I winced at the graphics, became embarrassed reading the first page and angry reading the second. How has this article been published in what is my professional body’s official journal? How can it get the basics so badly wrong?

1. The second paragraph.

This paragraph starts ‘Before undertaking a hazardous substance assessment’. You do NOT assess the hazardous substance. You assess what you are doing with the hazardous substance.

2. Faulty understanding of the Chemical (Labelling and Packaging) Regs and GHS terminology.

The radiation and biohazard symbols are always a yellow / black triangle (as per Signs and Signals Regs). The only time these are not used is when these materials are being transported as Class 7 and Class 6.2 dangerous goods respectively (see for example IATA for details). The graphics used here are incorrect.

The GHS08 symbol (the silhouette) is not just for carcinogens, mutagens and teratogens. It is anything that ‘may cause or is suspected of causing serious health effects’.

The article therefore does not know its own classifications.

The term ‘reproductive toxin’ (stated in the article incorrectly as ‘reprotoxins’) is not equivalent to teratogens. Teratogens (literally meaning monster forming) impact on the foetus. Reproductive toxins is a much broader term that includes chemicals that impact on, for example, male fertility.

The article therefore does not seem to understand that all teratogens are reproductive toxins, but not all reproductive toxins are teratogens.

3. Failure to address all of COSHH.

The article correctly states that new and expectant mothers are at risk if the chemical is a mutagen or teratogen.What is missing is any discussion of COSHH section 7(5). This part of COSHH imposes additional requirements for carcinogens and mutagens.

The article has therefore contrived to miss out a key part of UK chemical safety law.

Most of the carcinogenic and mutagenic effects on a foetus happen when the cells of the foetus are most rapidly multiplying. This is in the first trimester. This is when expectant mothers need most protection, but this is also when they often do not know they are pregnant. The only sensible way to get around this problem is to control the carcinogens and mutagens so stringently that exposure approaches zero, male or female, pregnant or not. With this approach taken, new and expectant mothers are at the same risk as everybody else (i.e. negligible).

Everybody, including asthmatics, are at risk of harm from sensitisers. The article misses the critical point that it may be a sensitising chemical that is causing the asthma in the first place. It is these sensitised asthmatics exposed to their sensitising chemical who are at significantly increased risk.

4. Exposure routes / control measures.

The article fails to make the critical link between link between exposure routes and control measures. Eliminate the exposure route and you control the risk.

5. Dealing with the risk.

The article presents a list of control measures that can be implemented to control risk. What it fails to do is indicate this is a hierarchy of control. As presented in the article, PPE is just as acceptable a control measure as substituting a hazardous chemical for a less or non-hazardous chemical. This is obviously not correct.

6. ‘Rotate staff to minimise exposure times to hazardous chemicals’.

The implication of this statement is that it is an acceptable control measure for employers to expose staff to hazardous chemicals up to the Workplace Exposure Level threshold and then move them to other activities whilst other members of staff get exposed in turn.

As such, this statement is a disgrace. It is outrageous to see this in a ‘Health and Safety’ article as a control measure.

7. Emergency procedures. 

The article appears to mix up engineering controls, administrative controls and emergency controls.

8. Very, very strange examples given. 

Throughout the article there are a number of very strange examples given. The three most egregious are listed below in the order they appear in the article.

1. Dangerous to the environment: e.g. chlorofluorocarbons.

It is true that they are dangerous to the environment, but CFCs were banned by the Montreal Protocol in 1995.

2. Toxic: e.g. asbestos.

Asbestos is carcinogenic, not toxic.

3. Replace asbestos with safer synthetic substitutes.

This would only be a control measure if it was still permissible to use asbestos (finally banned in UK in 1999).

The impression given by these examples as well as the errors in chemical safety (COSHH regs rolled out from 1989) is that the article is based on a very old, pre-1989 article that has been badly updated.

I would cancel my subscription, but my employer insists I am a member of IOSH.

Sort of sums up the worth of the content when no one is willing to put their name to the article

It is with trepidation that I consider opening my copy of IOSH Magazine.

People do often get COSHH wrong but it shouldn't be happening in our own magazine.

Edited by user 10 January 2022 14:57:39(UTC)  | Reason: typo

Dear all.

Letter to Editor being drafted.

SMoore5C

I've just looked at the article in question and I must admit it is very weak and shallow with no insights into how people get COSHH wrong, which to be honest is what I would expect IOSH matters to be doing.

“I see elsewhere that this mag has won competitions for best in class, I believe-not sure which class, maybe remedial?”

Most Style over least substance?

To the Editor.

Dear Emma.

I am writing to express my significant concerns about the recent article ‘The Right Chemistry’, published in the January / February 2022 edition

My review of the article has been posted on 10th January 2022 on the IOSH discussion forum. The link is here; IOSH Magazine - Chemical Safety Article.

To be brief, in several sections the article is factually incorrect. Other sections are factually correct but missing critical information, making the information highly misleading. Finally, there are several statements which, though true, are ridiculous given the chemicals concerned are banned (and have been for many years).

I would be grateful if you could provide me with some insight into the questions raised at the start of my review. These are:

·         How has this article been published in what is my professional body’s official journal?

·         How can it get the basics so badly wrong?

I would also like comment on my final remarks ‘The impression given … is that the article is based on a very old, pre-1989 article that has been badly updated’.

Please note this email shall be published on the IOSH discussion forum thread, as will your response.

Certain concerns raised here have been brought to our attention with regard to the recent 'Back to basics' article on chemical hazards in IOSH Magazine (Jan/Feb 2022). An email was also received by our magazine's editor. 

For comments, complaints and feedback of this kind, IOSH has a specific process designed to ensure the right staff are alerted to assess and reply appropriately. Full details are here - https://iosh.com/more/contact-us/comments-compliments-and-complaints/ We recommend you use this instead of forum threads we may not see. 

In this case, two corrections are valid and we apologise for any ambiguity or errors in the printed article. 

With regard to teratogens, we accept that the term in brackets after reprotoxins (reproductive toxins) may have implied it was a ‘subset’ of reprotoxins. The online edition has now been altered to remove those brackets and include a comma before the word teratogens. 

We also accept that the classification 'Toxic' should not have given asbestos as an example alongside lead. Asbestos is a carcinogen not a toxin. This has now been corrected in the online edition.  

The purpose of our back-to-basics articles is to provide a general overview of themes and principles suitable for a global audience. For instance, we deliberately do not cite legislation or regulations (such as COSHH) particular to certain territories, and diagrams accompanying the article show ways chemicals can enter and affect the body, so do deal with exposure routes.  

This feedback has provided opportunity for us to reflect on how this series is presented and explained, and we will take this into account in future issues. Thank you.

Edited by user 10 February 2022 13:52:21(UTC)  | Reason: Spelling corrected in paragraph 4

Bonjour from sunny La Belle France

As above, thanks for the response, although we still do not know who wrote the article.

My view, and other poster's, is that at least a passing reference to the requirements and existence of COSHH should be included particularly as, no doubt, you would be expecting CPD points to 'be scored' by readers of this series [80%-ish of whom will be UK based] Future articles will be perused carefully.

Loved the appropriate typo, coma for comma!

Regards

Mike

PS It's the first time we have had a post from Team.IOSH. Who are they then?

I had a cursory skim of the preferred method of reponse, to see-very typically IOSH, much more long-winded than a forum post which you really should be checking, there's lots to learn on them