coshh beyond clp - trident.uk.comfor_handout).pdf · coshh beyond clp by david osborn chartered...

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COSHH beyond CLP

byDavid Osborn

Chartered Occupational Safety and Health Practitioner

Presentation to

REACH / CLP Regulations – An Overview

Key changes for the COSHH Assessor

HSE views on COSHH Assessment - a “proportionate” approach

COSHH Essentials

‘Chemical Hazard Calculator ‘

Case study :

Using the 'calculator' in practice : One Company’s approach

Resources available to help COSHH Assessors

Programme

Registration, Evaluation, Authorisation and restriction of Chemicals 2007

• Targeting Substances of Very High Concern in particular

• Primarily aimed at Manufacturers/Suppliers of chemicals

• Some implications for Manufacturers of “articles” if >0.1% w/w SVHCs

• Set the scene for CLP

Classification, Labelling and Packaging (CLP) Regulation.

• Replaced our “CHIP” Regulations – revoked 1st June 2015

• Implemented the United Nations “Globally Harmonised System” (GHS)

• Revised structure of Safety Data Sheets / new hazard warning pictograms .





COSHH Essentials


Case study :



Programme

Key Changes for the COSHH Assessor

EU Symbols replaced by

“Globally Harmonised System”


EU Symbols replaced by “Globally Harmonised System”

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‘Risk Phrases’ become ‘Hazard Statements’


‘Safety Phrases’ become ‘Precautionary Statements’ e.g:

• S7 P233 : Keep container tightly closed

• S2 P102 : Keep out of the reach of children

Some Hazard Statements have alpha-suffix e.g.

• H350 : May cause cancer

• H350I : May cause cancer by inhalationwhen ‘conclusively proven that no other routes of entry cause the hazard’

• H360 : May impair fertility or damage the unborn child

• H360F : May impair fertility

• H360D : May cause damage to the unborn child

• H360FD: May impair fertility and damage the unborn child


And despite it being a “Globally Harmonised System”

The European Union has to “do its own thing” as well !

“EU Hazard Statements” e.g. :-



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CMR (Carcinogenic, Mutagenic, Reprotoxic)

• CHIP Category 1 CLP Category 1A (known to cause effect in humans)

• CHIP Category 2 CLP Category 1B (presumed to cause effect in humans)

• CHIP Category 3 CLP Category 2 (suspected of causing effect in humans)

STOT (Specific Target Organ Toxicity)

• Category 1 : Danger (Causes damage to organs in humans)

• Category 2 : Warning (May cause damage to organs in humans)

• Category 3 : Warning (May cause irritation, drowsiness etc)

Toxicity

• Categories 1 – 3 : Danger (1=Highest level of toxicity)

• Category 4 : Warning (4=Lowest level of toxicity)

Corrosive / Irritant to skin / eyes

• Categories 1A, 1B, 1C: Danger “causes damage” (1A=most dangerous)

• Category 2 : Warning “causes irritation”.

OLD FORMAT (CHIP) NEW FORMAT (CLP)

Changes to Structure of Safety Data Sheets

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Safety Data Sheet OLD FORMAT : (CHIP)

Section 15 summarises classification of ‘whole chemical’

(taking account of dilution factors)

Safety Data Sheet NEW FORMAT : (CLP)


Section 2 summarises classification of ‘whole chemical’

(taking account of dilution factors)


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Extended Safety Data-sheets / Exposure Scenarios

• Should be provided by manufacturer to “downstream user” if:

• A substance is registered under REACH; and

• Registrant manufactures (or imports) more than 10 tonnes / year; and

• Chemical safety assessment shows the substance to be hazardous

Exposure scenarios:

• Describe the registrant’s (manufacturer’s) recommended control measures for specific usage situations

• REACH Regulation places a legal duty on the user to ensure that these controls are in place within 12 months

• The 12 month period starts upon the user’s receipt of a safety data sheet which contains a REACH registration number and an appendix containing the scenarios

• It is the supplier’s duty to provide the SDS by physical transmission as hardcopy or electronic version. Just making SDS’s available on the internet for customers to fetch is not sufficient (or lawful).




COSHH Essentials


Case study :



Programme

HSE – “A proportionate approach”

HSE – “A proportionate approach” (COSHH ACoP)

HSE – “A proportionate approach” (HSG 97)




COSHH Essentials


Case study :



Programme

COSHH Essentials

COSHH Essentials

The Generic Risk Assessment

Health + exposure risk control

hazard potential assessment approach

COSHH Essentials

R45(May cause cancer)

Seek specialist adviceE

R40(Risk of irreversible effects)

<0.5 ppmD

R23(Toxic by inhalation)

>0.5 – 5 ppmC

R20(Harmful by inhalation)

>5 – 50 ppmB

R36(Irritating to eyes)

>50 – 500 ppmA

Risk phrase

examples

Target exposure rangeHazard

Group

COSHH Essentials – Determine Hazard Group

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COSHH Essentials – Determine Hazard Group

Yet we saw : -

H304 – May be fatal if swallowed and enter airways

– Equates to “Group A” (Least hazardous)

How can this be ???

Answer: Because COSHH Essentials is primarily

focused on airborne substances i.e. not ingestion




COSHH Essentials


Case study :



Programme

A spreadsheet, based around similar principles to COSHH Essentials

But includes:

• Some phrases / statements that HSE don’t consider (e.g. toxic gas effusion)

• Fire, explosion and cryogenic hazards

• Environmental Hazards

Caters for all routes of entry (including ingestion)

Initial stages of a COSHH assessment can become a ‘desktop’ exercise

Then, based upon the level of hazard, further assessment can be:

• Proportionate (in terms of depth, detail, time and trouble)

• Carried out at an appropriate level of competency e.g.

• General Risk Assessor vs safety practitioner / chemical specialist

A “Chemical Hazard Calculator”

A “Chemical Hazard Calculator”




COSHH Essentials


Case study : Using the 'calculator' in practice

One Company’s approach


Programme

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HSE – “A proportionate approach” (COSHH ACoP)

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In its simplest form , the calculator can be used to classify hazard as

HIGH , MEDIUM , LOW

Case Study : XXX Ltd

Arrangements for COSHH consist of :-

• Procedure Document, with associated “Process Map”

• Spreadsheet “calculator” to determine chemical hazard rating and associated work instruction

• COSHH risk assessment template for “high risk” chemicals and processes involving more than one chemical

• COSHH “pro-forma” risk assessment template for “medium risk” chemicals

• COSHH ‘Info Card’ - for all chemicals (High, Medium and Low risk)

• Generic Risk Assessment for “Low risk” chemicals .


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COSHH Procedure : Definition of ‘Hazard Rating’

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<<< Check Highly Flam

and Flam = Medium

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Case Study :

XXX Ltd

COSHH Process Map

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Process Map:

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Process Map:

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Requirements of the COSHH Regulation 6(2)

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Detailed

COSHH

Assessment

Template

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Medium Risk

“Pro-Forma”

COSHH

Assessment

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Sections 1 - 4

Medium Risk

“Pro-Forma”

COSHH

Assessment

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Sections 5 - 9

Medium Risk

“Pro-Forma”

COSHH

Assessment

Section 10

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COSHH Info-Card (Printed A5, double-sided, Laminated)

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COSHH Essentials


Case study :



Programme

The following will shortly be available via a single link at the SOHSA website http://www.sohsa.co.uk/ :-

A sheet of handy links to web pages (e.g. ECHA/HSE)

This presentation, as PDF file

The “chemical hazard calculator” spreadsheet

Generic “Good practice working with chemicals”

Some of the documents you have seen :-By kind permission of Mr Richard Cross, Director, Cross Manufacturing Company (1938) Ltd

• Process Flow diagram

• COSHH Assessment Templates (.doc format for further editing):

• “High risk chemicals” : Report headings

• “Medium Risk chemicals” : Pro-Forma (with hazard pictograms etc)

• COSHH “Info-card” template (for A5 printing / laminating).

Resources for COSHH Assessors

http://www.sohsa.co.uk/

A Final (but important) Point

The “Chemical Hazard Calculator”:

Helps you get started with a COSHH assessment

Can make the initial stages a “desktop” exercise which could be

carried out by an administrator with minimal training

But always remember the ‘golden rule’ about COSHH Assessment

from the HSE publication HSG 97 :

COSHH is not a bureaucratic exercise.

It is about making sure things are done to reduce pain and

suffering caused by ill health.

So it’s not just about taking a safety data sheet, using a

‘calculator’, filling in forms / info-cards etc at the desktop

No risk assessment (COSHH or otherwise) can be done

without a person with sufficient knowledge and expertise

going and looking at the way chemicals are used ‘on the

shop-floor’, talking to the folk who use them and “exercising

the ‘little grey cells’…”

coshh beyond clp - trident.uk.comfor_handout).pdf · coshh beyond clp by david osborn chartered...

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