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Posted By Martin Williams
One thing that frequently frustrates me when trying to complete COSHH assessmsnts on impoted substances is the apparently inadequate information supplied by the vendor. I often find that Material Safety Data Sheets (MSDSs) supplied with substances do not contain sufficient information.
I have recently come across a substance manufactured in the US, but sold by a UK distriubutor, on which the label stated that it contained a chemical that caused cancer, but this was not reflected in the MSDS. How can our assessment be adequate in such circumstances.
Surely there should be an obligation on UK distributors of such substances to provide MSDSs which provide all the information (including R phrases) required for a suitable and sufficient COSHH assessment of substances.
I would be grateful to hear other member's views and experiences of this.
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Posted By Adrian Watson
Dear Martin,
There is a duty on anybody, under s 6 of the HSWA 74, who designs, manufacures, imports or supplys, any article for use at work to ensure people are supplied with adequate information.
CHIP 94, as amended, supplements this requirement and specifies the format and the types of information that must be supplied.
Hope this helps.
Regards Adrian Watson
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Posted By Steve
Dar Martin,
Under CHIP, the UK distributor has the legal responsibility to produce an MSDS and also affix suitable and appropriate labels to the product. If like you say the MSDS & labeling do not correspond I should inform your supplyier at once, noting the discrepancies, at the same time pointing out their legal duties under CHIP.
Hope this helps
Steve
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Posted By John D Crosby
Martin
It is possible that an MSDS complying with CHIP etc may not mention cancer if the material comes from the USA. This is because any product sold in the State of California which has the slighest chance of causing cancer has to be labelled as a cancer producing agent. Bottles/cans of beer are labelled in this way because they contain alcohol. We even had a petrol driven machine from the USA that had a label on that indicated that its use could cause cancer. Failure to label in California leads to exceptionally high fines.
Cheers
John C
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Posted By Martin Williams
Thanks to all who replied.
In particular John Crosby, I have just had a similar reply from our parent company in Los Angeles. It does appear that in order to satisfy the labelling requirements of the state of California (California Proposition 65),American imported chemicals are labelled with references to any cancer-causing agents that they may contain, even if you would have to be exposed to massive amounts before causing cancer.
I would be interested to hear how bottled mineral water from California would be labelled under Proposition 65!
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