Rank: Forum user 
|
In a lab at work whilst auditing our COSHH cabinets I have found that out of x41 substances on one shelf, only one of them was compliant to the standard I would expect:
In date, in a proper container with a lid, clearly labelled, CLP hazard warning pictograms, substance on the inventory sheet, suitable SDS present or easily available on computerised system, suitable COSHH RA readily available, segregation of non-compatible substances, bunding and ventilation where required/expected, spill kits (correct size and type) in the vicinity etc. I'm in the process of improving all of these non-conformances but have had some mild push-back. 1- Some products in R&D are no longer manufactured and the expired products are used infrequently to compare performance against replacement products. 2- Some expired products (e.g. solvents; acetone and IPA) are no longer used for lab testing but are still kept on site as they are used in cleaning activities.
My understanding of COSHH and GLP prevents any expired products being used or stored in labs. This is an accredited lab so I would expect a higher standard than what I'm seeing. Is there any reason expired products can/could be kept? What mitigation/documentation to excuse these expired products might be suitable? I would have thought any third-party auditor would pick-up on expired COSHH products and no matter the excuse would mark us down as non-conforming? If there is an allowance for this? can someone sign-post me of the appropriate method? Would putting them in a dedicated COSHH cupboard for expired products be suitable? Thanks in advance for your input.
|
|
|
|
|
|
Rank: Forum user 
|
Hi, Unaware of anything to prevent expired chemicals being stored or used, other than those that degrade (no good for anything) or the risk of peroxides forming - IPA has the potential to form peroxides. I would still use the older chemicals for cleaning, and if needed put a deviation permit in place for that use, and as mentioned a dedicated cabinet wouldnt go a miss so there is no risk of being used in a controlled process. An external or even internal auditor should have picked up this, and raised a non conformance which would need following up and justification for keeping it on site - at least that's what I am used to. Edited by user 04 September 2024 15:50:59(UTC)
| Reason: added information
|
|
|
|
|
|
Rank: Super forum user 
|
Where in COSHH does it discuss the age of chemical reagents? Most sell by / use by / best before dates are applied to protect the manufacturer from claim whilst in practice the product could be used for months or years where appropriately stored. For truly analytical reagents there is a case to ensure they remain effective however in a lot of systems there is scope to make a determination on the day of the relative strength / efficacy of the material before use and adjust any subsequent calculations. Out of interest why are you asking the forum rather than talking with the people who should know what they are doing - laboratory manager or R&D lead?
|
|
|
|
|
|
Rank: Super forum user
|
Where in COSHH does it discuss the age of chemical reagents? Most sell by / use by / best before dates are applied to protect the manufacturer from claim whilst in practice the product could be used for months or years where appropriately stored. For truly analytical reagents there is a case to ensure they remain effective however in a lot of systems there is scope to make a determination on the day of the relative strength / efficacy of the material before use and adjust any subsequent calculations. Out of interest why are you asking the forum rather than talking with the people who should know what they are doing - laboratory manager or R&D lead?
|
|
|
|
|
|
Rank: Forum user
|
Well COSHH 2002 doesn't have a section on expired products, but Regulation 9 (Maintenance, examination, and testing of control measures) includes the maintenance and inspection of control measures like storage, labeling, and monitoring substances. This surely extends to ensuring substances are in-date and suitable for use? Also, HSG 71 – Storage of packaged dangerous substances guidance recommends ensuring chemicals are stored according to manufacturer instructions, which includes monitoring expiry dates. It also advises checking for degradation or changes in properties over time, which could affect their safe use. HSG 193 – COSHH Essentials in Laboratories covers the safe handling of chemicals in laboratory settings including managing the lifecycle of chemicals: disposal of expired or deteriorated substances, to prevent risks associated with unsafe use. I was basing my assumption that expired COSHH substances should not be stored in labs by my understanding of GLP; Chapter 6; Test and Reference; implicitly includes ensuring chamicals are used within their shelf-life and have not degraded. Chaper 10 (SOP's) 'must ensure chemicals are not used beyond their expiry date. I remember a lab I was responsible for being audited by the FDA for a new product launch in America and they marked us down for a reagent that had expired only the day before, possibly triggering this belief that expired products shouldn't be in accredited labs. If it's just a best practice rather than set in stone rule I'll relax then and try and control the other COSHH issues rather than the low hanging fruit of expired chemicals.
|
|
|
|
|
|
Rank: Super forum user
|
COSHH has nothing to say on “expired” products. Its solely about safety. As for as being compliant with standards this depends on what sort of lab you are working in. in many labs there is no practical expiry date. I know of labs where they are happy using reagents from the 1970’s! The GLP(good Laboratory Practice) standard used to standardise procedures and practices in nonclinical studies to ensure accurate, reliable, and traceable data. If you have a container of reagent in a lab and everybody has access to it, you cannot be certain that is has not been contaminated by some careless worker. Reagents tend to be assigned to a particular user or users to be used on a particular project. Typically it is discarded after a period of time, when you can no longer guarantee its purity. This does not mean it is always disposed of, often it is donated to a lab where guaranteed purity is less of an issue. One safety issue with old chemicals is that the plastic containers degrade ( it probably takes 20 years but some people hold onto reagents that long) . We had a clear out in a lab and one of the containers just disintegrated. Fortunately the reagent wasn’t particularly hazardous but still a pain to clear up. Edited by user 05 September 2024 13:19:43(UTC)
| Reason: old but not the 11th century
|
|
|
|
|
|
Rank: Super forum user
|
Originally Posted by: A Kurdziel  some people hold onto reagents that long
One of my first tasks at the introduction of COSHH all those decades ago was to inventory the site laboratory chemicals including the flammable cabinet. Many reagents were in glass stoppered containers with hand written labels that had either faded due to time and fume or fell from the bottle as their adhesive had given up.
|
|
|
|
|
|
Rank: Super forum user
|
Originally Posted by: A Kurdziel some people hold onto reagents that long
One of my first tasks at the introduction of COSHH all those decades ago was to inventory the site laboratory chemicals including the flammable cabinet. Many reagents were in glass stoppered containers with hand written labels that had either faded due to time and fume or fell from the bottle as their adhesive had given up.
|
|
|
|
|
|
Rank: Forum user
|
Originally Posted by: A Kurdziel One safety issue with old chemicals is that the plastic containers degrade ( it probably takes 20 years but some people hold onto reagents that long) . We had a clear out in a lab and one of the containers just disintegrated. Fortunately the reagent wasn’t particularly hazardous but still a pain to clear up.
Oh yes, Of the x41 substances reviewed yesterday x5 of them were in completely corroded bottles with no labels on them at all! Fair enough I'll focus on the safety rather than the lab standard and quality aspects. Thanks
|
|
|
|
|
|
Rank: Super forum user 
|
I'd like to add that there can be two kinds of safety issues with some expired chemicals. One is that some chemicals can degrade in a way that affects their reactivity so that they can either spontaneously and explosively go off, or that when they are mixed with other chemicals or used in a process they react in an unanticipated way. The other is that if you have something like a resin or adhesive that is going to be used in a safety-critical application, expired products can be more likely to form incorrectly after application in a way that can make the end product unsafe in service (depending on what that service is).
But as others have said, in the vast majority of cases, expired chemicals are at most a quality issue and not a safety issue. Very often, they are not even a quality issue (depending on what they are and what they are being used for). Expiry dates are nearly always set for quality reasons rather than safety reasons and even the quality reasons don't always apply.
With adhesives and so on, I've generally been a proponent of marking the expired ones as "EXPIRED - for training use only" in exactly the way I would for expired first aid dressings.
|
 2 users thanked Kate for this useful post.
|
|
|
|
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.