoing them in a new format) might well be more than they will readily accept. 

I don't need telling what COSHH requires, I need a format that my people can follow, use and complete - I'm more than happy to admit that I inhabit an imperfect world, but COSHH Essentials, has until now met that particullar bill,

Thanks anyway

A Kurdziel  
#8 Posted : 19 November 2021 15:10:55(UTC)
Rank: Super forum user
A Kurdziel

Not knowing exactly what you are doing makes it difficult to tell you anything specific. As Chris said COSHH essentials is something for routine work activities. What you seem to be taking about is a technical process and COSHH essentials  is not really intended for that: you should be starting from first principles and given what you say you may be working with it is important that you get this right. It is also not clear whether you are talking about something new  or something that you have been doing for some time. If it is an established procedure, what are the current risk assessments based on if not COSHH?    

Edited by user 19 November 2021 15:45:14(UTC)  | Reason: spellings

peter gotch  
#9 Posted : 19 November 2021 16:06:15(UTC)
Rank: Super forum user
peter gotch

Sorry, Pseudonym but I am with others on this. COSHH Essentials will not cut it for the risk assessment you describe.

Which means going back to first principles rather than using what HSE always said was not suitable for every application.

....and even first principles is going to be potentially complicated. You need to consider the interaction between various ingredients. Are the effects entirely different, additive, "synergistic" or possibly involving chemical reactions to produce completely different contaminants.

P

thanks 1 user thanked peter gotch for this useful post.
A Kurdziel on 22/11/2021(UTC)
stevedm  
#10 Posted : 19 November 2021 16:47:23(UTC)
Rank: Super forum user
stevedm

...you can only go so far with COSHH essentials...your industrial hygienist should be able to guide you since it is API..which OEB?..that will dictate the containment measures - mechanical, ventilation, maint, and PPE...HFA inhalation would be main route so repiratory..

this gives some sense of the toxicology on it but I would refer to your IH support in house...drop me a pm if you need to...

https://citeseerx.ist.psu.edu/viewdoc/download?doi=10.1.1.858.7291&rep=rep1&type=pdf

thanks 2 users thanked stevedm for this useful post.
A Kurdziel on 22/11/2021(UTC), pseudonym on 24/11/2021(UTC)
chris.packham  
#11 Posted : 19 November 2021 22:08:51(UTC)
Rank: Super forum user
chris.packham

May I suggest that responsibility for COSHH compliance lies with the organisation and need therefore to engage all relevant knowledge within and outside the organisation that could contribute to effective management of chemicals. In anything but the smallest organisation this will mean that whilst overall responsibility for COSHH has been delegated to a single individual the COSHH risk assessment and management activity will almost certainly require input from more than one person. Certainly there may be need for an industrial hygienist to conduct measurements, but possibly also someone with the industrial chemistry knowledge to correctly identify the hazards of chemicals as used, someone with the knowledge to identify how exposure to these can affect health of the exposed and the consequences of such and, of course, input from those who actually carry out the work. as only they will probably have sufficient knowledge of what really happens not only during normal conditions but when, perhaps only very occasionally and short term, there is a deviation from the normal (standard work practice). The interaction between chemicals and the human frame is far more complex and our knowledge of this so far from complete and it is easy to reach assumptions that do not match reality. Whilst I am a believer in keeping it simple this should never be at the cost of accuracy.

thanks 1 user thanked chris.packham for this useful post.
A Kurdziel on 22/11/2021(UTC)
chris.packham  
#12 Posted : 20 November 2021 10:03:25(UTC)
Rank: Super forum user
chris.packham

As an addendum to my comments I recommend taking a look at section 6(4)-2 of the Health and Safety at Work etc. Act and ask yourself whether the standard safety data sheet really provides the information that this part of the Act requires.

stevedm  
#13 Posted : 22 November 2021 07:26:38(UTC)
Rank: Super forum user
stevedm

HFA is OHC 4...10 mcg/m3..you should base your engineering controls and sampling around that level.. 

thanks 1 user thanked stevedm for this useful post.
pseudonym on 24/11/2021(UTC)
JohnW  
#14 Posted : 23 November 2021 18:34:24(UTC)
Rank: Super forum user
JohnW

Pseudonym wrote > I don't need telling what COSHH requires, I need a format that my people can follow, use and complete - I'm more than happy to admit that I inhabit an imperfect world, but COSHH Essentials, has until now met that particullar bill< You’ve got work to do, and if you know the hazards of your materials/gases then use your knowledge of COSHH which you have implied is equal to those who gave you the expert advice above. Good luck!

Edited by user 23 November 2021 18:35:51(UTC)  | Reason: Typo

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