Personal experience from being a provider of SDS is that Sevron were very poor at document management as despite flagging multiple out of date documents from my company they were never taken down or updated.

Used Lycos then SDS / GHS Professional by Safeware Quasar (now part of Underwriters Laboratories who also own WERCS and MySDS) https://msc.ul.com/en/capabilities/hazard-communications/

Safety data sheets are not the definitive source of information for COSHH. Indeed, the latest issue of the ACoP for COSHH states:

Paragraph 10 - Employers should regard a substance as hazardous to health if it is hazardous in the form in which it may occur in the work activity. A substance hazardous to health need not be just a chemical compound, it can also include mixtures of compounds, micro-organisms or natural materials, such as flour, stone or wood dust.

My particular interest is in the risk assessment for skin exposure. There are literally thousands of chemicals that will not appear as skin hazards on safety data sheets (or not appear at all) but if contact with skin occurs can result in damage to health. Indeed, the most common cause of occupational irritant contact dermatitis is due to skin exposure to water (wet work and wearing of occlusive gloves). There are aver 4,900 chemicals listed as sensitisers by dermatologists, only a small fraction of which will have been classified as H317 and appear as such on a safety data sheet.

A COSHH risk assessment should be based on the real hazards arising when chemicals are used for a particular task and any skin exposure thereto. Therefore, the sequence of steps should be to define the task and all chemicals used therein, determine the hazard that arises from the chemicals as used and any actual or potential exposure thereto. I have yet to find any proprietary system that really achieves this.

Of course, if you are just seeking a system to record your findings, i.e. your completed risk assessment that is a different matter. 

15 minutes for a COSHH assessment? COSHH is not a front page item for a firm incorporated in April 2015 and claiming either 15 or 20 years experience depending where you look on their landing page.

Edited by user 20 November 2019 13:49:02(UTC)  | Reason: Typos

Personally I find it takes at least 15 minutes just to confirm the information from the material supplier is accurate and to current best available knowledge before commencing the assessment. So your comment that it could be done was interesting and warranted further investigation.

I cannot help the web site bearing contradictory information on the home page, nor that the COSHH tool you speak of is not prevalent - in what way is stating fact rude?

A lot of  previous attempts at COSHH software have merely regurgitated an input MSDS rather than providing a meaningful assessment.

Meantime I will protect my employer from a court deciding what is compliant by remembering any and all software is merely a tool and will never carry the duty holders legal responsibilities (as noted in the providers End User Licence Agreement).

ome years ago the HSE ran a project on preventing occupational skin disease. Quoting from this:

“HSE’s experience suggests that a large proportion of SDSs do not provide adequate or correct infrmation on hazards and exposure controls.” – from Topic Inspection Pack, Work Related Contact Dermatitis, Skin Disease Programme

Also a study by the European Chemicals Agency (ECHA), the organisation responsible for REACH, found that of 1,181 companies they inspected in 29 countries, mostly ‘downstream users’, i.e. formulators, regarding compliance with REACH, 52% were producing safety data sheets described in the study as ‘deficient’. ECHA – REACH-EN-FORCE2

Anton de Groots book on patch testing lists 4,900 chemicals known to dermatologists as skin sensitisers. Only a small percentage of these will have been assigned HS317 and will not appear as such on safety data sheets, assuming they appear at all.

The most common cause of occupational contact dermatitis is from excessive exposure to water (wet work). Incidentally, wearing occlusive (wateproof) gloves counts as wet work due to the hyperhydration and its effect on cells in the skin. I cannot remember when I last saw a safety data sheet for water.

As I have already posted on this forum, the current ACoP for COSHH states:

“Employers should regard a substance as hazardous to health if it is hazardous in the form in which it may occur in the work activity. A substance hazardous to health need not be just a chemical compound, it can also include mixtures of compounds, micro-organisms or natural materials, such as flour, stone or wood dust.” - COSHH ACoP (6th edition), para. 10

So one has to question whether relying on the safety data sheet is a gooc basis for a COSHH risk assessment.

Just a quick one on this - a company I used to work for used Sypol for all COSHH assessments. The HSE visited one day and were NOT happy that we were using software as opposed to a competent person carrying out the assessments. They strongly suggested we ditched it and went back to using internal documents and not just printing off pre-completed online forms.

Garbage In equals Garbage Out

I assume (perhaps a tifle optimistically?) that most on the forum are aware and have read the sixth edition of the ACoP for COSHH. For those who haven't take a look at what it says about chemical hazards.

In the U.K. the Approved Code of Practice (ACoP) for COSHH  Paragraph 10 states:“Employers should regard a substance as hazardous to health if it is hazardous in the form in which it may occur in the work activity. A substance hazardous to health need not be just a chemical compound, it can also include mixtures of compounds, micro-organisms or natural materials, such as flour, stone or wood dust."

So should we be surprised that some still view the safety data sheet as somehow sacrosanct as the source of information on chemical hazards? 

With COSHH many still continue to concentrate on the safety data sheet, despite their well documented shortcomings.

“HSE’s experience suggests that a large proportion of SDSs do not provide adequate or correct information on hazards and exposure controls.” – from Topic Inspection Pack, Work Related Contact Dermatitis, Skin Disease Programme

A study by the European Chemicals Agency (ECHA), the organisation responsible for REACH, found that of 1,181 companies they inspected in 29 countries, mostly ‘downstream users’, i.e. formulators, regarding compliance with REACH, 52% were producing safety data sheets described in the study as ‘deficient’. - ECHA – REACH-EN-FORCE2

What tends to be ignored is the provision of information required in the Health and Safety at Work etc. Act 1974:

Section 6-4 contains the following:

“It shall be the duty of any person who designs, manufactures, imports or supplies any substance for use at work:-

(c) to take such steps as are necessary to secure that there will be available in connection with the use of the substance at work adequate information about the results of any relevant tests which have been carried out on or in connection with the substance and about any conditions necessary to ensure that it will be safe and without risks to health when properly used.”

This year a supplier of chemicals was prosecuted for non-compliance with this requirement and fined £500,000!

Do you insist on section 6-4 information from your supplier?

In addition, for a COSHH assessment it is what the person carrying out the task is exposed to that matters. Since when using chemicals we almost always change them in some way which may result in a change in the hazard the risk assessment should be based on the hazard present during the task rather than that of the chemical when supplied.

Figures hot off the press from ECHA show non-compliance is still 44%

https://echa.europa.eu/-/44-of-hazardous-mixtures-not-compliant-with-classification-and-labelling-obligations

For mixtures 17% (one in five) were incorrectly classified whilst 33% (one in three) carried incorrect labelling

or as previously stated "Garbage In = Garbage Out"