Rank: Forum user 
|
On my COSHH Risk Assessments I take the substance ingredients which have WELs and transpose them on to the assessment. The thing is that for general workplace substances this level of information is, to be honest, of little or no use to anyone reading the assessment. I would like to remove some of that info and simlify the RA. For example, for a spray red oxide paint engineers may use to coat newly fabricated items the MSDS states for an 8hr TWA "dimethyl ether 766 mg/m3 / 400ppm" as a WEL. How would anyone know (as I said its in a general working environment) if that threshold is exceeded? I am quite happy to say that "the substance contains 'these' components for which there are WELs, and that by following the controls outlined in the RA it is unlikely that these limits will be exceeded". But how would I know that? Of course there will be occasions in other businesses where use of such substances is greater than a "quick 5 minute spray" so there is potential for exposure to increase and therefore get closer to the WEL. Has anyone got any thoughts regarding this? Do I take a pragmatic approach as I have suggested? And, essentially, would that stand up in court!!
|
|
|
|
|
|
Rank: Super forum user 
|
Originally Posted by: Davidfilce  How would anyone know (as I said its in a general working environment) if that threshold is exceeded? I am quite happy to say that "the substance contains 'these' components for which there are WELs, and that by following the controls outlined in the RA it is unlikely that these limits will be exceeded".
If you do not "know" the levels of exposure from substances in your processes how can you then claim to have suitable controls? The whole point of a COSHH assessment is to consider exposure and devise suitable controls to attempt to eliminate risk, not to merely just fly under a set point.
The whole point of the REACH regulation is to replace substances hazardous to human health and the environment - many common use substances will over time be banned from the workplace. What you should be examining through the COSHH process is actually displacing the dimethyl ether component - first principal control "eliminate". If that is not practicable you can look to engineering controls - dip tanks / spray booths / automatic application to segregate worker and work piece.
|
|
|
|
|
|
Rank: Super forum user
|
Originally Posted by: Davidfilce How would anyone know (as I said its in a general working environment) if that threshold is exceeded? I am quite happy to say that "the substance contains 'these' components for which there are WELs, and that by following the controls outlined in the RA it is unlikely that these limits will be exceeded".
If you do not "know" the levels of exposure from substances in your processes how can you then claim to have suitable controls? The whole point of a COSHH assessment is to consider exposure and devise suitable controls to attempt to eliminate risk, not to merely just fly under a set point.
The whole point of the REACH regulation is to replace substances hazardous to human health and the environment - many common use substances will over time be banned from the workplace. What you should be examining through the COSHH process is actually displacing the dimethyl ether component - first principal control "eliminate". If that is not practicable you can look to engineering controls - dip tanks / spray booths / automatic application to segregate worker and work piece.
|
|
|
|
|
|
Rank: Forum user
|
Thank you
This is not for substances which are used in great quantities. My point is for those substances, often off the shelf substances, which, when you examine the MSDS, identify components which have a WEL. Fairy washing up liquid for example, clearly and over the counter familiar product, has ethanol as an ingredient stated on their MSDS. This has a WEL of 1000 ppm (8hr TWA). The question is, at what level of usage is 1000ppm likely to be reached? It is a substance to which one can be exposed from washing one cup up at the end of the working day through to manufacturing thousands of gallons of the substance on a manufacturing site. somewhere within that range there is potential for the WEL to be reached. But at what point would you start to undertake measurements, and how?
Many household / familar products are used in buisness which have ingredients which have a WEL in EH40. Its trying to ascertain a defendable point at which measurement is or is not undertaken (apologies for the washing up liquid example, but it is a good one to illustrate the point I think).
The same will stand for all sorts of little used paints, sprays, pastes etc used in maintenance activities too. WD40 lubricant is a fine example too with 4 components with WELs, but as we know, we only iuse a quick spray on a sticky component. But somewhere between that and full-on manufacture there may be a point where we reach the WEL.
|
|
|
|
|
|
Rank: Super forum user 
|
Morning David, As an ex-aerosol development chemist (a long time ago) it will be difficult to eliminate DME if using an aerosol spray but relatively easy to substitute. DME is primarily the propellant in your spray, although it also has other attributes in this application. It is pretty easy to find red oxide primer spray that uses LPG (Butane/Propane mix) which will still have WELs but be less harmful than DME and also less of a static discharge risk*. Even better in COSHH terms would be to eliminate the spray propellant altogether and brush it on as a liquid but this may not suit your specific needs. *Not my finest hour but many moons ago I blew up an LEV system from a static discharge with DME. It was definately a learning experience once my ears had stopped ringing and I'd changed my trousers. DME has largely been phased out of aerosols but is still occasionally sued in heavy paint applications such as red oxide and galv spray.
|
|
|
|
|
|
Rank: Super forum user
|
Originally Posted by: Davidfilce Many household / familar products are used in buisness which have ingredients which have a WEL in EH40. Its trying to ascertain a defendable point at which measurement is or is not undertaken (apologies for the washing up liquid example, but it is a good one to illustrate the point I think).
Yes many substances in the home have a WEL - more substances though are being removed from supply to the general public and you need to remember that it is in the workplace where COSHH assessments are a regulatory requirement. Use would be classed as professional (as part of employment, including cleaners) or industrial (raw material use or manufacture).
Following your washing up liquid example in the home there is no mandated requirement to measure for ethanol - COSHH does not apply
At work your assessment would either describe the infrequent minimal professional use for cleaning dishes or monitoring and controls as part of an industrial process.
When you look at the SDS in addition to WEL in Section 8 are DNEL (Derived No Effect Level) which actually consider the different end users - Public, Industrial, Professional - often with different values by group.
Your red-oxide is in the workplace where I suspect you are not lashing around gallons of material but at the same time that can of aerosol does not spend months languishing in the stores - I would still be looking to alternatives.
|
|
|
|
|
|
Rank: Super forum user
|
Originally Posted by: Davidfilce Many household / familar products are used in buisness which have ingredients which have a WEL in EH40. Its trying to ascertain a defendable point at which measurement is or is not undertaken (apologies for the washing up liquid example, but it is a good one to illustrate the point I think).
Yes many substances in the home have a WEL - more substances though are being removed from supply to the general public and you need to remember that it is in the workplace where COSHH assessments are a regulatory requirement. Use would be classed as professional (as part of employment, including cleaners) or industrial (raw material use or manufacture).
Following your washing up liquid example in the home there is no mandated requirement to measure for ethanol - COSHH does not apply
At work your assessment would either describe the infrequent minimal professional use for cleaning dishes or monitoring and controls as part of an industrial process.
When you look at the SDS in addition to WEL in Section 8 are DNEL (Derived No Effect Level) which actually consider the different end users - Public, Industrial, Professional - often with different values by group.
Your red-oxide is in the workplace where I suspect you are not lashing around gallons of material but at the same time that can of aerosol does not spend months languishing in the stores - I would still be looking to alternatives.
|
|
|
|
|
|
Rank: Super forum user
|
A COSHH assessment is just another risk assessment. Finding out the WEL that associated with a substance is just step one of the hazard identification process. What you really need to do is establish the risk to your staff in your workplace. The WEL might be relevant, or it might not be relevant. The example that you gave of using a washing up liquid which contains trace amounts of ethanol, which has a WEL, is a fairly classic example of a case where the WEL is neither here nor there. As people have said, the aim of a risk assessment is to enable you to make a choice as to the most suitable controls, starting with eliminating hazardous substances. Its only when you are looking at airborne hazards and controlling them with LEVs or RPE that the WEL becomes really relevant. Just copying stuff from the SDS (Note it not be an MSDS for about 15 years) does not provide you with any useful information.
|
|
|
|
|
|
You cannot post new topics in this forum.
You cannot reply to topics in this forum.
You cannot delete your posts in this forum.
You cannot edit your posts in this forum.
You cannot create polls in this forum.
You cannot vote in polls in this forum.