COSHH beyond CLP. Presentation to. by David Osborn Chartered Occupational Safety and Health Practitioner Programme

Transcription

1 COSHH beyond CLP Presentation to by David Osborn Chartered Occupational Safety and Health Practitioner Programme 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

2 REACH / CLP Regulations An Overview 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 1 st June 2015 Implemented the United Nations Globally Harmonised System (GHS) Revised structure of Safety Data Sheets / new hazard warning pictograms. Programme 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

3 Key Changes for the COSHH Assessor EU Symbols replaced by Globally Harmonised System Key Changes for the COSHH Assessor Risk Phrases become Hazard Statements - 9 -

4 Key Changes for the COSHH Assessor 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 inhalation when 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 Key Changes for the COSHH Assessor 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 inhalation when 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

5 Key Changes for the COSHH Assessor And despite it being a Globally Harmonised System The European Union has to do its own thing as well! EU Hazard Statements e.g. :- Key Changes for the COSHH Assessor 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

6 Changes to Structure of Safety Data Sheets OLD FORMAT (CHIP) NEW FORMAT (CLP) Safety Data Sheet OLD FORMAT : (CHIP)

7 Safety Data Sheet NEW FORMAT : (CLP) Safety Data Sheet NEW FORMAT : (CLP)

8 Safety Data Sheet NEW FORMAT : (CLP) Key Changes for the COSHH Assessor 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 19 - is not sufficient (or lawful).

9 Key Changes for the COSHH Assessor 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) Programme 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

10 HSE A proportionate approach HSE A proportionate approach (COSHH ACoP)

11 HSE A proportionate approach (HSG 97) Programme 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

12 COSHH Essentials COSHH Essentials The Generic Risk Assessment Health + exposure risk control hazard potential assessment approach

13 COSHH Essentials Hazard Group A B C D E Target exposure range > ppm >5 50 ppm >0.5 5 ppm <0.5 ppm Seek specialist advice Risk phrase examples R36 (Irritating to eyes) R20 (Harmful by inhalation) R23 (Toxic by inhalation) R40 (Risk of irreversible effects) R45 (May cause cancer) COSHH Essentials Determine Hazard Group

14 COSHH Essentials Determine Hazard Group COSHH Essentials Determine Hazard Group Yet we saw : - H304 May be fatal if swallowed and enter airways Equates to Group A (Least hazardous) How can this be??? Answer: Because COSHH Essentials is primarily focused on airborne substances i.e. not ingestion

15 Programme 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 A spreadsheet, based around similar principles to COSHH Essentials But includes: A Chemical Hazard Calculator 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

16 A Chemical Hazard Calculator A Chemical Hazard Calculator

17 A Chemical Hazard Calculator Programme 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

18 HSE A proportionate approach (COSHH ACoP) Case Study : Cross Manufacturing Company (1938) Ltd Approach taken by Cross Manufacturing Company (1938) Ltd is to use the calculator in its simplest form : to classify hazard as HIGH, MEDIUM, LOW

19 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. Case Study : Cross Manufacturing Company (1938) Ltd COSHH Procedure : Definition of Hazard Rating

20 Case Study : Cross Manufacturing Company (1938) Ltd By kind permission of Mr Richard Cross (Director) COSHH Process Map Case Study : Cross Manufacturing Company (1938) Ltd Process Map:

21 Case Study : Cross Manufacturing Company (1938) Ltd Requirements of the COSHH Regulation 6(2)

22 Case Study : Cross Manufacturing Company (1938) Ltd Case Study : Cross Manufacturing Company (1938) Ltd

23 Detailed COSHH Assessment Template Case Study : Cross Manufacturing Company (1938) Ltd

24 Medium Risk Pro-Forma COSHH Assessment Sections Medium Risk Pro-Forma COSHH Assessment Sections

25 Medium Risk Pro-Forma COSHH Assessment Section 10 Case Study : Cross Manufacturing Company (1938) Ltd

26 Case Study : Cross Manufacturing Company (1938) Ltd Case Study : Cross Manufacturing Company (1938) Ltd

27 Case Study : Cross Manufacturing Company (1938) Ltd Case Study : Cross Manufacturing Company (1938) Ltd

28 COSHH Info-Card (Printed A5, double-sided, Laminated) Version issued before REACH / CLP / GHS COSHH Info-Card (Printed A5, double-sided, Laminated) Version issued after REACH / CLP / GHS

29 COSHH Info-Card (Printed A5, double-sided, Laminated) Version issued after REACH / CLP / GHS COSHH Info-Card (Printed A5, double-sided, Laminated) Version issued after REACH / CLP / GHS

30 Case Study : Cross Manufacturing Company (1938) Ltd Programme 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

31 Resources for COSHH Assessors The following resources are available via the internet at 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). The HSE have issued guidance: BREXIT REACH 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

32 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 THE END QUESTIONS / DISCUSSION