The control of substances hazardous to health, Environmental


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The control of substances hazardous to health

The control of substances hazardous to health The Control of Substances Hazardous to Health Regulations 1999 (COSHH) The Health and Safety Homepages provide you with a wealth of health and safety related information whether you are a duty holder or just an interested employee 13, http://www.healthandsafety.co.uk/cosele.htm (Direct Hit) The Control of Substance Hazardous to Health (COSHH) Regulations of 1988 since amended and consolidated in 1999 are the main piece of legislation covering control of the risks to employees and other people arising from exposure to harmful substances in connection with any work activity under the employer's control. The main objective of the Regulations is to reduce occupational ill health by setting out framework for controlling hazardous substances in the workplace The Chemicals (Hazard Information and Packaging for Supply) Regulations 1994 (CHIP2) In terms of the Regulations, a Substance Hazardous to Health is: · one that has already been classified as being very toxic (T+), toxic (T), harmful (X), corrosive (C) or irritant (Xi) under the Chemicals (Hazard Information and Packaging) Regulations or CHIP (The Approved Supply List). · or a substance which has been assigned exposure limits · or a substance that is carcinogenic, mutagenic or toxic to reproduction · or dust in substantial concentrations in air and · any substance not mentioned above but which creates a hazard to health comparable to those mentioned above. Legal duties under COSHH are laid primarily on the employer; it is the directors duty to see that proper systems of work and management are in place. Relevant information and training on how to deal with hazardous substances must be provided, a duty that extends to every and anybody on the premises. Duties on employees include making proper use of any control measures, following safe systems of work, abiding by local rules and reporting defects in safety equipment. · An assessment of the risks to health arising from the use of hazardous substances at work and deciding what precautions are needed, · preventing or adequately controlling exposure, · ensuring that control measures are used, maintained, examined and tested, · monitoring exposure and carrying out health surveillance and · ensuring that employees are properly informed, trained and supervised. "Suitable and sufficient" assessment includes determining the hazardous substances that are to be encountered, assessing the risks they present to health, calculating the quantity the duration and how frequently the substances are used, how hazardous they are and what the exposure routes and finally deciding on the action needed to prevent exposure or to reduce it as far as is reasonably practicable. This will also include the actions to be taken in an Emergency, to clear up any spills and to safely dispose of any residues. Except for the most trivial cases, the conclusions of this assessment must be recorded, made readily accessible and reviewed regularly. Employers must ensure that the exposure of employees to hazardous substances is either prevented (i.e. no exposure) or adequately controlled. If it is reasonably practicable, exposure must be prevented by changing the process or activity so that the hazardous substance is not required or generated, or replacing it with a safer alternative (especially important if the substance is a carcinogen), or using it in a safer form. If prevention is not reasonably practicable, exposure must be adequately controlled by one or more of the measures outlined in the Regulations e.g. total enclosure of the process, suitable ventilation etc. (If total enclosure is not practicable for a carcinogen then all the other methods of control mentioned in the Regulations must be used.) Adequate control of volatile or airborne substances can be assessed by reference to the set Exposure Limits. Adequate control also means having systems in place to deal with emergencies, spills and disposal. Only as a last resort should personal protective equipment be used as a means of protection. (However, the routine wearing of laboratory coats and safety glasses is generally regarded as a basic measure to minimise risks from foreseeable hazards - it is not reasonably practicable to provide other means of protection for workers and especially for their eyes.) Ensuring that Control Measures are Used and Maintained Employees are required to make proper use of control measures (e.g. fume-hoods) and to report defects and employers must take all reasonable steps to ensure that they do so. Employers must also ensure that the equipment is kept in efficient working order and good repair and that it is tested regularly. Monitoring Exposure and Health Surveillance Monitoring of the concentrations of hazardous substances in the air must be carried out in certain circumstances e.g. where there could be a serious risk to health if control measures failed or deteriorated. Where the assessment has shown this to be necessary e.g. use of a substance known to cause occupational asthma or severe dermatitis, then health surveillance must be carried out. Information, Training and Supervision COSHH requires that employers provide their employees with suitable information, instruction and training about:· the nature of the substances they work with or are exposed to and the risks created by exposure to those substances and · the precautions they should take Employers should give sufficient information and instruction on· control measures and how to use them, · the use of any personal protective equipment and clothing, · results of any exposure monitoring or health surveillance and · emergency procedures. HSE Press Release E099:01 - 15 June 2001 Trichloroethylene users advised to plan ahead for revised hazard classification The Health and Safety Executive (HSE) alerted users today to the fact that the hazard classification for trichloroethylene, more commonly referred to as 'trike', is in the process of being changed. It urges them to plan ahead for the tighter requirements in prevention and control measures that this could entail. Trike is used in a large number of workplaces, particularly as a powerful solvent for removing grease. It is often used in vapour degreasing tanks for the cleaning of metal parts. It is also used as a solvent in certain adhesives and chemical processes. The current human health hazard classification for trike under the EU Dangerous Substances Directive, places it in the lowest category (Category 3) of carcinogen (a substance that may cause cancer). Following recent European discussions, it was agreed that this classification be upgraded to a Category 2 carcinogen. HSE plans to implement this change in Spring 2002 (with some transitional arrangements). The effect of this reclassification will be to bring trike within the scope of tighter controls for both worker protection, through the Control of Substances Hazardous to Health (COSHH) Regulations, and the environment (the Solvent Emissions Directive). John Thompson, Head of HSE's Chemicals Policy Division, said: "I urge users to review their arrangements for working with trike, not only in the short term but in the long term as well. Don't act in haste now, or you may need to change again. Seek specialist advice if necessary. Suppliers should also start planning ahead for the change in formal hazard classification." HSE wishes to draw attention to the main factors that trike users need to consider as a result of the change. Whether trike is used as a degreasing agent or for another use you should: · Look again at the effectiveness of your prevention and control measures; · Consider using substitutes as part of your risk management strategy, but be careful not to do this in isolation. In choosing your alternative: a. take care not to choose one with a greater overall health, safety and environmental risk. Otherwise you may expose workers to high levels of a different hazard; b. ensure your degreasing tank is in good condition. Using a substitute without improving the equipment is unlikely to provide any health and safety benefit and again may even increase the risks for workers; c. ensure that plant controls, such as thermostats, are adjusted to the specific requirements of your substitute; and d. take care when replacing the solvent. In cases of deplorably bad practice, workers have died after entering degreasing tanks without breathing apparatus. If you can't clean the tank without entering it, follow current good practice. · Consider enclosing degreasing tanks as far as is reasonably practicable, particularly if you are considering upgrading anyway; · Consider your short and long-term strategy for degreasing, since any modifications also need to comply with the Solvent Emissions Directive. This is currently being transposed into UK legislation, and, along with the reclassification, means that stricter emission limits will apply to discharges of trike; · Whatever you do, consider all the options, keep abreast of developments and, if needed, seek expert advice, including your solvent or equipment supplier; · Don't go in for a knee-jerk response. Trike is not banned for degreasing operations - indeed there may be circumstances where trike is the only option. Similarly, the use of open-topped tanks for vapour degreasing has not been banned. If it is not reasonably practicable to enclose a tank, take care to operate it in accordance with current good practice. But note that over the coming years there will be increasing pressure to use an enclosed tank, whichever solvent you are using. Further useful information on good practice for vapour degreasing, and possible alternatives, is available in the free publication 'Vapour Degreasing' (ref. GG15), produced by Envirowise telephone 0800 585794 or at www.etbpp.gov.uk 1. Trichloroethylene is manufactured by several companies. The main UK manufacturer is INEOS Chlor. The main global manufacturer is the US company Dow. It is estimated that up to 10,000 workers may be exposed to trike in the UK. 2. The vote on the European Union package of classification changes took place on 25 January 2001; adoption and publication in the Official Journal of the European Communities is expected to take place around the end of June. The change will be implemented into UK law, via the Chemicals (Hazard Information and Packaging for Supply) Regulations, in Spring 2002, with a transitional period to 30 July 2002, to account for products already in the supply chain and to allow time for suppliers to reclassify and relabel. 3. Category 3 carcinogens are substances that cause concern for humans owing to possible carcinogenic effects, but in respect of which the available evidence is not adequate for making a satisfactory assessment. Category 3 carcinogens are not included in the COSHH definition of "carcinogen". Category 2 carcinogens are substances that should be regarded as if they are carcinogenic to humans. After a long scientific debate among EU scientists, Member States have now agreed that the evidence for trike justifies a Category 2 classification, based on evidence from laboratory studies in rodents and epidemiological investigations. Trike vapour, if inhaled, can also cause a range of effects, from drowsiness through to causing death at very high exposures. 4. Category 1 and 2 carcinogens are subject to the COSHH Carcinogens Approved Code of Practice (ISBN 0 7176 1670 3, ref. L5). Employers must consider whether it is reasonably practicable to prevent exposure to a carcinogen by using an alternative substance and, if not, whether it is reasonably practicable to enclose the process totally. 5. New legislation is planned by the Department for the Environment, Food and Rural Affairs to implement the Solvent Emissions Directive (1999/13/EC). This directive specifies that solvent emissions from certain processes should be controlled to a very low figure for most solvents, and lower emission limits will be imposed on solvents that are classified as Category 1 or 2 carcinogens, mutagens and reproductive toxicants. The Directive is likely to come into full operation by 2007 and will be enforced by the Environment Agency, or the Scottish Environment Protection Agency (SEPA) in Scotland. Call HSE's InfoLine, tel: 08701-545500 or write to: HSE Information Services, Caerphilly Park, Caerphilly CF83 3GG. Published on the HSE web site on 18 June 2001 As many of you will be aware, the classification of trichloroethylene (trike) is in the process of being changed to a class 2 carcinogen (see article). HSE is aware that this is likely to cause difficulties with substitution, particularly where toxicological information about alternatives may be limited. HSE is currently looking at one suggested alternative, n-propyl bromide. It is expected that this will be considered by WATCH at its meeting on 17 September 2001. We will report the outcome in future TSB editions Category 1 - substances known to be carcinogenic to humans. There is sufficient evidence to establish a causal association between human exposure to the substance and the development of cancer. Category 2 - substances that should be regarded as if they are carcinogenic to humans, for which there is sufficient evidence, based on long-term animal studies and other relevant information, to provide a strong presumption that human exposure may result in the development of cancer. Category 3 - substances that cause concern owing to possible carcinogenic effects but for which available information is not adequate to make satisfactory assessments. Categories 1 and 2, if purchased from a supplier will carry the "toxic" (T) symbol and the Risk Phrase R45 (may cause cancer) or R49 (may cause cancer by inhalation). Category 3, if purchased from a supplier carries the "harmful" (Xn) symbol and the Risk Phrase R40 (possible risk of irreversible effects). TRICHLOROETHYLENE - A CATEGORY 2 CARCINOGEN Trichloroethylene has been reclassified as a category 2 carcinogen (from category 3) by the European Union. After a long scientific debate the revised classification was agreed, based on evidence from laboratory studies and epidemiological investigations. The new classification will take effect in the UK from spring 2002 and will affect the way that trichloroethylene can be used in workplaces. For example: · there will be new labelling requirements under CHIP; · the specific requirements in COSHH on carcinogens and the Carcinogens ACoP will apply to use in the workplace; and · environmental legislation will need to comply with the Solvents Emissions Directive (which the Department for Environment, Food and Rural Affairs leads on). Taken together with the reclassification, this will mean that stricter emission limits will apply to discharges of trichloroethylene. Two common uses of trichloroethylene in the UK are in metal degreasing (particularly vapour degreasing) and as a solvent in adhesives. In general, HSE urges users to consider substitutes and enclosure, but advises against a knee jerk response: trichloroethylene is not banned for degreasing operations and nor has the use of open topped baths for vapour degreasing been banned. Metal objects often become dirty and greasy during manufacture, and solvents such as trichloroethylene can be used to clean them before further processing. As the Carcinogens ACoP recommends using enclosed systems whenever possible, firms currently using open topped baths may be considering switching to enclosed baths. Alternatively, it may be possible to substitute a different solvent in an existing vapour degreasing system. Several are available, but engineering modifications might be needed to control vapour. For example, dichloromethane is very volatile and vapour levels can rise very quickly, and some solvents are flammable. HSE is currently reviewing the possible harmful effects of one possible substitute, n-propyl bromide, aiming to provide information to users which will help control the risks from exposure to this substance. It is hoped that the review will be completed later this year. Other possibilities are to use a process which does not involve using solvents, or to prevent objects from getting dirty and only clean objects when necessary. Reducing cleaning requirements can also increase process efficiency. Each alternative will have advantages and disadvantages and you will need to look at individual processes to decide on the best alternative. But any start-up costs are often balanced by longer term savings. Some alternatives include using wet detergent processes before other wet processes such as plating or passivating. Advice on good practice for vapour degreasing and possible alternatives is available in a free publication Vapour degreasing (ref GG015) from Envirowise (the Environmental Technology Best Practice programme), tel: 0800 585794; website: www.envirowise.gov.uk Implementing an Environmental Management System (EMS) within your company is the first vital step to identifying where environmental performance can be improved and unnecessary expenditure can be saved. This Guide demonstrates how your competitors at home and overseas are taking up EMS as a business decision aimed at increasing profit and enhancing public image. Do not underestimate the demands of the job, Healtgh and safety is an all inclusive principle, it is to be integrated into the workplace within the existing mangement structure. To protect the health of the workforce it is important to evaluate solvent hazards and reliably assess workers exposure. Evaluation of personal exposure is an important step in evaluating the risks to health, enabling occupational hygienists to target measures which best control exposures. Exposure level is a result of interactions between the individual, workplace, and environmental factors. Assessment of exposure is further complicated by the fact that chemicals can be taken up into the body by both inhalation and dermal contact. Determining solvent toxicity is difficult to work out. The solvent type, routes of exposure and the temporal nature of exposure (i.e. Duration/concentration) all have an impact on the risk. Occupational exposures may involve solvent combinations or mixtures which may act additively or synergistically target organs, which further compound problems in evaluating the potential health effects.. Acute health effects, generally reversible short-term effects as well as chronic, often irreversible. High solvent exposure can lead to acute irritation of the skin eyes nose and throat, and depending on the concentration a number of central nervous system symptoms. Headaches dizziness and light headedness at low levels give way to intoxication, unconciousness and depressed respiration at higher levels. These effects are clearly important directly and indirectly since impaired judgement may cause accidents. The chronic effects of long term exposure are less well understood Cancer neurological impairments linked to song term solvent exposure. Behavioural changes have been shown in solvent exposed workers with some studies indicating increased levels of aggression and anxiety.Neurological impairment By Dr Spugeon Sept is an excellent review of neurological effects. Learning impairment, memory, tremoer, pootr lvel of coordination, reduced sensation to touch e.t.c. …Stress M*anagement n Reporting of injuries diseases and dangerous occurences Regulations 1995 Health and Safety (Consultation with employees) Regulations 1996. Legal requirement to consult employees Employers must make information available to enable emplouyees to participate fully in an deffectivelly in the health and safety consultation. Consultation involves listning to employees views and taking account of what they say before any decision is taken. It is a legal requirement for all employees to be consulted, not just informed. Where trade unions are recognised , consultation must occur through a safety representative under the safety Representatives and safety Committees regulations 1997. Successful organisations activelly encourage and support consultation. safety representatives are trainned enabling informed decisions on H&S issues.Effective consultation bodies are involved in planning, measuring and reviewing performance, as well as considering the results fo accidents, ill health and incident investigation Employees at all levelsare also involvedin a range fo activities. They set up for example performance standards, devise operating systems, procedures and instructions for risk control, oragnise incentive schemes, set up safety rulesan dhelp in monitoring and auditing. Supervisors with direct knowledge of the way work is carried out can make important contributionto the preperation of practically achieveble procedures. Oppertunities to promote involvement raises Heatlh an dsafety issues within the organisationYet short term conflict an ddisagreements are likely to arise on what constitutes a safe and healthy environment, conflicts that are liukely to resolve themselves as the workforce develops more constructive working relationships and shared objectives. Consultation Between Nuttals and employees The creation of a positive safety culture: It is recommended for the successful implementation of In oder to communicate and learn in the creation fo a safety culture consultation with the employees is essential. Employers need to be empowered with correct information to listens and respond to employees.` A health and safety policy would normally require the company to do everything that is reasonable to provide a healthy and safe workplace. This requires the workforce to obey safety rules and comply with legal requirements. The application requires communication between managers and workforce. A strong link must be forged between a safety culture and Nuttals ability to engage its workforce in meaningful discussion which go beyond statements of the policy’s intent. A safety culture is a product of individual and group values, attitudes, perceptions, competencies and patterns of behaviour which determine the style and proficiency of the organisations health and safety management. structural and cultural barriers to change To identify difficult organisational factors, H&S should establish the political/social dynamics by undertaking a sructured organisational analisys. Using defined cultural models to identify weaknesses thus H&S advisers together with managers and workers, can direct energies to achieve cultural change. The Health and Safety At Work Act 1974 The Health and Safety At Work Act 1974 imposes very strict rules on owners, partners, directors and employers. Unlike other responsibilities these obligations cannot be contracted out. The primary document that underpins all health safety in the workplace, is a coherent safety policy and procedure document. This is required to prove company policy commitment and to allow interested parties to refer to detail and audit safety management. Careful consideration of the work area can reduce risk and eliminate hazards at source. All nominated and statutory duty holders will be named and identified to allow proper regulation of the work place. The recent legislation and newer regulations require employers and staff to prove and demonstrate competance and to operate sensible measures to reduce risks or hazards. Mature companies may not be aware of the dramatic changes over the past years, and safety officers may have been promoted or moved on recently, this is not a welcome development. This can leave an obvious vacuum in terms of safety management, especially when trying to keep pace with ever increasing health and safety laws, which can be dangerous. Integarte H&S with opther management functions. Highly complex undertakings can also harbour poor communication between departments, and this can also lead to a lack of basic information and compliance to health or safety or risk assessment. Bad advice can sometimes cost a company badly needed resources, ill informed managers can at times jump to costly conclusions to save a prosecution or injury claim. Our practice can solve many of these problems for you, by identifying work related illness or disability promptly. Consideration of the relevant problems can sometimes improve productivity and improve staff morale. Improving mutual respect at the work face will be win-win situation for all persons concerned. The creation and implementation of good safety policies can reap intangible benefits for many undertakings. Good staff relations, less sickness and absenteeism can be a spin off benefit of practical safety management. The H.S.E at present is promoting the philosophy that good business can be linked to good health and safety arrangements, and we wholeheartedly endorse this ethos. The ultimate aim of P.H.&S is to help your enterprise or partnership integrate good practice at a sensible cost whilst helping you to train your staff and change their workplace for the better . To lessen the risk of prosecution or litigation we can offer you tried and tested methods to regulate and audit your operations. In time we would like to feel that your company will not need to rely on outside consultants as we steer you and your staff to a more regulated approach to safety compliance. There is not an employer in existence that can operate without risk or in a fault free manner, we feel that by risk assessing your work area and identifying hazards that can appear suddenly, you can definitely safeguard your long term well being. Bibliography:

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