I am compiling a COSHH RA for a process involving 3 substances. I know a COSHH RA is an assessment of the full spectrum of using the substance in the work place and not about the substance in isolation. 

The MSDS only lists one Haz Statement under Section 2 for H319 (Eye irritation) but when you look at Section 3 (ingredients) there are many other H statements such as for toxicity. 

I am unclear what to include in the COSHH RA where it asks me to list "hazardous properties of the substance". I assume the other H statements are not included for the substance in Section 2 because the quantities are very small. The likely use and exposure scenario in our case would also be very limited. I am therefore thinking of just including H319 as the hazard. But then the H statements (health related only - not fire etc) may have potential impacts. What is the usual course of action in this scenario? 

I agree with Kate, you've done this correctly. I only include the SDS section 2's in the COSHH Assessments, unless other aspects of the assessment require me to include section 3's.

Exposure limits TWA / STEL / DNEL / PNEC are listed (usually for the component substances) in Section 8.

The SDS describes the properties of the "As Received" substance or mixture with Section 2 containing the applicable labelling. Abstracting data from several Section 2 will not necessarily represent the hazard within your process as each component added will dilute others potentially reducing hazard or react to create additional unspecified hazard or neutralise each other.

The current standard for writing SDS EU 2020/878 requires additional information in Section 3 including  Specific Concentration Limits which impact the hazard classification applied to the Section 3 substance.

You also need to be very careful that not every SDS has the most current information (latest to enter force ATP 16 EU 2021/643 - 23/02/2022 and ATP 15 EU 2020/1182 - 01/03/2022 many are yet to address the re-classification of Titanium Dioxide as Carcinogen 2 under ATP 14 EU 2020/217 - 1/10/2021).

Missing these rules can mean serious omission in the necessary labelling information which is why Section 3 becomes important to verify the component substance information is accurate otherwise the classification is fundamentally flawed.

Originally Posted by: Roundtuit

Exposure limits TWA / STEL / DNEL / PNEC are listed (usually for the component substances) in Section 8.

The SDS describes the properties of the "As Received" substance or mixture with Section 2 containing the applicable labelling. Abstracting data from several Section 2 will not necessarily represent the hazard within your process as each component added will dilute others potentially reducing hazard or react to create additional unspecified hazard or neutralise each other.

The current standard for writing SDS EU 2020/878 requires additional information in Section 3 including  Specific Concentration Limits which impact the hazard classification applied to the Section 3 substance.

You also need to be very careful that not every SDS has the most current information (latest to enter force ATP 16 EU 2021/643 - 23/02/2022 and ATP 15 EU 2020/1182 - 01/03/2022 many are yet to address the re-classification of Titanium Dioxide as Carcinogen 2 under ATP 14 EU 2020/217 - 1/10/2021).

Missing these rules can mean serious omission in the necessary labelling information which is why Section 3 becomes important to verify the component substance information is accurate otherwise the classification is fundamentally flawed.

Roundtuit, bit of a coincidence but one of the other processes I am reviewing has an updated substance MSDS classifying the ingredient Titanium Dioxide as a carinogen just as you mention! Although not included under section 2 hazards for the substance I have included a note in the COSHH RA highlighting this as a potential hazard if the substance is allowed to mist. Very unlikely in our use scenario but I think worth mentioning.