OSHCR Registered Consultant Archives - Page 9 of 10

Air sampling for exposure to solvents (toluene, xylene and similar)

If you would like to speak to one of our safety consultants or occupational hygienists about an air sampling survey for wood dusts please contact us on 01453 800100. Outsource Safety specialise in Occupational Health and Hygiene consultancy.

Xylene and toluene sampling methods

An activated charcoal badge type dosimeter was used, attached at the lapel. The badge was left exposed for a recorded period and later washed through with a solvent to extract the analyte which is then passed through a gas chromatography instrument to analyse the concentration of particular substances, in this case xylene and toluene were selected.

Xylene – Background Information

OCCUPATIONAL EXPOSURE STANDARDS

8-HOUR TWA: 100 ppm
15-MINUTE REF. PERIOD: 150 ppm
IDENTITY AND PROPERTIES
CAS No: 1330-20-7
EEC No: 601-022-00-9
Formula: C6H4(CH3)2
Synonyms: xylol, dimethylbenzene
Saturated vapour
concentration: about 8000 ppm at 20oC
Boiling point: 137-144 oC
Conversion factor: 1 ppm = 4.34 mg.m-3 at 25oC

Xylene is an aromatic hydrocarbon with a characteristic odour, perceptible at about 1 ppm. Commercial xylene is a mixture of the three xylene isomers and may contain some ethyl benzene. It is a clear, colourless, mobile, fairly volatile fluid, which is insoluble in water and miscible in other organic solvents. Xylene is classified under the CHIP 2 Regulations (1994) as harmful, to be labelled with risk (R) phrases:

R10: FLAMMABLE
R20/21: HARMFUL BY INHALATION AND IN CONTACT WITH SKIN
R38: IRRITATING TO SKIN

OCCURRENCE AND USE

Xylene is produced mainly from crude oil in the UK, but some also arises from coking processes. It is a component of petrol and hydrocarbon solvent mixtures; and is used in chemical manufacture and as a solvent. Individual isomers are raw materials for making terephthalic acid and phthalic anhydride. It is a carrier solvent for surface coatings (e.g. paints, adhesives, pesticides) supplied for commercial and domestic use.

EXPOSURE

Many thousands of workers may be potentially exposed to xylene, with more than 10 000 user-firms in the UK. Typically, exposures to xylene vapours are controlled to below 50 ppm where xylene is used as a chemical precursor and in the manufacture and use of formulated products. Higher exposures may occur in spray-painting large items, printing, and using xylene-containing products in confined spaces; in these circumstances respiratory protective equipment is worn. Short-term exposures up to 500 ppm have been reported in machine-cleaning operations.

MEASUREMENT

Long-term monitoring is performed by pumped sampling with solvent desorption or by diffusive sampling and thermal desorption {Methods for the determination of hazardous substances MDHS 66 (Rev) MIXED HYDROCARBONS (C5 TO C10) IN AIR – LABORATORY METHOD USING POROUS POLYMER DIFFUSION SAMPLERS, THERMAL DESORPTION AND GAS CHROMATOGRAPHY ISBN 0 7176 0867 0 HSE Books (1995)} and gas chromatographic determination. Measurement of the urinary metabolite methyl hippuric acid is a suitable biological indicator of uptake.

METABOLISM

Xylene vapour is rapidly absorbed through the respiratory tract. It is also absorbed by skin contact, and penetrates many materials used for protective clothing. Over 90% of the absorbed dose is metabolised and excreted in the urine as methyl hippuric acid. A small proportion (5%) is exhaled in the breath.

HEALTH EFFECTS

Animal studies

Exposure to high concentrations of xylene has been shown to cause hearing loss and enlargement of kidneys and liver, due to high metabolic demand. Toxicity to reproduction has been observed, but only at or near levels which are maternally toxic. Xylene gave negative results in carcinogenicity and various mutagenicity tests.

Human data

Minimal eye, nose and throat irritation has been reported at levels down to 100 ppm for 30 minutes, and this can also arise with brief exposures at slightly higher levels. The principal effects known in humans are on the central nervous system. Exposure at 300 ppm affected the sense of balance, caused visual disturbances and slowed reaction-times and some effects were seen at 200 ppm; but exposure to 160 ppm over 4 hours caused no significant adverse health effects. At around 700 ppm for up to 1 hour, headache, dizziness and nausea occur. The isomeric composition of xylene is not considered an important factor in its health effects.

BASIS FOR SETTING THE LIMIT

The critical health effects are irritation and central nervous system effects. The irritant effects reported at 100 ppm appear to be minimal and this was considered to be a no-effect level. In view of these irritancy effects an occupational exposure standard was set at 100 ppm (8-hour TWA). Since irritant effects can arise with even brief exposures at higher levels a short-term OES was set at 150 ppm (15-minute reference period). The limits apply to o-, m- or p- isomers of xylene, or mixtures thereof. A ‘Skin’ notation was considered appropriate to indicate the potential for absorption by this route.

Toluene – Background Information

OCCUPATIONAL EXPOSURE STANDARDS

8-HOUR TWA: 50 ppm
15-MINUTE REF. PERIOD: 150 ppm
NOTATION: SKIN
IDENTITY AND PROPERTIES
CAS No: 108-88-3
EEC No: 601-021-00-3
Formula: C6H5CH3
Synonyms: toluol, methyl benzene
Saturated vapour
concentration: about 30 000 ppm at 25oC
Boiling point: 110.6oC
Conversion factor: 1 ppm = 3.75 mg.m-3 at 25oC

Toluene is an aromatic hydrocarbon with the typical sweet/pungent odour of such substances and an odour threshold around 3 ppm. It is a clear, colourless, mobile, volatile liquid which is insoluble in water and miscible with most organic solvents. Toluene is classified under the CHIP 2 Regulations (1994) as highly flammable and harmful, to be labelled with risk (R) phrases:

R11: HIGHLY FLAMMABLE
R20: HARMFUL BY INHALATION

OCCURRENCE AND USE

Toluene occurs naturally in crude oils and is now produced by catalytic reforming of petroleum feedstocks. About 150 000 tonnes per annum are used in the UK. Toluene has widespread use in the production of a range of industrial chemicals, and as a solvent in adhesives, including rubber solutions, coatings and printing inks. It is a common component of many mixed petroleum hydrocarbon solvents.

EXPOSURE

A large number of workers are potentially exposed to toluene. Processes at which exposure to toluene is well-controlled are in the petrochemical sector; exposures are fairly well controlled in the footwear industry (adhesives), silk-screen printing, chemicals production, paint manufacture and decorating industries. In each case mean exposures are less than 15 ppm with more than 96 % of samples less than 100 ppm. Poorly controlled processes include rubber-coating, machine-cleaning, and general adhesives uses, where mean exposures range from 15 to 89 ppm with only around two thirds of samples less than 100 ppm. High short-term exposures can be experienced at liquid transfer points and during manual cleaning. There is a potential for domestic exposure from paint and adhesives.

MEASUREMENT

Short-term measurement can be performed by colorimetric detector tubes, and continuous monitoring is with meters, but these may not be selective for toluene. Long-term measurement is by pumped sampling onto charcoal with solvent desorption, {Methods for the determination of hazardous substances MDHS 36 (Rev) TOLUENE IN AIR – LABORATORY METHOD USING PUMPED CHARCOAL ADSORPTION TUBES, SOLVENT DESORPTION AND GAS CHROMATOGRAPHY ISBN 0 11 885960 9 HSE Books (1990)} or diffusive sampling with thermal or solvent desorption, {Methods for the determination of hazardous substances MDHS 40 (Rev) TOLUENE IN AIR – LABORATORY METHOD USING PUMPED POROUS POLYMER ADSORBENT TUBES, THERMAL DESORPTION AND GAS CHROMATOGRAPHY ISBN 0 11 885961 7 HSE Books (1990)} and gas chromatographic determination. Biological assessment of toluene exposure is by measuring blood-toluene at the shift-end.

METABOLISM

Toluene is readily absorbed by the respiratory tract, and is also absorbed through the skin. It is rapidly distributed, accumulating to some extent in fat and also the liver, brain and lung. Some toluene is exhaled: otherwise it is metabolised to hippuric acid and o-cresol, which are excreted in urine over an extended period.

HEALTH EFFECTS

Animal studies

Inhalation studies showed narcosis at 10 000 ppm, following central nervous system effects. In repeated studies at high exposures, kidney and liver damage occurred, with no effects at 200 ppm. It is difficult to form firm conclusions on findings that exposure to toluene may cause hearing or eyesight impairment.

IN VIVO and IN VITRO studies show toluene is unlikely to be carcinogenic or mutagenic. Toluene only showed teratogenic effects at high doses.

Human data

The principal effects are on the central nervous system with impaired reaction times and vigilance reported for exposures to 200 or 240 ppm for 3 to 7 hours, and dizziness, headache and fatigue reported following exposure at 50 to 100 ppm for 4 to 8 hours. Although longer term effects on the central nervous system have been claimed, there is no substantive evidence that they occur following repeated exposures between 50 and 200 ppm. Toluene vapour is irritating to the eyes and respiratory tract, with no effects being reported at 80 ppm. The liquid irritates the skin. There are no data on carcinogenic effects in humans.

BASIS FOR SETTING THE LIMIT

The critical health effect is upon the central nervous system. A level could be identified which was unlikely to be injurious to employees, and an occupational exposure standard was set at 50 ppm (8-hour TWA) on this basis. However, this implies a need to introduce improvements in control in some industry sectors. A short-term OES was set at 150 ppm (15-minute reference period) which would minimise short-term effects such as irritation. A ‘Skin’ notation was considered appropriate.

Posted by Roger Hart

The safety of bottled water in cars

This is a question which has been raised by some clients following a spate of emails circulating on the web. Read on to find out the opinion of our experienced safety consultants and if you have questions or need more advice please call our safety consultancy on 01453 800100.

Below is a copy of the email (in italics) which started this urban myth;

Email Subject: Drinking Bottled Water Kept in Car

…a friend whose mother recently got diagnosed with breast cancer. The doctor told her women should not drink bottled water that has been left in a car. The doctor said that the heat and the plastic of the bottle have certain chemicals that can lead to breast cancer. So please be careful and do not drink that water bottle that has been left in a car and pass this on to all the women in your life.

This information is the kind we need to know and be aware and just might save us!!!!

*The heats causes toxins from the plastic to leak into the water and they have found these toxins in breast tissue. Use a stainless steel canteen or a glass bottle when you can*!

The first alarm bell which rings here and announces this email as something which may not be 100% true is the fact that all materials containing food stuffs must pass stringent tests before being put into use.

However, there is as usual an element of truth, bottles can potentially leach endocrine disruptors into the water which they contain, in this case man made chemicals which have the potential to interfere with the production of reproductive hormones in the body – not cause cancer.

Research on this subject is in its early stages and there may not be a link – more research is needed but it is a potential concern. Some chemical leaching does take place but these are at levels which are minuscule and do not pose a threat to health. Tests have shown them to always be within the limits set within the EU and US authorities. You’re greatest risk is from microbial contamination, particular in the case of still mineral waters which will not have undergone special treatment to reduce these levels.

The bottom line is that single use water bottles are known to be safe and multiple use water bottles are also safe to the best of current knowledge. Nothing is without risk but you should not be concerned by leaving water bottles in cars but you might not want to drink the warm water anyway – unless you’re very thirsty!

Notes

Some concerns have also been raised involving reusable water bottles and the leaching of bisphenol A (BPA). You may now see a number of baby bottles boasting to be BPA free. This is potentially a concern but research continues into this to establish the actual level of risk and its true effects on the human body.

Posted by Roger Hart

Benzene in cars and other vehicles

We have completed this guidance in response to the recent spate of emails which have raised serious concerns about the levels of benzene which can building up within cars and other vehicles left in hot weather. In common with most of these types of emails there is an element of truth to this statement but what is the true story? Read on to find out.

Starting with the basics, it’s true that benzene is a toxic chemical known to produce a variety of ill health effects, including anaemia and cancer (specifically leukaemia) in humans. Benzene occurs naturally (typically as a component of crude oil) and you’ll also find it used in a range of products as a solvent (plastics, synthetic fibres, dyes, glues, detergents and drugs). It’s also a constituent of tobacco smoke and it present in petrol and petrol exhaust fumes.

Low levels of benzene are often present in outdoor air due to vehicles exhausts and industrial emissions. Vapours containing measurable levels of benzene are emitted by household products such as glues, paints, and furniture wax as products ‘gas off’. Due to this effect even higher levels of benzene can sometimes be found indoors, especially in new buildings with new fixtures and fittings.

Benzene in cars

Given the evidence above we have to conclude that dashboards, door panels, seats, and other interior components do emit benzene, as claimed in the email. In most cars these items will be made from plastics, synthetic fabrics and glues, some of which will have been manufactured using benzene may therefore “off-gas” trace amounts of benzene, particularly under hot conditions.

Scientific research

Most published studies where benzene levels have been measured inside vehicles have been done under typical driving conditions, i.e. in traffic. While such studies have found that benzene levels can significantly exceed those outside the vehicle and could pose a human health hazard, this is mainly attributed to the presence of exhaust fumes from other traffic.

Also, the amounts of benzene actually detected by researchers were significant but were far lower than the amounts that have been stated in these emails. A 2006 study reported in-vehicle benzene levels from exhaust fumes ranging from .013 mg to .56 mg per cubic meter — a far cry from the 400 mg to 4,000 mg reported.

Benzene levels in parked cars

In the one study found that took measurements of benzene levels inside parked cars with their engines turned off, the results were more benign. Toxicologists took samples of the air inside both a new and a used vehicle, under simulated hot-sunlight conditions, measuring the levels of volatile organic compounds (VOCs) including C3- and C4-alkylbenzenes, and exposing human and animal cells to the samples to determine their toxicity. Despite the detectable presence of VOCs (a total of 10.9 mg per cubic meter in the new car and 1.2 mg per cubic meter in the old car), no toxic effects were observed. Apart from noting the slight possibility that allergy-prone individuals might find their condition exacerbated by exposure to such compounds, the study concluded there is “no apparent health hazard of parked motor vehicle indoor air.”

When in doubt, ventilate

Despite this finding, some drivers may still be concerned about the presence of any benzene vapours inside their car, especially given the World Health Organization’s stated position that there is “no safe level of exposure” to the carcinogen. They may also worry that turning on the vehicle’s air conditioner might exacerbate their exposure to trapped toxins by recirculating contaminated air. If that’s the case, there’s no harm done — and much peace of mind to be gained — by simply opening the windows and ventilating the car before turning it on.

Posted by Roger Hart

Choosing a dust mask

We often have questions regarding which mask should be used and so thought a very quick summary here would be useful.

In general, filtering face masks used for dusts and similar can be categorised into three types all with an FFP number.

FFP1 for simple dusts such as nuisance and soft wood dusts
FFP2 for more hazardous dusts such as grinding, powder painting or respirable cystalline silica
FFP3 for hazardous dusts which also involve some vapours and gases which are hazardous to health (a good example here would be welding fumes)

One of the key failing when we review the use of face masks is how people wear them and you should, since November 2002 in fact, be testing the fit of these items to ensure they are effective – this is known as fit testing.

Many people do not fit masks well and do not even press the metal strip fixed around the nose of the mask to get a good seal – if a mask is to protect you this is essential. A second common error is keeping the mask at the point of work uncovered – perhaps on a work bench. This will allow the mask to collect exactly what it should be protecting you from and allow you to inhale it as soon as you use it! Always keep RPE in a sealed container or bag to prevent this type of contamination.

More information is supplied below on the new APF figures. These allow you, once occupational hygienists, such as ourselves, have completed an appropriate air sampling survey, to select an item of RPE which will adequately protect you and your staff from harm (see graphic to the right for more information). The APF is an allowance over which the mask will protect you;

For example; the allowable limit for hard and soft wood dusts is currently 5 mg per cubic metre. In your workplace an occupational hygienist such as one of our safety consultants may measure the dust level at 3 times this amount, 15 mg per m3. In that case you would need to seek an APF (assigned protection factor) of at least 3. This would put you in the typical 4-10 or 4-20 range.

One final point concerns the amount of time which a mask will last before requiring replacement, this can be summarised as follows;

For particulate (dusts) when breathing become more difficult the mask will be partially blocked and should be replaced
For gases and vapours the mask should be replaced when you detect ‘breakthrough’ i.e. when you can detect through smell or taste the item against which you should be protected be that a solvent or other substance.

As a general rule, disposable masks should be disposed of daily and reusable half face respirators should have their filters changed at least monthly.

If you would like to speak to an experienced occupational hygienist about this please contact us on 01453 800100

Posted by Roger Hart

Air sampling for exposure to isocyanate (MDI, TDI and similar isocyanates)

If you would like to speak to one of our safety consultants or occupational hygienists about an air sampling survey for isocyanate exposure please contact us on 01453 800100.

ISOcyanate air sampling method

The methods closely follows the recommendations of HSE MDHS 25/3 and the principle is as follows;

A measured volume of air is drawn through a glass fibre filter impregnated with 1-(2-methoxyphenyl) piperazine mounted in a sampler and attached in the breathing zone of the exposed worker. The Methylene Di-isocyanate (MDI) is held on the filter for subsequent High Pressure Liquid Chromatography (HPLC) analysis using ultraviolet and electrochemical detection. The results of this analysis, coupled with the flow rate and time period, enable the exposure levels to be quoted as milligrams per cubic metre (mg.m-3) for application to the exposure limit published in HSE Document EH40/2001.

ISOCYANATES

all (as -NCO)

MAXIMUM EXPOSURE LIMITS

8-HOUR TWA: 0.02mg.m-3

15-MINUTE REF. PERIOD: 0.07mg.m-3

NOTATION: SENSITISER

IDENTITY AND PROPERTIES

Isocyanate is the functional group (-NCO) which occurs in a number of substances and their reaction mixtures. The saturated vapour concentration at 25oC varies with the substance; refer to manufacturers data sheet.

Conversion factors:

di-isocyanate 1 ppm = 3.44mg.m-3 -NCO at 25oC

isocyanate 1 ppm = 1.72mg.m-3 -NCO at 25oC

Isocyanates react rapidly with all substances having ‘available hydrogen’. This includes alcohols, amines and amide groups in proteins. Isocyanates are soluble in many organic solvents and decompose at varying rates in water. Substances carrying the isocyanate group are not detectable by smell until many times the exposure limit (for example, TDI odour threshold is about 30 times the MEL).

OCCURRENCE AND USE

Organic isocyanates may arise from burning polyurethane. Only MDI is produced in the UK, by reacting methylene dianiline with phosgene in a closed process; other isocyanates are imported. About 60,000 tonnes per annum of isocyanates are used in the UK, of which about half is used for polyurethane foam, and the rest for surface coatings (paints, lacquers, inks, adhesives), foundry core binders and synthetic rubbers.

EXPOSURE

The number of persons who may be occupationally exposed to isocyanate is not known. In general, exposure can be minimised by using isocyanate prepolymers of low volatility. Control measures such as suitable extraction ventilation and use of airline breathing apparatus are needed where isocyanate aerosols or significant vapour concentrations may occur.

Exposures above 0.02 mg.m-3 isocyanate may be experienced in spray-painting large articles, with exposures briefly exceeding 0.06 mg.m-3, Respiratory protective equipment is required for these processes. In most foam plants, exposure is controlled to below 0.01 mg.m-3 isocyanate. Molten MDI can give rise to high exposures if the fume is not extracted.

MEASUREMENT

Methods based on air sampling through bubbler solutions and subsequent instrumental or colorimetric analysis are detailed in MDHS 25.

METABOLISM

The main exposure route is by inhalation of vapour, aerosol mist or dust. Isocyanate reacts rapidly with respiratory tract surfaces; its further metabolic fate is not known.

HEALTH EFFECTS (Human data)

The isocyanate group (-NCO) is the functional group which causes the adverse health effect. Heavy exposure has been associated with bronchitis. There have been numerous reports on asthma due to isocyanates, but the levels which can induce sensitisation are unknown although there are anecdotal reports suggesting that peak exposures may be important. Sensitised individuals may react with severe asthmatic symptoms at very low concentrations of isocyanate, in some cases below 0.02 ppm. The development of sensitisation may occur within months of exposure, or only after years of symptom-free exposure. Sensitisation may result in the development of bronchial hyper-reactivity, and the affected individual responds to non-specific stimuli such as cold air and exercise. In these individuals, recovery may not follow cessation of exposure. Health surveillance is appropriate. {EH 16 ISOCYANATES: TOXIC HAZARDS AND PRECAUTIONS ISBN 0 11 883581 5 HSE Books (1984)}

BASIS FOR SETTING THE LIMIT

The critical health effect of isocyanates is respiratory sensitisation and in the absence of dose-response data a no-adverse-effect level cannot be established. Consequently a maximum exposure limit was considered appropriate. This was set at 0.02 mg.m-3 (8-hour TWA) isocyanate, with a 15-minute reference period MEL set at 0.07 mg.m-3 isocyanate.

Posted by Roger Hart

CDM 2015, a quick summary

CDM 2015 regulations

It would be true to say that we rarely experience a change in regulation which causes so much speculation and conversation amongst safety professionals, designers and architects, contractors, clients and everyone else who might be involved in a construction project at some stage but CDM 2015 has done it.

Flowchart of CDM 2015

There is still a lot of confusion amongst the duty holders and so we thought we would attempt (based on the latest guidance documents) to explain how we think the regulations will work from the perspective of each duty holder from client through to contractor but if you prefer a helicopter overview take a look at or download our flowchart below;

(Important Note: this guidance is provided as is and without warranty and is based on some assumptions and draft guidance documents)

Notification of HSE (F10)
1. 2007 Regs: you are required to notify HSE should your project last more than 30 consecutive days or more than 500 person days
2. 2015 Regs; you will be required to notify HSE only if you project lasts more than 30 working days and has more than 20 people on site simultaneously or lasts more than 500 person days (add up the numbers on-site each day and the number of days, incidentally 19 persons x 26 days would be 494 person days)
  1. Note: we expect that this will reduce notifiable projects to less than one-third of their current number for larger businesses. For domestic architects the effect will be almost all projects will come under CDM 2015
  2. The duty to notify technically rests with the client under the revised regulations
Transitional arrangements
1. The regulations are set to come into force on 6th April 2015, however, for projects for which a CDM Coordinator has already been appointed at that time there is a six month transitional period where the old regulations can still be applied and the CDM Coordinator can remain in role. If this is the case you should start planning the transition now and be compliant with the new regs before 6th October 2015
Removal of the domestic client exemption
1. This was a key enabler for the change in the regulations. The UK did not apply this part of the EU directive fully and was under great pressure from the EU to do so. The regulations will now apply to all domestic work involving 2 or more contractors.
2. The client duty to also ensure that the regulations are implemented on domestic projects will pass from the client to the principal contractor. This may present the largest challenge to smaller contractors or those specialising in domestic works for new builds and extensions which up until now have been exempt. It is worthy of note that this duty stays with the designer until and unless another Principal Designer is appointed in writing.
3. These regulations “apply to ALL building projects, whether or not a person is acting in the course or furtherance of a business”
  1. Note: This is significant. Even small projects will require a safety plan albeit one which HSE expects and allows to be smaller and less detailed than a notifiable project. In truth, it is likely that these plans will follow a very similar layout to larger project plans in the absence of firm guidance on what should be included to be compliant with the new regulations. This is an area in which we can help so please contact us if you need to discuss this aspect and if you are an existing client we can supply you with a suitable template plan.
Role of the Principal Designer (replaces the CDM Coordinator Role)
1. This is now expected to be a person in the design team (architect, structural engineer, services engineer). This will typically be supported by a safety expert such as ourselves working on a framework agreement or support contract as a Principal Design Consultant, for a copy of our framework agreement and cost structure please contact us on 01453 800100 or request a callback.
  1. Role and duties;
    1. • Eliminating or controlling risk throughout the design phase;
      • Ensuring that the Principal Contractor (PC) is kept updated;
      • Ensuring that a Construction Phase Plan (CPP) is prepared;
      • Assisting the Client with the preparation of pre construction information and fulfilling their project / design brief;
      • Make certain that all designers comply with their duties to design out risk where practicable;
      • Preparing the Health and Safety file at project completion.
Role of the Client
1. A key change is that the client must set a clear brief for the project and this should set out arrangements for how health and safety will be managed. This may well be seen to include provision for audit arrangements to ensure good safety provision, risk management and welfare arrangements, another area where we can and do provide support.
2. From the regulations;
  1. “A client is required to appoint a principal designer as well as a principal contractor in any project where there is, or it is reasonably foreseeable that there will be, more than one contractor working on the project (regulation 5). Under the 2007 Regulations appointments for similar roles were required for notifiable projects.”
3. An additional role and interesting requirement placed on clients is to ensure that the Principal Designer and Contractors carry out their roles fully. How they might be able to fulfil this duty without recourse to a construction safety professional such as ourselves is questionable – we usually supported in house teams even under the 2007 regulations so a new and specific requirement makes this an area which must be addressed fully by clients from 6th April 2015
Role of the Principal Contractor
1. There are more slight modifications for the role of Principal Contractor and the role is similar to the 2007 regulations for those who previously fell into scope. The largest change will be the notification and application changes mentioned above which bring far more projects, including domestic, into the scope of the regulations for these larger contractors.
2. However, the largest impact will be faced by small and medium sized business as ALL projects must now produce a health and safety plan and produce a health and safety file regardless of the projects size
3. Smaller and repetitive projects
  1. What about small jobs which still involve more than one contractor? How could the regulations apply to maintenance works where only 2 hours are required at site for small works?
    1. Our answer; We don’t yet know how HSE will see this being managed but we can guess. Under the existing regulations repetitive works could generally be grouped together and it’s possible that HSE will allow an overall arrangement for a maintenance contract rather than insist on repeated documents which could be argued to be unreasonable. We’ll update you when we know more.
Sub-contractors and competency requirements (PQQ’s,SSIP and Approval Schemes in general)
1. The requirement for competency has been replaced with a requirement of “skills, knowledge and experience” in an apparent effort to reduce this burden
  1. Sum result: We would be amazed if this changes anything. A form of words which requires you to do much the same thing is very unlikely to have an impact on the current status quo so don’t expect CHAS, SMAS or SafeContractor requirements to be affected.
2. In support of our opinion above it is worthy of note that the PAS 91 is specifically referenced as a means of assessing pre qualification, anyone familiar with this document will know how detailed this assessment is.

Guidance and support

It’s likely that some of our guidance above will change as we learn more about the regulations and how HSE will apply them. It’s also true to say that a greater understanding will come after an unlucky few suffer FFI fines and prosecution for failures in applying the Regs. We’ll continue to keep you updated and if you want to find out a bit more detail we would recommend the CONIAC guidance which can be found below and the HSE guidance to be found here; Legal (L) Series guidance

Note:  all documents current as of time of last edit but subject to change

Posted by Roger Hart

DSEAR, do you know or don’t you?

DSEAR, the Dangerous Substances and Explosive Atmospheres Regulations – quite a mouthful and something which very few clients have addressed to the extent that they should.

If the above is true then it might come as a further surprise to you to know (or at least be reminded) that these regulations were introduced and came into force in 2002!

Their purpose is to ensure protection against risks from fire, explosion and similar events arising from dangerous substances used or present in the workplace, and also sets a minimum requirement for the protection of your workers from fire and explosion risks linked to any dangerous substances and potentially explosive atmospheres. Think blasts, fires, burns and suffocation in terms of risks which you are protecting from.

We’ve added some general requirements of the regulations below but you might want to know more from our experts, if you would like to discuss any aspect of DSEAR feel free to call us on 01453 800100 or use the contact links at the bottom of this post.

Key requirements

Assess risks and then decide how best to reduce them;
Put in place suitable procedures/ equipment to deal with the potential for accident and emergencies;
Ensure that you supply your employees with adequate information, instruction, training and supervision;
Classify your areas into zones which must then be marked and suitably protected.

Activities, processes and substances which come under DSEAR

Storage of highly flammable liquids, including petroleum spirit
Storage of flammable goods, such as paints, solvents, reagents
Storage, use and handling of flammable gases, including LPG
Use of flammable gases, such as acetylene, for cutting and welding
Handling and storage of waste dusts from woodworking operations
Handling and storage of flammable wastes including fuel oils
Hot work on tanks or drums that have contained flammable material
Work activities that could release naturally occurring methane
Use of flammable solvents in laboratories
Transport of flammable liquids in containers around the workplace

If you’ve got questions or need support on safety in the industrial, contracting or construction sectors please contact us for sensible and proportionate advice on 01453 800100

Posted by Roger Hart

Why should I outsource safety to consultants?

outsource safety will free up your business to focus on its strengths. This will benefit your business by allowing your staff to concentrate on their main tasks and on your future strategy and growth – we will work with your internal health and safety staff to support them and help them improve and develop your health & safety systems;
outsource safety will improve your efficiency and customer service. When you choose our health & safety consultants to support your internal safety professionals you are gaining the support of a highly experienced and well-connected organisation able to react quickly and flexibly to your business needs;
your business will gain a competitive advantage. Outsourcing your safety will bring flexibility to your business, turning fixed costs into variable costs and freeing up capital. It will also give your business the edge when winning new contracts against your competitors;
We have the skills and experience to support internal your safety professionals on more difficult and diverse risk issues. Areas such as COSHH risk assessments, personal exposure sampling, occupational health assessment and fire require very specific knowledge sets;
Areas which might not affect your business day to day still need to be tackled, for example, an extension which comes under the CDM Regulations will require a CDM support but you do not have the skillset required in house. We have specialists who will work with you and provide a full CDM service

Outsource Safety

It may be tempting to rush into outsourcing, but take the time to meet with one of our health & safety consultants and talk through what you need, we don’t use sales people so the person you meet will be your dedicated contact and retained health & safety consultant.

Consider the following:

Concentrate on your core strengths and not those which are secondary to your success.
Consider the true costs of handling it in-house. Include hidden costs such as office space, training, company cars, recruitment, holidays and so on.
Check the return on investment (ROI) – we can help you to calculate exactly how much you could save whilst getting a better service.
Consider the effects of a temporary downturn – you could have high employment costs when you could be only paying for what you actually need.
What are the costs of not outsourcing? Will your business suffer because it cannot afford to invest in the expertise or the facilities that we can provide? Perhaps your competitors are already outsourcing these roles.
What are the costs of developing new skills sets to cover areas like COSHH risk assessment, CDM Principal Designer duties and Occupational Health requirements?

If you’ve got questions or need support on safety in the industrial, contracting or construction sectors please contact us for sensible and proportionate advice on 01453 800100

Posted by Roger Hart

COSHH – Material Safety Data Sheet (MSDS) – a guide

Introduction

You may have noticed these documents floating in on top of a box of items which arrive at your premises or you may be familiar with them from past risk assessments. The truth as to why they’re there is that they’re required by law.

They are the information on which any COSHH risk assessment is based and manufacturers and suppliers are bound by law to make the information contained in them available so that we all have the information needed to decide how best to protect ourselves and others from the substances we use. They’re also useful for comparing a couple of alternative substances and choosing which one is least harmful.

What do I need to know?

One thing which we don’t need to tell you is just how much information is contained in an MSDS – this is where most people say “I must get around to looking at that sometime soon” and nothing much more happens. The truth is that you only need look for some key phrases and in just a few of the 16 sections which make up an MSDS.

Just the facts please!

Think about what questions you need answering;

What are the dangers with using this substance?
What protection do I need to use?
What if an accident occurs, what would my actions be?
What if someone spills this substance, what would I need to do?

It’s all in there…somewhere

Check through the sections, using 1-4 above, this is where you need to look;

Hazards identification – is it corrosive, irritant, harmful?
Exposure controls / personal protection – what PPE do I need to specify?
First aid measures – eye contact, skin contact and so on, its all there.
Handling and storage and disposal considerations – check these two sections for the answers you need.

I think I might give it a go!

Good for you! Bear in mind that your first one will be the hardest. Once you’ve found your feet you’ll be reviewing them in no time.

But what do I do with all this information?

You need to create a COSHH risk assessment. This need not be a lengthy document and it can be simply a part of the risk assessment you complete for a whole task. For example, if you are being exposed to solvent based paints as part of a job which involves painting there’s nothing wrong with completing an assessment which accounts for the whole process – manual handling, fire, sips and trips and so on – COSHH assessment is just a component part. In fact, it might be better way to approach it.

Never mind the quality, feel the width!

Avoid the temptation to bulk out assessments, they won’t be read by the people who use the substance. Keep you risk assessment factual and short.

I could do this but I just don’t have the time and resources

That’s why we’re here! If you need some help over the telephone just call us, there’s no charge. If you would like your consultant to visit and guide you through some of the more difficult ones please let us know as this can also be arranged. Alternatively, if you’d like a specialist from C&G to review everything for you and complete all of your risk assessments for a fixed cost we’d be happy to visit and quote you, just call us on 01453 800100 or visit our contact us page.

Right, I’ve finished. Now what do I do with all these MSDS Sheets?

Keep them on file. Every year or two its good to update them but their most important use is for when you have questions again – this could be when a work process changes. Plus, make sure they’re to hand in case of an accident so you can send a copy with the injured party to inform the medical staff of what exactly has been injected, ingested or inhaled.

Any more questions?

If you have unanswered questions please call one of our safety consultants. We’re here to help on 01453 800100.

Posted by Roger Hart

COSHH Risk Assessments | Do they apply to your business?

Only if you use chemicals in your workplace. Things like washing up liquid and bleach don’t need assessing but your staff should still be informed of the correct way to use them.

Assessment is the responsibility of the employer. Persons preparing the assessment will need to have access to, and understand, COSHH related legislation, Codes of Practice and published guidance. They will need to be competent to carry through the work of assessment and consult with the workforce and inform them of results accordingly.

Assessment is a step-by-step approach: Identify what hazards there are then evaluate the risks to people. For significant risks, decide on the action needed to remove or reduce them to insignificant levels.

COSHH Risk Assessments | Do they apply to your business?

COSHH risk assessments need to meet the requirements of The Control of Substances Hazardous to Health Regulations 2002. So, in simple terms, your risk assessments need to be completed in ‘Sections’ ensure that you meet the requirements.

These may be broken down as follows:-

Date of assessment and review date – You should always have a review date even if the substance or method of using it isn’t going to change.
The Substance name, and a description of the process in which the substance is used.
You also need to list the hazardous properties of the substance, and any information on the possible health effects of using it.
A simple statement of the level, type and duration of exposure to the substance, and any relevant Occupational Exposure Standards should be included.
You need to show how effective is your use of the preventative and control measures that you have put into place.
If you use chemicals that could cause sensitisation or irritation to the skin, or substances that can be breathed into the lungs, or can be absorbed through the skin then some form of Health Surveillance will need to be carried out. You will need to detail the type and results of this surveillance which could take the form of questionnaires as well as biological monitoring.
If you use higher risk substances such as isocyanates or chromate based paints then the results of biological monitoring should be available for inspection by the Health & Safety Executive and it should be stated in the assessment that this is the case and you must retain these records for at least 30 years.
If you use substances in combination then the risk presented by the mixture should be stated.
Explain also how you will address the issues of Information, Instruction and Training for persons exposed.

Finally, all employees should read and understand the details of the risk assessments. All employees should receive instruction in relation to the substance involved and to the work processes in which it is used from a competent person. Employees could, for example, attend a suitable awareness course related to the substances, the hazards to which they give rise to, and the preventative and control measures necessary for their protection. The proper fitting, use and care of PPE should be included in the content of this training as should relevant emergency measures such as fire fighting, spill control, and the recognition of symptoms related to exposure and first aid measures.

A record should be kept to this effect in the personnel file for the employees concerned Instruction and training should be reviewed annually or whenever the risk changes and records re?made.

As always, if you have questions related to specific COSHH assessments please call one of our safety consultants for advice and support on 01453 800100.

If you’ve got questions or need support on safety in the industrial, contracting or construction sectors please contact us for sensible and proportionate advice on 01453 800 100

Posted by Roger Hart

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