Is your organisation aware of all the chemicals in your workplace? Do your safety leaders understand the potentially harmful effects they can have? Is the relevant protection, control measures and PPE in place to safeguard your business and employees?
If your business means that you use any of these substances, you need to comply with The Control of Substances Hazardous to Health regulations (COSHH).
- Cleaning products
- Oils or lubricants
- Paints and adhesives
- Biological agents
- Dusts and fumes
These regulations in the UK govern the use of hazardous substances in the workplace and requires employers to conduct a formal risk assessment for any exposure to a hazardous substance in the working environment.
Chemical management can be a niche or challenging area of health and safety; however, it’s important to understand and identify the risks so that your organisation can:
- Maintain the health and safety of your workforce
- Make sure that your team feels protected and valued
- Protect your reputation
- Reduce the prospect of financial penalties
- Build a commercial advantage
When it comes to COSHH risk assessments, organisations are required by the Registration, Evaluation, Authorisation and restriction of Chemicals (REACH) regulation to complete Safety Data Sheets (SDS) for each hazardous product in use. This includes all of the information about a substance, its hazards and how to handle, store and emergency measures in case of accident.
But, just how accurate is the information recorded in an SDS? Worryingly, analysis conducted by Alcumus found that nearly 40% of materials have the wrong classification, increasing the safety and financial risks to an organisation.
This error was also uncovered by an EU-wide Forum enforcement project that found significant non-compliance in the classification and labelling of mixtures:
- 43% of companies had at least one non-compliance
- 44% of reported mixtures were non-compliant in some way
Whether this is a result of an SDS being written based on superseded regulations, time pressures, lack of company resources or an absence of training, organisations need to do more to make sure that writing an SDS is much more than a box ticking exercise if they are to reduce the health and safety risk to employees and wider public.
If not, then inaccurate data means inappropriate controls that could lead to your organisation using the wrong safer substitutes, personal protective equipment (PPE) or inefficient health and safety measures. All of these could potentially put the user of the hazardous substance in danger and cause financial implications for the business.
If the chemical management software system that you use does not have the capability to re-calculate the SDS classification and takes your given classification at face value, is that a risk you’re willing to take?
SDS best practice
As a result of our in-house specialists challenging the quality of the chemical data received from the material’s manufacturer, Alcumus is able to produce a better, more accurate COSHH assessment for clients.
Our COSHH expert, Mike Harris, explains how this works:
- SDS Hygiene: We analyse the constituents of a material as its declared in the SDS and calculate what the classification should be, which can be contrary to the initial SDS classification.
- SDS Management: We store the SDS in our database to provide an audit trail to help show how the assessment was calculated. Where we have disagreed with the classification in the SDS, we explicitly declare on the assessment that our finding is based upon our classification and not that in the SDS.
Here’s just one example of an SDS that does not show a significant health risk:
- Sadolin Classic contains a substance called Butanone oxime at less than or equal to 0.3% according to the data sheet from 2017.
- Butanone oxime was previously a Category 2 carcinogen, so would not be classified for suspected carcinogenicity at concentrations less than 1%. Recent legally binding changes to classification for this substance (15th ATP to the CLP Regulations) now means this is a confirmed human carcinogen (Category 1B) which means substances containing 0.1% or greater of Butanone oxime are classified as carcinogenic.
- Since the most recent SDS for Sadolin Classic was created before the legislation change, it still classifies it as non-carcinogenic. The Alcumus software uses the latest legislation and so correctly classifies it as a confirmed human carcinogen with significant impact on the required control measures for this assessment
Our in-house, qualified chemical specialists, recommend the following guidelines depending on the level of risk:
- Annual review of high risk substances
- Three year review of medium risk substances
- Five year review of low risk substances
You should also review your COSHH assessments outside these best practice time periods when:
- A new safety data sheet is received
- A process changes or following technological development
- An accident or incident occurs
- Someone feels ill whilst using the product
- Maintenance demonstrates a failure of control measures
- A safer substitute is found
Our technology, 900,000 pre-written, compliant COSHH risk assessments and in-house, qualified chemical specialists have helped businesses to protect their people and comply with COSHH and global legislation for more than 40 years. Find out more about our chemical management software and services here: www.alcumus.com/en-gb/coshh/