coshh beyond clp - tridenthse.co.uk · -1-coshh beyond clp by david osborn chartered occupational...

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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

• Interpretation later clarified by decision of the Court of European Justice (Sep 2015)

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”

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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


‘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)

Safety Data Sheet NEW FORMAT : (CLP)




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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 (Article 39) 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).


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Duties on users of substances covered by a REACH ‘Authorisation’ (Article 66)

• If a substance is covered by an Authorisation by the manufacturer (or any ‘upstream actor ’) then the user has a duty to notify ECHA (European Chemicals Agency) within three months of first receiving supply of that substance.

• ECHA will keep that information in a register which is available to Member States’ “Competent Authorities” (e.g. HSE).




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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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”





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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Approach taken by Cross Manufacturing Company (1938) Ltd is to use the calculator in its simplest form : to classify hazard as HIGH , MEDIUM , LOW

Case Study : Cross Manufacturing Company (1938) 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’

Case Study :

Cross Manufacturing Company (1938) Ltd

By kind permission of Mr Richard Cross

(Director)

COSHH 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


COSHH Assessment

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Sections 5 - 9


COSHH Assessment

Section 10

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

Version issued before REACH / CLP / GHS


Version issued after REACH / CLP / GHS


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COSHH Essentials


Case study :



Programme

The following resources are available via the internet at http://www.trident.uk.com :-

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

(An earlier version of) this presentation, as a 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

BREXIT – “REACH”The HSE have issued guidance:

Essentially not much change for users of chemicals.

EU (Withdrawal) Act 2018 – Royal Assent 26/6/18

HSE will assume role of ECHA in UK

Manufacturers, Suppliers, Importers duties set out in guidance…

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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’…”

QUESTIONS / DISCUSSION

THE END

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