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FlashingBlade  
#1 Posted : 13 June 2022 16:48:25(UTC)
Rank: Forum user
FlashingBlade

So, walking around a site today and I notice a new extraction system being installed. I query the site managment on where is the design specifications, commissioning data, installer accreditation documentation etc etc only to be told its not actually a LEV system, its a system designed to improve product quality, not protect employees. 

My question was then 'well, what would happen to that contaminent if the extraction isnt fitted or if it fails to function correctly, could it become airborne?'

'Yes' - was the reply

'And could someone potentially inhale that contaminent?' 

Again yes was the response 

'So its therefore helping protect workers in the area?'

'Only as a side benefit' 

Long story short, their view was that even without the LEV working, there was never a scenario whereby enough dust would be generated so as to become hazardous (anecdotal) and that because the primary purpose was to maintain product quality, it doesnt fall under COSHH. 

Just wondered what others thought? 

Ian Bell2  
#2 Posted : 13 June 2022 17:06:04(UTC)
Rank: Super forum user
Ian Bell2

Would need to see the CoSHH assessment to see the justification for the contractors argument.

FlashingBlade  
#3 Posted : 13 June 2022 17:17:25(UTC)
Rank: Forum user
FlashingBlade

Originally Posted by: Ian Bell2 Go to Quoted Post

Would need to see the CoSHH assessment to see the justification for the contractors argument.

There isnt one as the material being processed isnt inherently hazardous. It generates dust during processing which could then be hazardous upon inhalation as cotton/wool dust (2.5 and 10 mg/m3 respectively as per EH40. 

Brian Hagyard  
#4 Posted : 14 June 2022 07:08:05(UTC)
Rank: Super forum user
Brian Hagyard

Originally Posted by: FlashingBlade Go to Quoted Post
Originally Posted by: Ian Bell2 Go to Quoted Post

Would need to see the CoSHH assessment to see the justification for the contractors argument.

There isnt one as the material being processed isnt inherently hazardous. It generates dust during processing which could then be hazardous upon inhalation as cotton/wool dust (2.5 and 10 mg/m3 respectively as per EH40. 

If its a respiratable dust then it is a substance hazardouse to health and is covered by COSHH - dont be fooled that its OK as no safety data sheet!

FlashingBlade  
#5 Posted : 14 June 2022 08:17:55(UTC)
Rank: Forum user
FlashingBlade

That was my view too. They may have intended the system to improve product quality by removing dust from the process but if the abence of the extraction system would potentially lead to the problematic (from a production perspective) dust becoming airborne and therefore respirable, then it has to meet the requirements of a LEV under COSHH. 

Ian Bell2  
#6 Posted : 14 June 2022 08:21:40(UTC)
Rank: Super forum user
Ian Bell2

I would still expect to see some form of screening assessment, to justify the decision of the dust being non hazardous - and no requirement for a full CoSHH assessment.

However as indicated by others I would guess it will get captured under the general dust clause of CoSHH

Roundtuit  
#7 Posted : 14 June 2022 09:16:44(UTC)
Rank: Super forum user
Roundtuit

Given Cotton Dust has a lower EH 40 value 2.5 mg/m3 than its constituent Cellulose 4mg/m3 there is a need for control to prevent disease such as Byssinosis (mill workers lung).

As with all combustibles you would want the extraction system under frequent maintenance & cleaning.

Roundtuit  
#8 Posted : 14 June 2022 09:16:44(UTC)
Rank: Super forum user
Roundtuit

Given Cotton Dust has a lower EH 40 value 2.5 mg/m3 than its constituent Cellulose 4mg/m3 there is a need for control to prevent disease such as Byssinosis (mill workers lung).

As with all combustibles you would want the extraction system under frequent maintenance & cleaning.

antbruce001  
#9 Posted : 14 June 2022 10:56:51(UTC)
Rank: Forum user
antbruce001

Go back to first principles, to reduce risk SFARP. If a system is installed already, then it must be reasonably practicable to maintain it as a LEV system as the cost implications are minimal. Also, you are maintaining the quality improvements you purchased the equipment for in the first place. The debate isn't 'should a LEV be provided to ensure compliance with COSHH', as the system has been installed anyway but rather 'should we maintain and check preformance of the system as a LEV system because it's reducing the risk of exposure to hazardous sudstances as defined in COSHH'. 

Roundtuit  
#10 Posted : 14 June 2022 12:20:38(UTC)
Rank: Super forum user
Roundtuit

Such considerations of course are dependent upon the systems design being adequate for extraction with reagrds to purposes of health rather than ambient air quality.

By exmaple a fume cupboard has a "working" height marked for its sash opening - fully open and the extraction is insufficient to draw contaminants, closed to mark and the inward air flow prevents the contaminants seeping back in to the room. Same extraction in both scenarios.

Roundtuit  
#11 Posted : 14 June 2022 12:20:38(UTC)
Rank: Super forum user
Roundtuit

Such considerations of course are dependent upon the systems design being adequate for extraction with reagrds to purposes of health rather than ambient air quality.

By exmaple a fume cupboard has a "working" height marked for its sash opening - fully open and the extraction is insufficient to draw contaminants, closed to mark and the inward air flow prevents the contaminants seeping back in to the room. Same extraction in both scenarios.

Kate  
#12 Posted : 14 June 2022 13:34:22(UTC)
Rank: Super forum user
Kate

I'm clearly going against the flow here.  My argument is that if an extraction system has been installed for reasons that have nothing to do with COSHH, and it isn't a control measure referred to in the (COSHH) risk assessment (on the basis that it hasn't and wouldn't be provided for the protection of health), then it doesn't need to be maintained as a COSHH control measure (as it isn't a COSHH control measure) and therefore doesn't need the thorough examination and so on (which you wouldn't be able to do anyway as if it hasn't been designed to protect health, you won't have any relevant design criteria to compare it against - as the OP alludes to).

It's like asking for a face fit test for a face covering worn under Covid guidance (seeing it as RPE which it is not).  Or an EN169 certification for a pair of sunglasses (seeing them as protective eyewear which they are not).  It might look like something that is a health control measure, but it is outside the scope of H&S regulations.

thanks 2 users thanked Kate for this useful post.
Brian Hagyard on 14/06/2022(UTC), Evans38004 on 14/06/2022(UTC)
Brian Hagyard  
#13 Posted : 14 June 2022 14:19:07(UTC)
Rank: Super forum user
Brian Hagyard

No i agree Kate it has not been designed as LEV - but perhapse it should have been. Thats should have been on the basis of a risk assessment - which because of the respirable dust we would class as a COSH assessment. Someone else has raised the risk of it also being explosive (not my field) in which case any extraction system should take that into account as well. Im still not sure why this extract system has been installed.

John Elder  
#14 Posted : 15 June 2022 14:21:46(UTC)
Rank: Forum user
John Elder

The answer is simple providing you know what the ventilation has been provided for. Is it to provide general / dilution ventilation for the area which then isnt LEV.

Or was it to capture the release of dust at source to prevent exposure then it would be LEV.

People confuse general ventilation with LEV systems all the time, the difference is general ventilaion may or may not draw the air flow (contaminated or not) accross the breathing area/zone off the operator, whereas Local Exhause Ventilation captures the contaminated air at source of release or at a close proximity to the release without drawing the contaminant across the operators breathing zone/area (If designed correctly).

If the system is being used for general process ventilation then it will not require inspection. If it is there to control the levels for exposure then it is LEV. 

You mentioned that it was to help the process as opposed to being for control of exposure then thats fine, but both types of system should'nt be confused and dont normally get uses to provide both purposes.

If you have concerns of exposure level from dust should the ventilaion system fail then the process should be interlocked to the ventilaition system. This will prevent the process for running and contanimating the air without the ventilation running. If you are concerned that there could be a sudden buildup of contaminent then and interlocked LEV system could be considered.   

A Kurdziel  
#15 Posted : 15 June 2022 15:24:12(UTC)
Rank: Super forum user
A Kurdziel

The issue is clarity as to what you are doing. You identify a risk of exposure to an airborne hazardous substance; you may decide that the best control is some sort of  LEV then you check it to make sure that it is providing the level of protection you require. You might decide that the ventilation in the work area  can also sufficiently reduce the risk of exposure: if that s the case it is still a control and needs to be checked whether you call it LEV or not.

On the other hand in some labs people use things they call Laminar Flow cabinets. These are designed to prevent contamination of  materials and reagents. They work by blowing filtered air over the work area towards the user.  They do not offer any sort of user protection (a bit like the face coverings mentioned). This does not require statutory  testing but if you start getting product contamination issues then you probably wish had tested it.

People are often using Class 2 cabinets nowadays because they offer both operator and product protection. They are definitely LEV and there is no such thing as a “side benefit”; if it proves user protection it’s a control and needs to comply with all that entails.  

peter gotch  
#16 Posted : 15 June 2022 20:14:03(UTC)
Rank: Super forum user
peter gotch

Let's look at this from a legalistic perspective.

The case law says that "practicable" requires what is possible in the light of "current knowledge and invention", which is a regularly moving parameter as technology moves on.

Assessing what is "reaonably practicable" means working out the cost in terms of time, money and effort and deciding whether the cost of mitigating a risk is "disproportionate" or "grossly disproportionate" depending on which legal judgment you prefer, but with the onus on the duty holder in both criminal and civil proceedings to prove (on the balance of probabilities) that they have done all that is "reasonably practicable".

So, imagine this process without extraction and say the exposure of workers might be 50% of the occupational exposure standard.

It might cost £X,000 to reduce that exposure to 10% of the occupatational exposure standard and that might NOT be reasonably practicable.

However, if the same £X,000 is spent to assist with quality and not to reduce exposure, but where a side effect is to reduce exposure to 10% of the OES then the marginal cost of reducing exposure is NIL.

ERGO it is reasonably practicable to reduce exposure to 10% by the installation of extraction.

Then for operational reasons it will make sense to check that the extraction works - for quality reasons. 

From a COSHH or other health and safety legal perpective the marginal cost of doing what is required for operational reasons is also NIL - and so is "reasonably practicable".

The situation is entirely different if the extraction is put in for a mix of reasons. But, on the basis of the original posting the extraction is there only for production reasons - enhanced worker protection is a free benefit in terms of both installation and whatever maintenance, inspection, testing etc is considered appropriate and the COSHH assessment can be framed to reflect this. 

However, what is probably more important is an Operations and Maintenance Manual for the equipment - for quality reasons.

stevedm  
#17 Posted : 17 June 2022 08:28:24(UTC)
Rank: Super forum user
stevedm

DSEAR - Cotton dust has an MIE of 25 - not that bad but still a problem.   

IanB I am surprised you didn't mention it ;) 

There is clearly a disjoint from production and safety here...and I see that the engineering change process working well as you had to walk onto site to find out..  :)  Few issues to solve not least the LEV... 

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