Working within pathology where we carry out processing of histopathology samples preserved in 10% formalin. Main exposure to formaldehyde vapours is during tissue cut up on downflow benches. Under COSHH, exposure to formaldehyde (carcinogen) must be ALARP. UK WEL is 2ppm. EU CMD (UK signed up to prior to Brexit) assigned a transitional OEL of 0.5ppm in healthcare from July 2021. I have proposed that we should maintain exposure to below 0.5ppm. We monitor exposure using passive diffusion badges and air sampling using PPM Formaldemeter. I'm finding it difficult to demonstrate exposure ALARP and to below 0.5ppm.

Questions:

1. Is anyone aware of the UK/GB adopting the EU CMD transitional arrangements following Brexit?

2. What monitoring is used to measure personal exposure and how are you demonstrating exposure is ALARP?

3. Has anyone else adopted the 0.5ppm exposure limit in their lab?

Thanks

Thanks for your reply Peter.

The link provided is to EU legislation and does not demonstrate that it has been transposed into UK law, irrespective of what was signed up to prior to Brexit. Your statement regarding the funeral sector also applies to healthcare with a transition period OEL of 0.5ppm.

Yes, there will be/is difficulty in attaining 8hr TWA limits of 0.5ppm, let alone 0.3ppm, in histopathology labs and mortuaries.

Concerns on this matter have been highlighted greatly over the past 2 years but there doesn't seem to be many answers. We've been working on this for over a year but need to be able to demonstrate our 'ALARP'. Amongst other controls, we're looking at time limits for staff working in the cut up lab but this will result in more people being exposed, contradicting one of the requirements of COSHH.

Another issue, not confined to healthcare, is trying to get employers to appreciate ALARP. Many see WELs as 'targets' and 'if the WEL for formaldehyde is currently 2ppm and exposures are under this, then what's the problem?'!

This is one of those specific questions lost in the morrass of disengaging from forty years of EU regulation.

https://osha.europa.eu/en/legislation/directive/directive-200437ec-carcinogens-or-mutagens-work

Member States have to comply with the mid-2019 amendments by 11th July 2021. A transitional higher limit value for formaldehyde shall apply in the health care, funeral and embalming sectors until 11th July 2024.

I would guess, like me, you are going to have to wait for the later editions of EH40 - its last publication 17th January 2020 adopting the 2017 ammendments such as Hardwood dusts

You mention the N.I. protocol - I do not see separate entries for Northern Ireland in the GESTIS database.

https://www.hseni.gov.uk/news/publication-new-workplace-exposure-limits

Indicates the NI are following UK EH40.

the Eu medicaines agency has for this and othre products always treated Northern Ireland as separate to the Uk and the Eu standard has been applied, certainly from my knowledge, for over the last 10 years....in my assessments I have always included NI with Ireland/EU despite the polictical boundaries...I am not going to get into Brexit as I think most of us working in the field apply the best standard available to ensure the protection of our people...so our IH standard for that product used the EU standard across all sites including those in the UK.

Originally Posted by: CRIOGES

Barroness Crawley will be putting a question to HMG on the matter of the EU legislation on Carcinogens.

Could you please provide actual published regulation to support your assertion that formaldehyde is mentioned in the N.I. Protocol.

Originally Posted by: CRIOGES

In Labratories we can help with this if anyone does want assitance

Not really surprised to find there is a commercial enterprise with exactly the same name as its logo.

Originally Posted by: Roundtuit

Originally Posted by: CRIOGES

In Labratories we can help with this if anyone does want assitance

Not really surprised to find there is a commercial enterprise with exactly the same name as its logo.

I am not trying to hide that fact. Not sure what the issue is with this either? As a professional forum id expect everyone on here to be part of a commercial operation or at least self employed in this area. H&S would be a weird hobby. 

I offered to see if i can help resolve the issue. Im also personally involved with members of the House of Lords trying to get some clarity on the mess that is EU legislation that was due to be implemented. 

With regards to N.I i am only repeating what was told to me by that member of the house. the NI Protocol is a mess for a number of reasons which is why they are trying to reform it. 

Originally Posted by: CRIOGES

Originally Posted by: Roundtuit

Not really surprised to find there is a commercial enterprise with exactly the same name as its logo.

I am not trying to hide that fact.

Perhaps you would care to visit the forum rules, in particular rule 8. Advertising of jobs, goods or services for commercial gain is not allowed.

or even rule 11. Your registered screen name and avatars must not contain website or email address details, the name, or identifiable abbreviation of, an organisation, company, contact or location information, expletives, obscenities, religious statements or other potentially contentious terminology.

Originally Posted by: Roundtuit

Originally Posted by: CRIOGES

Originally Posted by: Roundtuit

Not really surprised to find there is a commercial enterprise with exactly the same name as its logo.

I am not trying to hide that fact.

Perhaps you would care to visit the forum rules, in particular rule 8. Advertising of jobs, goods or services for commercial gain is not allowed.

Well if you want to get pedantic about it i offered help on the subject and not services. 

Maybe we would all be better off if more focus was put on actually resolving these problems and we could start reducing the 8,000 occupational cancer deaths there are in the UK each year. We currently have the worst carcingenic protection laws in the western world right now. Thats why the HSE spends most of its time policing the 200 accidental deaths at work rather than the 8,000 cancer deaths which happen years after someone leaves that employment and as for the CQC who regulate healthcare ive never seen them do much in the way of worker protection at all. A bit like the police they are all great at cleaning up the mess once you are dead.