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When I have been working on COSHH assessments, I have always felt that only one out of these three ought to really pose any significant difficulty in our decision making process. What I mean by this is that if operatives wear protective gloves at all times when handling chemicals then this will prevent the absorption of said chemicals through the skin. Similarly, if an operative is absolutely intent on drinking or swallowing the chemical that is provided to them, then there is little you can do to prevent this misuse!
It is very common for me to come across
organisations for which COSHH has become an umbrella term,
encompassing all matters of chemical safety.
This leaves us with the matter of inhalation and whether we will eventually decide that it is necessary for employees to wear respiratory protection when using certain substances. In my opinion and in so far as cleaning is concerned, it is this that we should be focusing on when creating our COSHH assessments.
Prior to COSHH regulations being introduced in 1988, we had a situation in the UK where people were going to work and being exposed to hazardous substances without any control or true idea of what might befall them in later life. One of the substances which really pushed the development of the COSHH regulations along was asbestos, as many thousands of people were overexposed to asbestos whilst working, consequently developed asbestosis and ultimately died as a result.
This being the case, efforts were made during the creation of the COSHH regulations to identify every substance known at that time to pose a hazard to human health. These were listed in a document entitled EH40 Workplace Exposure Limits which continues to exist and is frequently updated.
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Interestingly the upshot of the legislation is not that it is illegal for manufacturers to make products containing hazardous substances but simply that if they do, they must make it known which substances they have used on the Material Safety Data Sheet (MSDS) relating to that product. Going back to a point I have made previously however, it is surprising if not slightly alarming the number of people I meet with responsibility for Health & Safety, who simply do not know where to find this information.
When looking at any manufacturer’s data sheets, they should all be laid out in a similar manner, covering the same 16 areas of information in the same order. The example I frequently use when training on this matter is a product from the Premiere range called Force Citrus. Section 3 of the data sheet lists all the product’s raw materials and in the case of Force Citrus, itemises the following: N-(3- Aminopropyl)-N-dedecylpropane-1, 3-diamine, silicic acid, sodium salt, nonionic surfactant, perfume.
Now I’m no chemist and whilst I think I’ve got a fair handle on what a perfume might be aiming to achieve, I’m at a bit of a loss where everything else is concerned! Clearly we lay-people need this information presenting to us in an easier to understand format and this takes place with Section 8 of the MSDS which in the case of Force Citrus states: ‘No exposure limits known for ingredients’.
Were the product to contain a legally classified hazardous substance it would be listed here along with its exposure limit.
Whilst carrying out COSHH assessments it is obligatory on the employer to make certain decisions/ answer key questions if a product is identified as containing a hazardous substance.
1. Do we have to use it?
2. Can we source something ‘safer’ that will do the same job?
3. What PPE (particularly respiratory protection) is required in order that people are safe whilst using it?
Tomorrow’s Cleaning November 2015 | 29
One would hope that while carrying out these assessments, the hazardous substances we come across are relatively few and far between and that the questions posed above are fairly easy to answer. Let’s face it we are talking about cleaning chemicals here. Most manufacturers I know will aim to be ethical by making products that are as safe as reasonably possible whilst also complying completely with their legal obligations.
However in my experience it is entirely possible for some to comply with the legalities whilst ignoring the matter of ethics wholeheartedly. I’m always reminded of a visit I once paid to a prestigious public school in order to give some advice on one or two floors they were having difficulty with.
Whilst waiting in office of the Housekeeping Manager, I spied a 10 litre container of another manufacturer’s multi-purpose cleaner. Having not previously seen much from this manufacturer and being naturally curious I had a read of the label, which portrayed the product to be fairly innocuous and run of the mill. The Housekeeping Manager said that it was brilliant and they used it everywhere – in the dormitories, in the refectories, in the classrooms etc.
I had a look at the MSDS for the product and on reading, I nearly fell off my chair! The product contained three hazardous substances, including formaldehyde. Formaldehyde is a carcinogen, overexposure to which has been proven to cause cancer. Clearly the COSHH assessments had not been carried out effectively in this particular instance and not through any willful neglect or deliberate misconduct but simply because those concerned had not been trained to carry out the process.
I’ve said it before and no doubt I’ll say it again but there can be no undermining the value of training for people working at all levels within our industry, regardless of what we think we already know.
www.premiereproducts.co.uk
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