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Prepared by the Health and Safety Laboratory for the Health and Safety Executive 2013
Health and Safety Executive
Assessment of exposure to carcinogens and asthmagens in the contract import, processing and repackaging industries
RR983Research Report
Joan Cooke Health and Safety LaboratoryHarpur HillBuxtonDerbyshire SK17 9JN
The aim of this research was to assess the effectiveness of exposure controls at small and medium-sized enterprises (SMEs) carrying out the import, reprocessing and repackaging of chemical carcinogens and asthmagens.
Visits were made to 10 companies which decant and repack chemicals including carcinogens and asthmagens. The visits examined handling practices and exposure controls, and included, where possible, a quantitative exposure assessment, either by biological monitoring or air sampling.
Although there were some examples of good practice, overall, this survey found that control of exposure was variable in its effectiveness. Deficiencies in COSHH assessments (Control of Substances Hazardous to Health) and/or inadequacies in engineering controls (LEV - Local Exhaust Ventilation) and/or PPE (Personal Protective Equipment) were found at all but one site visited.
Recommendations for improvements to management systems and/or exposure control were made for all but one site. Recommendations included the need to improve LEV systems; to introduce health surveillance programmes; and to improve PPE programmes, including ensuring the introduction of fit testing for Respiratory Protective Equipment (RPE), undertaking routine RPE maintenance and ensuring correct glove selection.
This report and the work it describes were funded by the Health and Safety Executive (HSE). Its contents, including any opinions and/or conclusions expressed, are those of the authors alone and do not necessarily reflect HSE policy.
Assessment of exposure to carcinogens and asthmagens in the contract import, processing and repackaging industries
HSE Books
Health and Safety Executive
© Crown copyright 2013
First published 2013
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Acknowledgements
HSL wish to thank the Chemical Business Association (CBA) for their assistance in the early stages of this work, the ten companies that provided access to their premises and all the individuals who participated in the sampling exercises. Thanks are also given to HSL’s Analytical Sciences Unit who analysed all the samples collected.
ii
iii
KEY MESSAGES
The Chemical Business Association (CBA) provided a listing of some 15 companies actively
involved in the import and supply of chemical carcinogens and asthmagens. When contacted
three of companies advised that although they imported such chemicals, they did not in fact
break open any containers. They advised that the chemicals were sold on to end users in the
manufacturers’ containers without decanting and repackaging.
In total, ten companies were visited as part of this survey. Exposure control standards were
highest at the only top tier COMAH site visited. Poor management systems and / or control at
source were observed at the other sites. These were a mixture of lower tier, sub, and non
COMAH sites. This supports a conclusion drawn from a previous survey JS2002998 (‘A
workplace survey on the control of task specific exposures to carcinogens, mutagens and
reprotoxins in the UK chemical industry’), that in general, standards of exposure control were
higher at top tier COMAH sites than at lower tier sites, which in turn were higher than the few
sub-COMAH sites visited.
The potential for liquid dyes containing the azo compounds CI Solvent Red 164 and 24 to
metabolise within the body to ortho-toluidine or aniline was investigated also. Aniline only was
detected, and then, in only 3 of 47 samples at levels significantly below the relevant guidance
value.
iv
EXECUTIVE SUMMARY
Introduction
The chemical industry in the UK comprises businesses of a range of sizes. The larger
organisations are members of the Chemical Industries Association (CIA) and they handle
approximately 80% of the UK chemical business but employ only 20% of UK chemical workers
(these figures came from an informal discussion with the Chemical Business Association -
CBA). This industry sub sector was surveyed in 2005 (JS2002998 ‘A workplace survey on the
control of task specific exposures to carcinogens, mutagens and reprotoxins in the UK chemical
industry’) and the findings reported in HSL report HSL/2005/35[1]
.
The purpose of this project was to survey small and medium sized enterprises (SMEs), many of
who are members of the CBA. This industry sub sector handles 20% of UK chemical business
but employs 80% of UK chemical workers (again these figures came from an informal
discussion with the CBA). The aim was to assess the effectiveness of exposure controls at those
SMEs carrying out the import, reprocessing and repackaging of chemical carcinogens and
asthmagens. The objectives of the work were:
i) To engage with relevant internal and external stakeholders and assemble a schedule
of workplaces, representative of this industry sector, to be visited. Stakeholders
included HSE’s Hazardous Installations Directorate (HID) and the CBA. The CBA
provided valuable assistance by liaising with members to secure agreement to
support this project.
ii) To visit up to 30 workplaces and assess handling practices and exposure controls
for carcinogens and/or asthmagens. The assessment methodology included (where
possible) a quantitative exposure assessment, either by biological monitoring or air
sampling.
iii) To analyse the findings and compile a final report to compare and contrast with the
findings from JS2002998. If appropriate, the report findings may also be used to
inform possible future work by HSE or industry relating to exposure control at the
import, reprocessing and repackaging of chemical carcinogens and asthmagens.
Methodology
A listing of some 15 companies was provided by the CBA and a further seven companies were
sourced from other surveys (the earlier task specific exposure survey mentioned above and one
looking at exposures in the surface engineering industry). Four formulators of the azo dye CI
Solvent Red 164 were approached following concerns that this substance can metabolise within
the body to ortho toluidine and aniline. A programme of cold calling was also undertaken.
Of those contacted, ten businesses, described below and identified as sites A - J, indicated they
decant and repack and agreed to assist this survey.
Sites A, B, C and D are formulators of dye penetrant solution reported as containing the azo dye
CI Solvent Red 164. Site C also supply a diesel marker concentrate containing the azo dye CI
Solvent Red 24.
Site E take delivery of a concentrated solution of hydrazine hydrate (hydrazine is a carcinogen)
and dilute it before selling on to end users.
v
Site F manufacture potassium chromate solution using chromic acid flake. This and the
resulting potassium chromate solution contain chromium in its hexavalent state (a known
carcinogen and respiratory sensitiser).
Sites G and H manufacture nickel solutions for the electroplating industry using solid nickel
sulphate. Nickel sulphate is a carcinogen and also a respiratory sensitiser.
Site I uses azodicarbonamide (ADC) in the production of blowing agents for flooring material.
ADC is a respiratory sensitiser.
Site J receive bulk deliveries of trichloroethylene (a carcinogen), transfer to bulk storage and
then utilise an automated closed loop filling system to decant and repackage chlorinated
solvents, to be sold on for use as vapour cleaning/degreasing agents.
A HSL occupational hygienist visited all the sites (accompanied at some by a HSE inspector)
and assessed work practices and exposure controls. Quantitative exposure measurements were
carried out using (where applicable) either air sampling and/or biological monitoring. A full
occupational hygiene report was then written and fed back to the company via the site inspector.
Main findings
Local exhaust ventilation (LEV) systems were present at all four sites, however improvements
were required. Personal Protective Equipment (PPE) consisted of protective gloves (worn at all
sites), coveralls worn at sites A and C, and Respiratory Protective Equipment (RPE) worn at
sites B and C. At sites B and D the workers were not provided with coveralls but instead wore
their own normal clothing.
Improvements had been made to the process at site E since a previous visit made to the site (not
as part of this project) by HSE. At the time of the previous visit, the company relied on PPE to
control exposure to the chemical handled (hydrazine). By the time of this project visit, the
hydrazine was handled remotely using a sealed transfer system and a computer controlled filling
station, thus achieving almost total containment.
At site F chromic acid flake was manually added to a caustic solution. The resulting solution
was then manually decanted by gravity feed through a flexible hose into containers for onward
despatch. Biological monitoring and air sampling was carried out to assess exposure to
chromium. Inhalation exposures to total chromium and hexavalent chromium were less than the
UK Workplace Exposure Limit (WEL) of 0.5 mg/m3 and 0.05 mg/m
3 respectively. One
worker’s urinary chromium concentration exceeded the UK Biological Monitoring Guidance
Value (BMGV). Control measures included LEV and PPE. The PPE worn consisted of chemical
protective suit, gloves and RPE.
Sites G and H mixed nickel sulphate crystals with other substances to make an electroplating
solution. At site G, the nickel sulphate was placed into a grinder to break down any large lumps
prior to mixing. Once mixed the solution was dispensed into containers for delivery. Biological
monitoring and air sampling were carried out to assess exposure to nickel. Air sampling for
exposure to TID was also carried out. Inhalation exposures to TID at both sites were less than
the COSHH exposure limit of 10 mg/m3. Exposures to nickel were also less than the WEL of
0.1 mg/m3. Inhalation exposures to TID and Ni at site H were all in fact less than the limits of
detection for the analytical methods (<0.02 mg/m3 and <0.001 mg/m
3 respectively) as 8-hr time
weighted averages. Urinary concentrations of nickel at site G were all within the range for those
with no occupational exposure (<10 µmol/mol creatinine). At site H, one urinary nickel
exceeded the standard that HSL adopted for this survey, but was lower than the German value.
vi
Control measures at both sites G and H consisted of LEV and PPE. The LEV was located at the
mixing vessels at both sites. PPE consisted of overalls and disposable gloves. RPE was worn at
site H.
At site I, bags of powdered ADC were manually emptied into a mixing vessel. Air sampling
was carried out for exposure to TID and ADC. The 8-hr TWA inhalation exposures were 4.6
mg/m3 and 2.8 mg/m
3 respectively. The exposure to ADC exceeded the WEL of 1 mg/m
3 by
almost three times. LEV was provided but deficiencies in its design meant that control was not
achieved at source. Battery powered RPE was worn by the operator carrying out the work.
At site J, trichloroethylene was handled in a closed loop system, with minimal worker contact.
Both air sampling and biological monitoring were carried out. Inhalation exposures were
significantly less than the UK WEL of 100 ppm. Urinary concentrations of trichloroacetic acid
(the urinary marker for trichloroethylene) were significantly less than the UK BMGV of 35
mmol/mol creatinine.
Urine samples were received from sites A through to D after work was carried out with liquid
dyes containing the azo compound CI Solvent Red 164. The samples were analysed for ortho
toluidine and aniline in response to concerns regarding the potential metabolisation to these
substances within the body. The majority of the results for ortho toluidine were at the non-
detected level (<0.4 µmol/mol creatinine). Measurable concentrations ranged from 0.4 to 2
µmol/mol creatinine, all of which were within the range for those with no occupational exposure
(up to 5µmol/mol creatinine). The majority of the aniline concentrations were within the range
for those with no occupational exposure (up to 10µmol/mol creatinine). One result was at this
value and two exceeded it, however the latter two should be treated with caution as they were
analysed after significant dilution due to low sample volume. However all results were
significantly less than the German Guidance Value [2]
. These findings were reported to the HSE
Working Group on Action to Control Chemicals (WATCH) in October 2011[3]
.
Urine samples were also received from site C after work with CI Solvent Red 24. All urinary
concentrations of ortho toluidine were at the non-detected level and none of the aniline
concentrations exceeded the reference range for those with no occupational exposure. This dye
is used in powder form, thus there is the potential for inhalation exposure. Air sampling for total
inhalable dust (TID) was carried out. The 8-hr time weighted average (8-hr TWA) exposure was
3.3 mg/m3 with the task based exposure being 21.5 mg/m
3 (over a sampling period of 73
minutes).
Recommendations
Recommendations for improvements to management systems and / or exposure control were
made to all sites apart from site E where none were required. These are summarised below:
o Improvements / reviews of COSHH assessments
o Carry out improvements to LEV systems; this included re-designing systems to offer better
control at source
o Compare future LEV through examination and test (TExT) reports to HSE guidance in
order to ascertain whether the report is comprehensive enough
o Introduce, where applicable, a programme of health surveillance when using asthmagens
o Improvements to PPE programmes including face fit testing, RPE maintenance and correct
glove selections.
CONTENTS PAGE
1. INTRODUCTION ....................................................................... 1
1.1 Project background 1
1.2 Overview of use of each substance 2
1.3 UK Regulatory position for each substance 3
2. METHODOLOGY ...................................................................... 5
2.1 The design of the study 5
2.2 Analysis details 5
3. RESULTS ................................................................................. 7
3.1 Formulators of CI Solvent Red 164 (A – D) and 24 (c) – as reported 7
3.2 Hydrazine Supplier – Site E 9
3.3 Potassium chromate producer – Site F 10
3.4 Nickel plating salts producer – Sites G and H 11
3.5 Producer of blowing agent for flooring material containing ADC – Site I 12
3.6 Repackaging of trichloroethylene into closed loop systems – Site J 13
4. DISCUSSION .......................................................................... 15
4.1 CI Solvent Red 164 and 24 15
4.2 Hydrazine 15
4.3 Potassium chromate 15
4.4 Nickel plating salts 16
4.5 ADC 16
4.6 Trichloroethylene 16
4.7 Common themes 16
5. CONCLUSIONS ...................................................................... 18
6. RECOMMENDATIONS ........................................................... 19
7. REFERENCES ........................................................................ 20
1
1. INTRODUCTION
1.1 PROJECT BACKGROUND
The chemical industry in the UK comprises businesses of a range of sizes. Most larger
organisations are members of the Chemical Industries Association (CIA) and they handle
approximately 80% of the UK chemical business but employ only 20% of UK chemical workers
(these figures came from an informal discussion with the Chemical Business Association
(CBA)). This industry sub sector was surveyed in 2005 (JS2002998 ‘A workplace survey on the
control of task specific exposures to carcinogens, mutagens and reprotoxins in the UK chemical
industry’) and the findings reported in HSL report HSL/2005/35[1]
.
The purpose of this project was to survey small and medium sized enterprises (SMEs), many of
who are members of the Chemical Business Association (CBA). This industry sub sector
handles 20% of UK chemical business but employs 80% of UK chemical workers (again these
figures came from an informal discussion with the CBA). The aim was to assess the
effectiveness of exposure controls at those SMEs carrying out the import, reprocessing and
repackaging of chemical carcinogens and asthmagens. The objectives of the work were:
i) To engage with relevant internal and external stakeholders and assemble a schedule
of workplaces, representative of this industry sector, to be visited. Stakeholders
included HSE’s Hazardous Installations Directorate (HID) and the CBA. The CBA
provided valuable assistance by liaising with members to secure agreement to
support this project.
ii) To visit up to 30 workplaces and assess handling practices and exposure controls
for carcinogens and/or asthmagens. The assessment methodology included (where
possible) a quantitative exposure assessment, either by biological monitoring or air
sampling.
iii) To analyse the findings and compile a final report to compare and contrast with the
findings from JS2002998. If appropriate, the report findings may also be used to
inform possible future work by HSE or industry relating to exposure control at the
import, reprocessing and repackaging of chemical carcinogens and asthmagens.
A listing of some 15 companies was provided by the CBA and a further five companies were
sourced from internal HSE sources. Four of this five were formulators of the azo dye CI Solvent
Red 164 following concerns that this substance can metabolise within the body to ortho
toluidine and aniline. The Surface Engineering Association (SEA) identified two companies as
suppliers of nickel solutions to the industry. A programme of cold calling was also undertaken.
Of those contacted, ten businesses, described below and identified as sites A - J, indicated they
decant and repack and agreed to assist this survey.
Sites A, B, C and D are formulators of dye penetrant solution reported as containing the azo dye
CI Solvent Red 164. Site C also supply a diesel marker concentrate containing the azo dye CI
Solvent Red 24.
Site E take delivery of a concentrated solution of hydrazine hydrate (hydrazine is a carcinogen)
and dilute it before selling on to end users.
2
Site F manufacture potassium chromate solution using chromic acid flake. This and the
resulting potassium chromate solution contain chromium in its hexavalent state (a known
carcinogen and respiratory sensitiser).
Sites G and H manufacture nickel solutions for the electroplating industry using solid nickel
sulphate. Nickel sulphate is a carcinogen and also a respiratory sensitiser.
Site I uses azodicarbonamide (ADC) in the production of blowing agents for flooring material.
ADC is a respiratory sensitiser.
Site J receive bulk deliveries of trichloroethylene (a carcinogen), transfer to bulk storage and
then utilise an automated closed loop filling system to decant and repackage chlorinated
solvents, to be sold on for use as vapour cleaning/degreasing agents.
A HSL occupational hygienist visited all the above sites (accompanied at some by a HSE
inspector) and assessed work practices and exposure controls. Quantitative exposure
measurements were carried out using (where applicable) either air sampling and/or biological
monitoring. A full occupational hygiene report was then written and fed back to the company
via the site inspector.
1.2 OVERVIEW OF USE OF EACH SUBSTANCE
1.2.1 CI Solvent Red 164 (as reported) and CI Solvent Red 24
Site A receive (from site D) a pre-blended dye penetrant kerosene based solution containing CI
Solvent Red 164, which they then put into aerosol cans for supply to the non-destructive testing
(NDT) industry.
Site B receives CI Solvent Red 164 in a xylene-based solution. This is then blended with other
materials and then packed into metal aerosols or tins for supply to the NDT industry.
Site C receives CI Solvent Red 164 as a 70% solution in xylene. This solution is then used to
formulate dyes for gasoline and petrochemical products. This site also uses CI Solvent Red 24
to manufacture gas oil marker concentrate (the substance added to diesel to form ‘red diesel’).
CI Solvent Red 24 is considered to have similar toxicological properties as CI Solvent Red 164.
It is delivered to site as a powered solid and blended with other ingredients to make a solution
that is 0.5% CI Solvent Red 24.
Site D receives CI Solvent Red 164 in a 40-60% solution in a petroleum solvent. This is then
blended with kerosene and a plasticiser before being dispatched to site A.
1.2.2 Hydrazine
Site E receives an aqueous solution of hydrazine hydrate (80% hydrazine hydrate, 51%
hydrazine), which they then dilute down to various strengths (in an aqueous solution) to be sold
on to end users. A small proportion is retained by the site and used to manufacture hydrazine
mono nitrate.
1.2.3 Potassium chromate
Site F adds chromic acid flake to a mixture of water and potash liquor to make potassium
chromate solution.
3
1.2.4 Nickel sulphate
Both sites G and H use nickel sulphate in the production of nickel solutions for the
electroplating industry. At both sites solid nickel sulphate is added to water along with other
ingredients, allowed to mix and then transferred to containers to be sold on to the end user.
1.2.5 Azodicarbonamide (ADC)
Site I blends powdered ADC with a plasticiser. The resulting substance is then sold on as a
blowing agent for flooring material.
1.2.6 Trichloroethylene
At Site J, trichloroethylene is pumped into specialist chlorinated solvent closed loop system
containers. These are then dispatched for cleaning/degreasing purposes.
A more detailed summary of the processes above can be found in the results section of this
report.
1.3 UK REGULATORY POSITION FOR EACH SUBSTANCE
All exposure limits, UK BMGV’s and risk phrases except for CI Solvent Red 164 and CI
Solvent Red 24 have been taken from EH40/2005 amended 2011 and the European Chemical
Substances Information System – ESIS (http://esis.jrc.ec.europa.eu/home.php).
1.3.1 CI Solvent Red 164
Some azo dyes are known to metabolise in the body to o-toluidine (classified as a Category 2
carcinogen in the EU) and/or aniline (a Category 3 carcinogen). Concerns have been raised with
HSE regarding health risks from the use of one of these dyes (CI Solvent Red 164). As a result
of this, in 2008 the Working group on Action to control Chemicals (WATCH) advised that
users of Solvent Red 164 should regard the substance as a suspect (Category 3) carcinogen [4]
and asked HSE to investigate exposure and potential for carcinogenic substances to form.
Both aniline and o-toluidine can be measured in urine. There are currently no UK biological
monitoring guidance values (BMGV) for either substance. As a guideline the German BAT
value of ~900µmol/mol creatinine [2]
is used for aniline, there is no corresponding value to use
for o-toluidine so the reference range for those with no occupational exposure (NOE) have been
used as a guide.
1.3.2 CI Solvent Red 24
CI Solvent Red 24 is considered to have similar toxicological properties as CI Solvent Red 164.
The WATCH Committee concluded in 2008 that this material (CI Solvent Red 164) be treated
as a suspect carcinogen due to the potential of metabolisation in the body to ortho toluidine (o-
toluidine) and/or aniline.
1.3.3 Hydrazine
Hydrazine is classified as a carcinogen (R45) and also has the risk phrases, R10 (flammable),
R23/24/25 (toxic by inhalation, in contact with skin and if swallowed), R34 (causes burns) and
R43 (may cause sensitisation by skin contact). It can also be absorbed through the skin. There is
a UK WEL of 0.02ppm (as an 8-hr TWA).
4
1.3.4 Potassium chromate
Potassium chromate is a hexavalent chromium compound. Hexavalent chromium (CrVI
) is
classed as both a carcinogen and respiratory sensitiser. Due to these classifications there is a
requirement under Regulation 7 of the COSHH Regulations 2002 as amended (‘Prevention or
control of exposure to substances hazardous to health’) ACoP to ‘reduce exposure so far as is
reasonably practicable’. Potassium chromate the compound has also been assigned the risk
phrases R49 (may cause cancer by inhalation), R46 (may cause heritable genetic damage),
R36/37/38 (irritating to eyes, respiratory system and skin) and R43 (may cause sensitisation by
skin contact).
The UK workplace exposure limit for chromium is 0.5mg/m3 and for hexavalent chromium is
0.05mg/m3. There is also a UK biological monitoring guidance value (BMGV) set for urinary
chromium at 10µmol/mol creatinine in a post shift sample.
1.3.5 Nickel sulphate
Many nickel compounds are known respiratory sensitisers. Nickel sulphate had been assigned
the risk phrases R49 (may cause cancer by inhalation), R38 (irritating to skin), R61 (may cause
harm to the unborn child), R20/22 (harmful by inhalation and if swallowed), R42/43 (may cause
sensitisation by inhalation and skin contact), R48/23 (toxic: danger of serious damage to health
by prolonged exposure through inhalation) and R68 (possible risk of irreversible effects).
Soluble nickel compounds (such as nickel sulphate) are assigned an 8 hour TWA WEL of 0.1
mg/m3 (as Ni).
There is no UK Biological Monitoring Value (BMGV) for nickel. At the time the site visits
were carried out, the HSL biological monitoring database contained approximately 2000 results
for urinary nickel, from a wide range of industries. The 90th percentile of the urinary nickel data
in this database was approximately 24µmol/mol creatinine and this was adopted as a guidance
value for the purpose of this project.
1.3.6 Azodicarbonamide
Azodicarbonamide is classed as a respiratory sensitiser (capable of causing occupational
asthma). ADC also has the following health based risk phrase: R42 (may cause sensitisation by
inhalation). In the UK there is an assigned workplace exposure limit (WEL) of 1mg/m3 to ADC
(based on an 8-hr time weighted average reference period).
1.3.7 Trichloroethylene
Trichloroethylene is classified as a carcinogen (R45) and has also been assigned the following
health based risk phrases: R36/38 (irritating to eyes and skin) and R67 (vapours may cause
drowsiness and dizziness). The substance can also be absorbed through the skin. The current
UK WEL is 100ppm (as an 8-hr TWA). There is a UK BMGV of 35mmol/mol creatinine for
urinary levels of trichloroethylene in a post shift sample.
5
2. METHODOLOGY
2.1 THE DESIGN OF THE STUDY
Initially a list of 15 companies was drawn up in consultation with the CBA. Three of these
stated that they no longer decanted / repackaged or split carcinogens / asthmagens. One of the
companies (site I) used azodicarbonamide in the manufacture of a flooring material and as such
was visited.
Internal HSE sources provided the contact details of a further five companies. One of which
(site E) had earlier been visited as part of another project [1]
. When visited the company had
placed a heavy reliance on PPE when handling hydrazine. HSL decided that a re visit to assess
improvements could be included in this study.
Survey work carried out on worker exposures in the surface engineering industry generated two
companies that manufactured nickel plating solutions using nickel sulphate for the
electroplating industry (sites G and H).
In 2008 WATCH requested HSE to investigate the potential for CI Solvent Red 164 to
metabolise to o-toluidine and aniline, therefore the names of four reported formulators of CI
Solvent Red 164 (sites A through to D) were identified as part of this work. This included one
formulator of gas oil marker concentrate containing CI Solvent Red 24.
Cold calling produced two sites (Sites F and J). Site F manufactured potassium chromate and
Site J distributed trichloroethylene in closed loop systems.
For sites A through to D, F and J, workers were asked to volunteer in a biological monitoring
programme. Informed consent was obtained in accordance with HSG167 “Biological
monitoring in the workplace”, a practical guide to its application to chemical exposure’ (HSE,
1997).
This programme involved submitting pre and post shift urine samples for analysis. Samples
were requested to be given over five days that exposure would occur.
At sites C, F, G, H, I and J, air sampling was also carried out for the substance handled.
2.2 ANALYSIS DETAILS
A list of the substances measured and the corresponding methods are presented in Table 1,
overleaf.
6
Table 1 – List of the substances measured per site and analysis methods used
Site Substance(s) Sampling and analysis method
A, B, C, D Aniline (in urine) Gas chromatography with mass spectrometry
(GC-MS).
Ortho toluidine (in urine) GC-MS
Total inhalable dust (Site C
only)
MDHS14/3 ‘General methods for sampling and
analysis of respirable and inhalable dust’.
F Chromium (total) (airborne) MDHS91 ‘Metals and metalloids in workplace
air by X-ray fluorescence spectrometry’.
Chromium (hexavalent)
(airborne)
BS ISO 16740 – utilising Ion chromatography
(IC).
Chromium (in urine) Inductively coupled plasma mass spectrometry
(ICP-MS) with collision cell technology.
G & H Total inhalable dust (airborne) MDHS14/3 ‘General methods for sampling and
analysis of respirable and inhalable dust’.
Nickel (airborne) MDHS91 ‘Metals and metalloids in workplace
air by X-ray fluorescence spectrometry’.
Nickel (in urine) ICP-MS
I Total inhalable dust (airborne) MDHS14/3 ‘General methods for sampling and
analysis of respirable and inhalable dust’.
ADC (airborne) MDHS92 ‘Azodicarbonamide in air’.
J Trichloroethylene (airborne) MDHS80 ‘Volatile organic compounds in air’.
Trichloroethylene (in urine) Trichloroacetic acid in urine by Liquid
chromatography – mass Spectrometry – mass
spectrometry (LC-MS-MS).
7
3. RESULTS
3.1 FORMULATORS OF CI SOLVENT RED 164 (A – D) AND 24 (C) – AS REPORTED
The findings of this and similar work on end users of the dye was presented to WATCH in
October 2011[3]
.
Site A
Dye penetrant solution supplied from site D in 1000L IBCs was used to fill up aerosol cans. The
solution was transferred from the IBC to an aerosol supply tank by pneumatic pump and lance.
The empty aerosol cans arrived on a conveyor belt and were filled automatically in a closed
transparent chamber. They were then crimped and gassed remotely in a separate unoccupied
building. At the time of the visit the local exhaust ventilation (LEV) was being renewed.
Personal protective equipment (PPE) consisted of poly cotton overalls (with disposable Tyvek
also being available), reusable and disposable nitrile gloves.
There were up to 20 workers potentially exposed to CI Solvent Red 164.
Site B
Dye penetrant solution was delivered to site in 100L drums. These were fitted with taps which
were used to release the drum contents into an open tub. This tub was then poured into a mixing
vessel and other ingredients were added. The vessel was then lidded and the contents allowed to
mix. The resulting solution was then transferred to either aerosols (in a semi enclosed system)
or either 5 or 25L tins in an open workroom. Workers wore their own clothing along with
disposable gloves, either PVC, neoprene or nitrile. Respiratory protective equipment (RPE) was
worn when loading the mixer. LEV was fitted to the lidded mixing vessel and also to the aerosol
filling station.
Up to five workers were potentially exposed to CI Solvent Red 164.
Site C
CI Solvent Red 164 was delivered to site in either 1 tonne IBCs or 200L steel drums. The
contents of the IBC/drum were loaded into a sealed mixing vessel by vacuum transfer using a
flexible hose and lance, with the operator in close proximity to the drum. There was a moveable
captor hood available for use. The other ingredients were added to the vessel in the same
manner. Whilst still sealed, the vessel contents were allowed to mix. The final product was
gravity dropped to either 1 tonne IBC or 200L drum. PPE worn consisted of RPE, chemical
resistant clothing and gloves.
CI Solvent Red 24 was supplied in powder form in polythene lined cardboard boxes. The boxes
were placed in an extracted booth that had been constructed ‘in house’. The dye was
pneumatically transferred using a hand held lance to a mixing vessel where it was dissolved in a
hydrocarbon solvent along with other ingredients. This vessel had a moveable captor hood at its
opening. When mixed the vessel contents were piped to heated storage tanks and held there
overnight prior to dispatch. PPE worn consisted of a positive pressure full body suit with
integrated visor, two pairs of latex gloves and safety footwear.
There were 37 employees at the company with around ten exposed to both dyes.
8
Site D
About 18kg of dye penetrant concentrate was transferred from a 100kg drum to an empty drum
using a flexible hose and lance. Other ingredients were added to the drum manually. A flexible
captor hood was available for this part of the process but was not always used. This drum was
then moved by forklift truck to a closed vat. Using an electronic pump, the drum contents were
transferred to the vat with kerosene then pumped in from a remote storage tank. Two more
drums of dye penetrant were then added to the vat using the electric pump. The vat was then
closed and its contents stirred until mixed. The solution was then pumped to a 1000L IBC where
it was stored until ready to be delivered to site A. PPE worn consisted of safety shoes, poly
cotton top (workers’ own jeans), natural rubber gloves and safety glasses.
Three people were potentially exposed to CI Solvent Red 164.
Poor local exhaust ventilation (LEV) design was observed at Sites A, C (for handling CI
Solvent Red 164) and D. The location of the discharge point for the LEV system at Site B was
also found to be inappropriate.
At site B workers own clothing was worn, advice was given on the day that this was
unacceptable. Respiratory protective equipment (RPE) was worn at Sites B and C (when
handling CI Solvent Red 24). Face fit testing was not carried out at Site B, not applicable for the
RPE worn at Site C.
For all sites urinary levels of both o-toluidine and aniline were within the range for those with
no occupational exposure (up to 5µmol/mol creatinine and 10µmol/mol creatinine respectively)
with the exception of 3 aniline results. Two of these 3 should be treated with caution, as the
sample volumes were very low, resulting in significant sample dilution. The remaining sample
had a ‘low creatinine’ concentration (see foot note below Table 2).
CI Solvent Red 24 is used by site C in powder form. The total inhalable dust exposure (8-hr
TWA) was 3.3mg/m3 (below the COSHH exposure limit of 10mg/m
3) and the task based
exposure during the addition of the dye to a mixing vessel was 21.5mg/m3 (over a sampling
period of 73 minutes). Static sample measured concentrations were in the range <0.08 to
2.6mg/m3. Urinary aniline concentrations were within the range for those with no occupational
exposure with o-toluidine ‘not detected’ in any of the samples. During the visit the company
stated that they were looking to switch to a liquid form of the dye. Contact was made with the
company during the writing of this report and they stated,
‘In the last 6 months or so we have completed the process development for making red 24 in
liquid form and production is going well …… we do have some stocks of red 24 in powder and
will use these up slowly over the next 6 months or so, although we will predominantly using red
24 liquid’.
Urinary o-toluidine and aniline results for Solvent Red 164 and 24 are summarised in Table 2.
9
Table 2 Urinary ortho-toluidine and aniline results (CI Solvent Red 164 & 24)
Substance Total µmol/mol creatinine
<LOD LOD - NOE >BMGV Min Max
Ortho-toluidine 69 55 14 N/A <LOD 2
Aniline 47 1 43 0 <LOD 61#
Note - The concentration of analytes in urine can vary depending on the state of hydration of the
worker. To compensate for this it is common practice to adjust an analyte concentration by
dividing its concentration by the concentration of creatinine. This assumes the analyte is
excreted in the same way as creatinine and for aniline and o-toluidine this is not certain.
However, creatinine adjustment is unlikely to introduce significant errors except at the extremes
of the concentration range so adjustments with 'low' (<3 µmol/l) and 'high' (>30 µmol/l)
creatinine concentrations are flagged as 'low' or 'high'. In such cases the result should be
interpreted with caution.
NOE = Reference range for those with no occupational exposure (5µmol/mol creatinine for o-
toluidine and 10µmol/mol creatinine for aniline)
LOD = ~ 0.4µmol/mol creatinine for both substances
BMGV = ~900µmol/mol creatinine for aniline [2]
. There is no value for o-toluidine
# = Result should be treated with caution due to significant sample dilution
3.2 HYDRAZINE SUPPLIER – SITE E
A previous visit to the site (as part of another project) found that there was open handling of
hydrazine on a daily basis. The conclusions from this visit were that the exposure controls relied
heavily upon PPE. At the time of that visit the company had plans to make significant
improvements. By the time of the visit for this project these improvements had been carried out
and were in operation.
Hydrazine hydrate was delivered to the site by road tanker and off loaded into dedicated storage
tanks within bunded areas. When required the solution was pumped to the mixing vessel
through welded fixed steel pipe work. Water was then added to dilute the hydrazine down to
varying strengths. Using a sealed transfer system operated by a computer controlled filling
station, the solution was loaded into various sized containers. There were approximately five
workers potentially exposed to hydrazine. PPE worn (to protect the worker if there is a break in
containment) consisted of chemical protective suit, gloves and footwear.
Upon inspection the handling, dilution and repackaging of the hydrazine was carried out in
almost total containment, therefore controlling exposure to as low as is reasonably practicable
(ALARP). Experimental BM was attempted but this failed to produce valid and meaningful
results.
10
3.3 POTASSIUM CHROMATE PRODUCER – SITE F
Chromic acid flake was added to a vessel containing potassium hydroxide manually using a
scoop. The vessel contents were left to settle overnight. The following morning the supernatant
liquid was pumped through pipe work containing in line filters to a holding vessel and the
sediment at the bottom of the tank washed out into a waste pit. The pipe work was then used to
connect the holding vessel to the original vessel and the liquid pumped back over and stored
until required. The final product was pumped into 5L containers using a hose. The hose was
placed in the container and the contents pumped in. When the container was full the hose was
taken out and placed in the next container. The headspace of the mixing vessel was extracted
and there was LEV present at the drumming off point in the form of a moveable captor hood.
PPE worn consisted of safety wellingtons, chemical protective suit (during flake addition), poly
cotton overalls, apron, hard hat, safety glasses, a half mask respirator and a battery powered
RPE system.
There were ten employees in total with five of these potentially exposed.
The company’s COSHH assessments were not considered suitable and sufficient. These were
re-written with only minor improvements required. The company’s most recent 14 monthly
thorough examination and test report of LEV (carried out by an external contractor) was not
adequate with the issue being raised with the relevant HSE personnel. One worker wore a half
facemask which face fit testing had not been carried out on.
Inhalation exposures to chromium and hexavalent chromium were substantially less than the
relevant WELs. One worker had urinary concentrations of chromium above the reference value
for those with no occupational exposure with one sample exceeding the UK BMGV of
10µmol/mol creatinine by 1.5 times. Tables 3 and 4 present summaries of the air sampling and
the biological monitoring respectively
Table 3 Results of the air sampling for total and hexavalent chromium
Sample type No
Substance (mg/m3)
Total chromium range Hexavalent chromium range
Task based 8-hour TWA Task based 8-hour TWA
Personal 4 <0.01 – 0.05 <0.001 – 0.008 0.003 – 0.017 0.0004 – 0.003
Static 2 <0.01 – 0.38 - 0.002 – 0.174 -
Exposure limit (8-hr TWA) 0.5 0.05
Sampling durations ranged from 53 – 76 minutes for the personal samples and were 72 minutes
for the static samples.
11
Table 4 Results of BM for chromium (in µmol/mol creatinine)
Total <LOD LOD - NOE >BMGV Range
6 0 2 1 1.14 to 15.13
NOE = 3µmol/mol creatinine
LOD = <0.08µmol/mol creatinine
BMGV = 10µmol/mol creatinine
3.4 NICKEL PLATING SALTS PRODUCER – SITES G AND H
Site G
Nickel sulphate was placed into a grinder to break down large lumps. Once ground it exited the
grinder via a discharge point and entered a bucket. This bucket was then tipped into a 1200L
IBC containing water. Other ingredients were in bags and were manually emptied into the IBC.
The contents were mixed by agitation and then left to settle. After ~24 hrs the solution was
drummed off into 25L containers. The container was placed onto scales and filled with a lance
connected to the IBC. When the required weight had been delivered, the lance was raised, the
container removed, a fresh one put on and the process repeated. There were two people
potentially exposed. There was a portable fan and filter unit at the discharge point of the grinder
and a moveable captor hood above the grinder, which was then moved to the IBC when that was
in use. PPE worn consisted of polypropylene overalls, safety shoes, safety glasses, disposable
latex gloves and a FFP1 mask.
Site H
The operator stood on a platform of stacked wooden pallets and manually emptied nickel
sulphate from 25kg sacks into a mixing vessel containing water. Other ingredients were added
and the vessels’ agitator turned on to allow the contents to mix for 15minutes. The solution was
then dispensed into 25L drums. The drums were placed in a wooden crate located on the top of
scales. There were 16 drums in one crate. A hose was connected via cam lock to the mixing
vessel and the solution then pumped into the drums using the weight as a guide. There were
three captor hoods, one over the mixing vessel, one over the drumming off area and another
over a storage area. When not in use these hoods were blanked off. PPE worn consisted of poly
cotton overalls, safety boots, visor and rigger type gloves; disposable nitrile gloves were
sometimes used.
Two workers were potentially exposed to nickel sulphate.
The COSHH assessments at both sites required some improvements. The LEV hood over the
mixing vessel at Site H was blocked when the hatch was raised.
None of the exposures to inhalable dust and nickel exceeded relevant exposure limits. Inhalation
exposures at site H were less than the detection limits of the method.
12
For site G, none of the urine results exceeded the reference range for those with no occupational
exposure (up to 10µmol/mol creatinine). For site H three results exceeded this value with one
result exceeding the standard adopted for this project (24µmol/mol creatinine). For this site the
urine samples were not supplied on the date of the air sampling therefore they cannot be directly
compared.
Tables 5 and 6 present the summaries of the air sampling and biological monitoring
respectively.
Table 5 Results of the air sampling for inhalable dust and nickel
Sample type No
Substance (mg/m3)
Total inhalable dust range Nickel range
Task based 8-hour TWA Task based 8-hour TWA
Personal 3 <0.24 to 1.75 <0.02 to 0.30 <0.02 to 0.17 <0.001 to 0.03
Static 7 <0.24 to 0.31 - <0.01 to 0.03 -
Exposure limit (8-hr TWA) 10 (COSHH 2002) 0.1 (WEL)
Sampling durations ranged from 31 to 82 minutes for the personal samples and 31 – 38 minutes
for the static samples
Table 6 Results of BM for nickel (in µmol/mol creatinine)
Total <LOD LOD - NOE >Guidance value Range
24 0 21 1 2.08 to 31.48
NOE = 10µmol/mol creatinine
LOD = ~<2µmol/mol creatinine
Guidance value (standard adopted) = 24µmol/mol creatinine (the 90th percentile in HSL’s
monitoring database)
3.5 PRODUCER OF BLOWING AGENT FOR FLOORING MATERIAL CONTAINING ADC – SITE I
ADC was received in 20kg bags, and manually added by the operator to a mixing vessel already
containing a plasticiser. The contents of this vessel were allowed to mix until blended. LEV was
present at the headspace of the vessel. The process itself was a one man job but there were ten
who are trained to do it. PPE worn consisted of a battery powered positive pressure hood, cotton
overalls, safety footwear, high visibility vest, hard hat and safety goggles. There were 36 people
employed on site.
During the visit airborne particulate was visibly generated during when the bags of ADC were
emptied into the mixing vessel. As the LEV was connected to the headspace of the vessel and
not at the point where the bags were emptied, it offered no enclosure of the source. The COSHH
assessment needed improvement.
13
The inhalation exposure measured was nearly three times the WEL, Table 7. As ADC is a
respiratory sensitiser, control can only be treated as adequate if exposure is reduced to as low a
level as is reasonably practicable (ALARP).
Table 7 Results of the air sampling for total inhalable dust and ADC
Sample type No
Substance (mg/m3)
Total inhalable dust range ADC range
Task based 8-hour TWA Task based 8-hour TWA
Personal 1 24.7 4.6 15.1 2.8
Static 5 0.84 to 5.8 - 0.64 to 3.0 -
Exposure limit (8-hr TWA) 10 (COSHH 2002) 1 (WEL)
The sampling period for the task based exposure was 45 minutes
There are no biological monitoring methods for ADC
Battery powered RPE was worn which would supply the worker with a protection factor of 20.
This would be adequate if the exposures obtained above were typical, however control of
exposure should be achieved by other means prior to the provision of protective equipment
(COSHH 2002 as amended) such as improvements to the LEV system.
3.6 REPACKAGING OF TRICHLOROETHYLENE INTO CLOSED LOOP SYSTEMS – SITE J
Trichloroethylene was delivered to site by road tanker, pumped to a bulk storage tank and stored
until needed. When required the solvent was pumped into specialist closed loop systems using a
hydraulic lance connected to a semi automated filling station. One person operated this filling
station while another puts the lids on the closed loop system. There was LEV at the end of the
lance at the point where the trichloroethylene was dispensed. PPE worn consisted of safety
footwear, high visibility jacket, reusable chemical protective gloves, safety glasses and poly
cotton overalls. There were 23 people employed at the company with up to five potentially
exposed to trichloroethylene.
The companies LEV report did not constitute a thorough examination and test and the COSHH
assessment needed improvement.
Measurements showed that exposures to trichloroethylene during transfer of solvent to the
closed loop system were low. Measurable concentrations were obtained at the source and also
from the top of the closed loop tanks in the storage area, possibly due to residue, however all
concentrations were significantly below the WEL. The BM results confirm this. Tables 8 and 9
present the summaries of the air sampling results and biological monitoring results respectively.
14
Table 8 Results of air sampling for trichloroethylene
Sample type No Trichloroethylene (ppm)
Task based 8-hour TWA
Personal 2 3.9 to 4.1 0.5
Static 7 0.6 to 20.0 -
Exposure limit (8-hr TWA) 100 (WEL)
Sampling durations for the personal samples were 56 and 60 minutes and for the static samples
ranged from 40 to 50 minutes
Table 9 Results of urine sampling for trichloroethylene (in mmol/mol creatinine)
Total <LOD LOD - NOE >BMGV Range
14 0 N/A 0 0.2 to 4.1
NOE = N/A – no value
LOD = ~0.08mmol/mol creatinine
BMGV = 35mmol/mol creatinine
15
4. DISCUSSION
4.1 CI SOLVENT RED 164 AND 24
At all the sites CI Solvent Red 164 was handled in solution, thus limiting the potential for
inhalation exposure. There was the potential for dermal exposure at all sites, however, this
appeared to be reasonably well controlled with a combination of measures. One measure was
enclosure of the process and was applicable to aerosol filling (sites A and B) and sealed / closed
mixing vessels (sites B, C and D).
LEV was present at sites B, C and D, however deficiencies were present at each. These included
incorrect locations of exhaust points (site B) and limited capture of the captor hoods at sites C
and D. The LEV systems at site A were in the process of being renewed at the time of the visit.
At site B workers wore their own clothing. It was pointed out at the time of the visit that this
was not acceptable. At site D workers wore their own trousers but a company issue polo shirt.
At the other two sites company issue overalls were worn (poly cotton – site A or chemical
resistant – site C).
The extraction booth at site C for handling CI Solvent Red 24 had been constructed ‘in-house’.
There was no commissioning report available. HSE Guidance HSG258 ‘Controlling airborne
contaminants at work A guide to local exhaust ventilation (LEV) recommends the use of a
commissioning report as a reference with which to compare future thorough examination and
tests. Further process improvements were planned by the company, which included using the
dye in liquid form once all the powdered dye had been used. The operator wore a full
compressed air fed positive pressure suit with integrated visor, which had an APF of 200.
Urinary levels of aniline for formulators of CI Solvent Red 164 and CI Solvent Red 24 (Sites A
to D) were within the reference range for those with no occupational exposure (up to
10µmol/mol creatinine) for all samples except three. These three results should be treated with
caution as two were significantly diluted prior to analysis and the third contained low creatinine
levels (the urine was dilute). However these three were significantly below the German
Guidance value of 900µmol/mol creatinine [2]
(there is no UK guidance value).
All urinary levels of o-toluidine were within the reference range for those with no occupational
exposure (up to 5µmol/mol creatinine).
Based on the measurements taken in this work it may be concluded that CI Solvent Red 164 is
not metabolised to ortho-toluidine. Only one formulator of products containing CI Solvent Red
24 was visited as such this report cannot make the same conclusion.
4.2 HYDRAZINE
Hydrazine was handled in almost total containment thus controlling exposure to hydrazine to
ALARP.
4.3 POTASSIUM CHROMATE
Chromic acid flake was handled in a slow and controlled manner. The resulting worker
inhalation exposures appeared to support this. However there was a high measured
concentration of hexavalent chromium for one of the static samples (0.174mg/m3) which
indicates the potential for generation of airborne particulate containing chromium.
16
Although inhalation exposures were low the biological monitoring results indicate exposure to
chromium. There was a high potential for dermal exposure to the potassium chromate solution
when removing filters from housings, drumming off and from splashes. Protective gloves were
worn when carrying out these tasks but good hygiene practices also need to be followed to
prevent exposure by other routes i.e. ingestion. Face fit testing of the negative pressure RPE
used by one of the workers had not been face fit tested, it was also observed that this mask was
dirty on the inside.
The companies COSHH assessments were not suitable and sufficient at the time of the visit.
Once they had been re-written only minor amendments were needed.
4.4 NICKEL PLATING SALTS
Inhalation exposure to nickel at both sites appeared to be well controlled by a combination of
controlled manual handling of the nickel sulphate and LEV. The low inhalation exposures
obtained support this. However the LEV hood at site H was blocked when the hatch of the
mixing vessel was raised.
At site G the urine results were all within the range for those with no occupational exposure,
indicating good control of nickel by all routes.
The biological monitoring results at site H exceeded the range for those with no occupational
exposure for three samples with one also exceeding the standard adopted for this work. These
samples were not from the same day as the air sampling and so could not be compared to
inhalation exposures obtained.
The COSHH assessments at both sites required improvements.
4.5 ADC
Exposure to ADC was not properly controlled at Site I; significant quantities of airborne
particulate were generated when adding ADC to the mixing vessel. The LEV system was fixed
to the headspace of the mixing vessel and therefore was not extracting at the source of the
exposure. The resulting 8-hr TWA inhalation exposure was nearly three times the WEL of
1mg/m3 (from a much higher task based exposure). ADC is a respiratory sensitiser and as such
control can only be considered adequate if exposure is reduced to as low a level as is reasonably
practicable (ALARP). LEV improvements and more controlled working practices would lower
exposures.
4.6 TRICHLOROETHYLENE
Worker exposure to the trichloroethylene occurred when the lance entered and exited the closed
loop system. There was LEV at the dispensing end of the lance i.e. at the source. As expected
with the closed loop type of system the air sampling and biological monitoring showed
exposure to be well controlled.
The LEV TExT report did not have all the required information to be considered a through
examination and test. The COSHH assessment also needed improvement.
4.7 COMMON THEMES
Deficiencies in the COSHH assessments at sites F, G, H, I and J were observed with the
individual site visit reports stating what was required by way of improvements.
17
A common denominator during the visits was poor LEV design. This was observed at Sites A
(however this was being renewed during the visit), B, C, D, H and I.
Inadequate LEV thorough examination and test reports were observed at Sites F and I. For site F
the issue was taken up with the relevant HSE inspector.
Face fit testing was not carried out, where applicable at Sites B and F. This is a requirement of
the COSHH Regulations 2002 as amended.
18
5. CONCLUSIONS
Based upon the results obtained in this work, the azo dyes CI Solvent Red 164 and CI Solvent
Red 24 are not metabolised to ortho toluidine.
At eight of the ten sites visited there was direct worker handling of the carcinogen / asthmagen.
Whereas the majority of these sites did this in a careful and controlled manner, one site did not
and thus elevated inhalation exposures were obtained.
There were flaws in LEV design as discussed earlier which resulted in the system not
controlling exposure at source i.e. incorrect positioning of hoods and the blocking of hoods by
vessel hatches.
Where applicable (sites F through to J) and with the exception of one site (I), all inhalation
exposures were low. There was, however evidence of a lack of control of exposure via other
routes (i.e. ingestion / dermal) from the biological monitoring results of sites F and H.
With the exception of site E further improvements could have been made at each site visited in
order to control exposure to carcinogens / asthmagens to ALARP.
19
6. RECOMMENDATIONS
Recommendations were made by HSE for improvements to management systems and / or
exposure control at all sites apart from site E where none were required.
The recommendations made are summarised below:
o Improvements / reviews of COSHH assessments
o Carry out improvements to LEV systems; this included re-designing systems to offer better
control at source
o Compare future LEV through examination and test (TExT) reports to HSE guidance in
order to ascertain whether the report is comprehensive enough
o Introduce where applicable a programme of health surveillance when using asthmagens
o Improvements to PPE programmes including face fit testing, RPE maintenance and correct
glove selections.
20
7. REFERENCES
[1] ‘A workplace survey on the control of task specific exposures to carcinogens, mutagens and
reprotoxins in the UK chemical industry’, C Keen 2005.
(http://www.hse.gov.uk/research/hsl_pdf/2005/hsl0535.pdf).
[2] ‘List of MAK and BAT Values 2012: Maximum Concentrations and Biological Tolerance
Values at the Workplace’.
http://onlinelibrary.wiley.com/book/10.1002/9783527666034
[3] ‘The supply and use of CI Solvent Red 164 as a penetrant dye in the detection of cracks in
metal components’, J Cooke, 2011
http://www.hse.gov.uk/aboutus/meetings/iacs/acts/watch/251011/watch-2011-4.pdf
[4] ‘The use of liquid dye penetrants containing the azo dye compound CI Solvent Red 164 in
the detection of flaws or cracks in metal components.
http://www.hse.gov.uk/foi/internalops/sectors/manuf/030810.htm
Published by the Health and Safety Executive 12/13
Assessment of exposure to carcinogens and asthmagens in the contract import, processing and repackaging industries
Health and Safety Executive
RR983
www.hse.gov.uk
The aim of this research was to assess the effectiveness of exposure controls at small and medium-sized enterprises (SMEs) carrying out the import, reprocessing and repackaging of chemical carcinogens and asthmagens.
Visits were made to 10 companies which decant and repack chemicals including carcinogens and asthmagens. The visits examined handling practices and exposure controls, and included, where possible, a quantitative exposure assessment, either by biological monitoring or air sampling.
Although there were some examples of good practice, overall, this survey found that control of exposure was variable in its effectiveness. Deficiencies in COSHH assessments (Control of Substances Hazardous to Health) and/or inadequacies in engineering controls (LEV - Local Exhaust Ventilation) and/or PPE (Personal Protective Equipment) were found at all but one site visited.
Recommendations for improvements to management systems and/or exposure control were made for all but one site. Recommendations included the need to improve LEV systems; to introduce health surveillance programmes; and to improve PPE programmes, including ensuring the introduction of fit testing for Respiratory Protective Equipment (RPE), undertaking routine RPE maintenance and ensuring correct glove selection.
This report and the work it describes were funded by the Health and Safety Executive (HSE). Its contents, including any opinions and/or conclusions expressed, are those of the authors alone and do not necessarily reflect HSE policy.