Health and Safety
Executive / Commission
Toxic Substances Bulletin
On behalf of all the editorial team, and contributors to TSB, I would like to wish you a happy New Year and welcome you to the first Internet-only version. We hope that the transition will broaden readership of TSB and that we will continue to retain our dedicated readership.
This edition includes a transcript of an interview I did, just before Christmas, with Sandra Caldwell who is Head of HSE's Health Directorate and Chair of the Health and Safety Commission's Advisory Committee on Toxic Substances. The message I took away from our meeting was that those involved in chemical regulation are living in 'interesting times'.
HSE's efforts to achieve real improvements in worker health and safety are being centred around the new priority programmes we mentioned in TSB46, which HSC has published in its new Strategic Plan.
It seems clear that action needs to be taken, where chemicals and other substances are affecting workers' health, to make sure proper controls are in place. The challenge is to ensure that the proper priorities are being tackled, and to do this effectively we need to have good knowledge about who is actually being exposed to what in the workplace.
This is one of the biggest challenges for those concerned with the regulation of toxic substances in the workplace, in this country, the EU, and worldwide. Anyone who can contribute to the debate on how the UK might best respond to this challenge is invited to write to TSB with ideas, views or comment (e-mail: crau@hse.gsi.gov.uk ).
December 2001
TSB readers are invited to try out our new interactive version of COSHH Essentials by going to www.coshh-essentials.org.uk, which is expected to go online from the end of February. All we ask in return is that you let us have your thoughts on the system and we will take these on board when developing phase II. We would also like to hear about any problems you experience in accessing the site. Plans are currently being drawn up for the official launch in April 2002.
The electronic version of COSHH Essentials takes the effort out of following the risk assessment process by automatically working out how hazardous a substance is and giving you the appropriate control strategy to follow - with online help at every stage. The appropriate guidance sheets and further action required can be printed off for your records (as pdf files).
By using a unique reference number, the assessment can be revisited within 30 days if you wish to make any changes to it, eg using a substitute chemical or changing the process. After 30 days all assessments will be deleted from the system and you will need to input the information again.
Please let us know what you think on coshh-essentials@hse.gsi.gov.uk
HSE's five-year asbestos campaign was launched in October with a series of roadshows held in partnership with the British Institute of Occupational Hygienists across the country. The campaign aims to raise awareness of the new duty to manage the risks from asbestos in existing buildings.
Further information on the campaign can be found at www.hse.gov.uk/asbestos/index.htm - including an open invitation to become a partner and join the campaign.
And don't forget to respond soon to CD 176, which asks your opinion on the revised proposals for amendments to the Control of Asbestos at Work Regulations and a new supporting Approved Code of Practice. The CD closes on 19 February.
HSC has agreed a package of measures on occupational asthma, aimed at reducing the cases of asthma caused by substances at work by 30% over the next nine years.
Occupational asthma is the most frequently diagnosed respiratory disease in Great Britain, with 1500 - 3000 people developing occupational asthma each year. Some sufferers become so disabled that they never work again. Many have to change jobs, can no longer use specialist skills and face a restricted lifestyle.
HSE will only achieve the target reduction by working together with other organisations. A project board has been set up with members from industry, unions, charities involved with asthma and health professionals. This will be meeting in January to develop and start implementing a joint action plan which will be published in summer 2002.
HSE's contribution to the plan will include:
If you would like more information about this plan and how you can help reduce occupational asthma, please contact us via the TSB feedback form or CRAU@hse.gsi.gov.uk
A new CD called Proposals for the Dangerous Substances and Explosive Atmospheres Regulations will be available from late January/early February 2002.
It is consulting on the implementation of the safety aspects of Directive 98/24/EC on the protection of the health and safety of workers from risks related to chemical agents at work (the Chemical Agents Directive - CAD) and Directive 1999/92/EC on minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres (also known as ATEX 137).
The CD will be available on the CAD/ATEX website at www.hse.gov.uk/spd/noframes/spdatex.htm, with paper copies available from HSE Books.
As foreseen in TSB45, Chemical Hazard Alert Notices (CHANs) were issued in June 2001 for Bacterial alpha amylase, Fungal alpha amylase and Subtilisins, along with one for Piperazine and piperazine dihydrochloride. A CHAN has also now been issued for Sulphuric acid mist, and another for n-Propyl bromide (1-bromopropane) is due to be issued in January 2002.
As chlorobenzene, phenol, hydrogen selenide, and piperazine and pirerazine dihydrochloride will have MELs from the start of 2002, CHANs for these substances will be withdrawn.
EH40 lists all the current UK occupational exposure limits (OELs) for hazardous substances that are potential contaminants in workplace air. It includes changes arising from the work programme of the Advisory Committee on Toxic Substances and its Working Group on the Assessment of Toxic Chemicals (WATCH).
The Health and Safety Commission, in September 2001, approved the latest list of OELs including substances in the 1st Indicative Occupational Exposure Limit Values (IOELV) Directive and domestic OELs for hydrogen sulphide, dichloromethane and piperazine dihydrochloride.
EH40/2002 was published on 31 December 2001 and with its publication HSE will implement the 1st IOELV Directive.
EH40/2002 is a fully revised edition, in a similar format to EH40/2000. It is a stand-alone publication as opposed to EH40/2001 which was used in conjunction with EH40/2000 (the latter providing much of the supporting guidance). It comprises updated Tables 1-4 of EH40/2001 and a revision of supporting guidance in EH40/2000.
For further information on EH40/2002 please contact: Ravi Govin, Health Directorate, HSE at: 6SW, Rose Court, 2 Southwark Bridge, London SE1 9HS, e-mail: ravi.govindaradjalou@hse.gsi.gov.uk
EH64 Summary Criteria for Occupational Exposure Limits are prepared from the data considered by ACTS and WATCH when decisions are made on occupational exposure limits for specific substances.
The EH64 summaries provide useful background information on the hazards of the substances, current use and exposure patterns, analytical techniques and the reasons why particular exposure limits have been set.
EH64 is due to be published in April 2002. The summaries published include criteria for all of the substances in the 1st IOELV Directive which came into force on publication of EH40/2002 on 31 December 2001.
For further information on EH64 please contact: Paul Hems, Health Directorate, HSE at: 6SW, Rose Court, 2 Southwark Bridge, London SE1 9HS, e-mail: paul.hems@hse.gsi.gov.uk
HSE has published new training guidance to help cut the cost of work-related accidents and ill health.
Employers have a legal and moral responsibility for the health and safety of their workforce - and effective training throughout the organisation is central to this. This new guidance is designed to help employers and trainers need to meet their health and safety responsibilities effectively - and to avoid the considerable cost of not doing so.
The free leaflet Health and safety training - what you need to know (INDG 345) provides pointers to employers about who needs health and safety training, how training can be delivered, brief guidance on the law and advice about where to find further information.
Effective health and safety training: a trainer's resource pack (ISBN 0 7176 2109 X, cost £21.95) helps you decide who needs training, your training priorities and what training methods to use. It also includes advice on the successful delivery of training, eg getting people involved and tailoring training to your organisation and checking that training is working.
Blood-borne viruses in the workplace: guidance for employers and employees (INDG342) is a leaflet is aimed at employers, employees and safety representatives in areas of work where exposure to blood or other body fluids may occur. It explains what blood-borne viruses (BBVs) are; the type of work where exposure to BBVs may occur; how BBVs are spread; the legal duties of employers and employees; what action to take after infection with a BBV and special considerations for first-aiders. It also provides a detailed further reading list.
The regulatory requirements for medical exposure to ionising radiation: an employer's overview (ISBN 0 7176 2134 0, cost £6.50) is aimed at senior managers, including directors and clinicians, within the medical sector. This includes chief executives of hospitals and other medical users of ionising radiation, such as chiropractors and dentists. It gives an overview of their responsibilities under ionising radiation protection regulations to manage the use of radiation in the workplace.
New editions of various leaflets have also been placed in the Free leaflets section of the HSE website, which can be accessed from the home page or on www.hse.gov.uk/pubns/hazards.htm. We have chosen some relevant leaflets to feature here.
www.hse.gov.uk/pubns/engindex.htm
Metal working fluids can cause dermatitis and (where mists and aerosols are present) respiratory complaints. These two
free leaflets contain advice on working with metal working fluids and setting up a health surveillance programme.
Metalworking fluids and you (INDG 169)
This leaflet is aimed at employees and contains information on when metal working fluids can be harmful, how they can
affect health and good practice when using metal working fluids and health checks.
Health surveillance programmes for employees exposed to metalworking fluids: Guidance
for the responsible person (INDG165)
It can be difficult to know where to start when setting up a health surveillance programme. This leaflet is designed
to help. It contains advice on signs of skins and breathing problems, record keeping and confidentiality and contains
questionnaires which can be used as part of the screening system.
TSB interviews Sandra Caldwell, Director of HSE's Health Directorate
Sandra Caldwell was appointed Director of Health Directorate two years ago when she took over responsibility for a range of activities on health risks at work - from Securing Health Together to chemicals and pesticides, noise and vibration, pathogens, radiation, manual handling, stress and smoking. TSB talked to Sandra about how she sees things developing in respect of chemical regulation.
TSB: What were your first priorities when you inherited the Health Directorate?
SC:
On the chemical side, I wanted to look across our responsibilities for chemicals to see how we might have a bigger impact on reducing the number of people being made ill by chemicals at work.
In order to achieve this, I think we must move away from the traditional ways of doing things and use the same types of innovative thinking that we have been applying to other challenges such as stress. We have recently completed a review of our activities. This will help us develop an overall chemical strategy and determine priorities which in turn will direct our effort on delivering and achieving real changes in the workplace.
Revitalising and Securing Health Together strategies have provided the spur for us to look at how we tackle old, hard problems such as occupational asthma. After consultation, we have decided to target particular action at asthmagens in specific industries, for example isocyanates in spray paints, as just a few substances cause the vast majority of asthma in the workplace.
Equally, asbestos continues to be a serious cause of concern. That is why we are introducing a new duty to manage the risk from asbestos in premises so that maintenance workers will be aware of the need to take steps to make sure they are not exposed to a silent but deadly legacy from the past.
We also have to make sure we continue to deliver our statutory functions - negotiating and delivering EU directives, managing the statutory biocide regimes and keeping an eye on European developments such as the EU Chemical Strategy.
TSB: One of the priority areas in Revitalising is helping small firms. How are you responding to this challenge?
SC:
You are right, this is a challenge, and an important one for us and for others in the health and safety system. Being able to get the right messages across to the right people in the right way is the key. There are many firms with different types of cultures which we must accept need different approaches. We are doing work to help us understand how we might respond.
For example, we need to look at ways to help firms improve the dissemination of messages in largely oral cultures. Our research tells us that they want clear, specific advice on what they need to do to obey the law, as general advice in leaflets can be difficult to interpret and apply to their workplace.
I see electronic products becoming increasingly important as time goes on and more people access the Internet. This is an important and powerful tool which we need to use to best effect.
Already we have been working to develop products for both inspectors and small firms to ensure the right controls are in place - the new, electronic COSHH Essentials which will be launched in April, and we are working on a new scheme which brings health, safety and environmental advice together. This new approach brings together advice from different parts of HSE and the Environment Agency in one simple package, which will make it easier for small firms to find and apply what they need to know.
TSB: How is what you are trying to do affected by Europe?
SC:
We have recently had to work hard on negotiating and implementing a variety of European directives - examples are the Indicative Occupational Exposure Limit Value Directives, Dangerous Substances and Preparations Directives, Safety Data Sheets Directive and Chemical Agents Directive.
But chemicals are not just a UK/Europe issue - they are international. We try to punch above our weight in a number of ways. To do this, we are trying to avoid duplicating work already being carried out in Europe to free our resources for other work, for example we have helped to develop the new Global Harmonisation System of chemical labelling.
As this work is now drawing to a close, we are moving resources to considering the EU Chemical Strategy. It is becoming evident that this new strategy will have a significant impact on the UK in the medium/long term.
TSB: So how is HSE's work changing as a result of all these influences?
SC:
We have already started to re-direct our efforts in various areas - for example, many occupational exposure limits (OELs) are now beginning statutorily set in Europe. It makes sense therefore to influence this process which will result in less having to be done domestically.
The Health and Safety Commission's Advisory Committee on Toxic Substances (ACTS) intends to use this opportunity to become more proactive and contribute more directly to reducing ill health in the work place - for example focusing strategy on vulnerable groups, and looking at the current system of setting OELs to make it more effective.
ACTS are publishing a discussion document on the OEL framework in the new year. In future years, evolution will continue until we have succeeded in eliminating what are unfortunately still common workplace illnesses - for example, dermatitis and respiratory illness.
11 December 2001
In TSB45, we reported that the European Commission (EC) had published a White Paper for a Strategy for a future chemicals policy (the full text can be found at www.Europa.eu.int/comm/environment/chemicals/whitepaper.htm). This update describes current progress with the White Paper proposals and expected developments over the next six months.
The Strategy resulted from an EC review of four pieces of EC chemical legislation that currently form the basis for identifying chemical hazards and risks to human health and the environment:
The resulting new Chemicals Strategy aims to establish a single system for reducing risks to the environment and human health. In this system, industry will prepare risk assessments and provide safety information to downstream users (chemical users down the supply chain) and substances will be subject to a new regime, REACH (the Registration, Evaluation, and Authorisation of Chemicals).
REACH will include:
Other recommendations include:
The Environment Council Working Group discussed these proposals in April and May 2001. The Environment Council adopted its conclusions on the future EU Chemicals Policy on 7 June (available at: http://eu2001.se/eu2001/news/news_read.asp?iInformationID=15701)
The Environment Council conclusions called upon the EC to present its main proposals for a regulatory framework to implement the Strategy by the end of 2001 and in October 2001 the EC began a series of targeted working groups to develop thinking on certain issues in the new Chemicals Strategy. These included authorisation, risk assessment, classification and labelling.
The outcomes of these working groups are expected by spring 2002 and will be used by the EC in developing its regulatory proposals for the new Chemicals Strategy.
The Department of Food and Rural Affairs (DEFRA) has the lead for the UK on the Chemical Strategy. HSE has worked closely with DEFRA, in particular providing support on areas that are relevant to occupational health. HSE and DEFRA, together with the Department of Trade and Industry, are currently participating in the EC working groups.
One aspect of the Government's Securing health together (SH2) strategy is sharing ideas on successful systems which help reduce workplace exposure to harmful health risks. HSC's Ionising Radiations Advisory Committee (IRAC) recently established a small working group to review how the radiation protection community could contribute to SH2.
They concluded that, as the current regulatory system had achieved marked reductions in individual doses from exposure to ionising radiation, there was unlikely to be scope for setting targets to reduce exposure further (except for exposure to radon in the workplace).
But a way to contribute to the overall goals of the strategy might be to form partnerships with other major hazard areas, such as chemicals. A cross-fertilisation of ideas, such as sharing the radiation community's experience of principles, might reap benefits.
One of these successful principles is known in the UK as the ALARP principle. Radiation protection legislation (The Ionising Radiations Regulations, 1985 and 1999) has placed particular emphasis on the requirement to keep exposures as low as reasonably practicable (ALARP), and not merely below prescribed dose limits. As with COSHH, employers need to follow a hierarchy of control measures which, in the first instance, seek to control the risk at source.
The greatest contribution to reducing exposure to ionising radiation in the UK has been the integration of the ALARP approach into the design of a project at the earliest conceptual stage.
ALARP also appears in the form of 'as low as is reasonably achievable', taking into account economic and social factors, when it is known as ALARA. This has been one of the key aspects of the internationally recognised system of radiological protection since at least the 1970s.
ALARA was introduced by the International Commission on Radiological Protection because of the incomplete evidence on which the risk values were based and the concern that there was no threshold below which there was zero risk. It is recommended that every effort should be made to reduce exposure to all types of ionising radiation to the lowest possible level.
In the Ionising Radiations Regulations 1999, the emphasis on restricting exposure is reinforced by a requirement on the employer to carry out an investigation if an employee receives a dose in excess of a specified investigation level. The investigation level must not exceed three quarters of the prescribed dose limit and HSE encourages employers to establish lower values, where appropriate.
The purpose of the investigation is to determine whether or not the exposure of groups or individuals engaged in similar tasks is being properly controlled to a level which is ALARP. Investigation levels have been instrumental in the marked reduction in occupational doses over the last 15 years. (See Central Dose Index of Information Summary Statistics for 1999.)
Employers are required to provide specific arrangements for the management of radiation protection. (See Approved Code of Practice Work with ionising radiation, L121.)
Management arrangements include the provision of competent advice from a qualified expert (a radiation protection adviser - RPA) and the adequate supervision of particular high-risk areas by a radiation protection supervisor (RPS). The employer needs to ensure an RPA is competent and suitable. Competence is defined in the HSE Statement on Radiation Protection Advisers
One of the ways in which RPAs have assisted employers has been advising them on how to develop and implement a radiation protection programme which encompasses the ALARP approach. Once this is established, the RPA can assist with auditing the programme to check its effectiveness.
The RPS has a crucial role in helping to ensure that the employer's arrangements comply with the legislation. In particular, they have a supervisory function to ensure that those employees who work in high-risk areas follow the key working instructions designed to reduce exposure ALARP.
HSE has produced guidance on the role of the RPS and training and competence requirements in the information sheet Radiation Protection Supervisors (IRIS 6), also available on the HSE website at www.hse.gov.uk/pubns/irp6.pdf
Significant reduction in radiation exposure can be obtained through sound management systems. However, this needs employers to adopt a systematic approach to the application and implementation of ALARP and requires commitment from senior management and all the workforce. Further information is available in the HSE guidance Successful health and safety management (HSG65), which is appropriate to all types of hazard and risk.
The Chief Scientific Adviser, then Sir Robert May, first published Guidelines on the use of scientific advice in policy making (also known as the May Guidelines) in March 1997. He recognised the increasingly influential role of science in contributing to the formulation of UK and international policy and regulatory decisions, particularly on sensitive issues involving people's health and safety and the environment.
To help ensure a consistent approach to these issues, the Guidelines set out some key principles applying to the use and presentation of scientific advice in policy making. It would be for individual departments and agencies to determine how these should apply in detail, but they would typically be relevant to cases where there was significant scientific uncertainty, a range of scientific opinion and potentially significant implications for sensitive areas of public policy.
A revised and extended version of the Guidelines was published in July 2000. Guidelines 2000 takes account of experience in operating the original Guidelines and the response to a public consultation exercise. Its key messages are to:
A quality statement has been drawn up by HSE's Chief Scientist to secure the effective implementation of Guidelines 2000 across HSE. This sets out the roles and responsibilities of all staff, especially policy makers and scientific advisers, identifies competences and training needs and defines an audit process for ensuring compliance.
The Government has recognised that in many cases the 'best' sources of advice will be its independent scientific advisory committees. The 2000 White Paper on Science and Innovation, Excellence and opportunity, announced that Guidelines 2000 would be underpinned by a Code of Practice which all scientific advisory committees would follow. A first draft of this Code was published alongside the White Paper and it was finalised in December 2001.
The publication of Guidelines 2000 and the Code of Practice reflect Government recognition of the need for a significant change in its approach to the handling of science. The following important principles have been developed which departments, their scientific advisory committees and other public bodies are required to implement:
The Government publications discussed in this article are available on the BERR web site.
www.newscientist.com
Just to prove we are not afraid of the competition, our first featured site is New Scientist.
Seriously, this site is great, especially the hot topics section where a series of articles on a topic are referenced. It even has a list of other sites to visit on masses of interesting topics.
www.netregs.gov.uk
NetRegs is a pilot site containing clear simple advice on environmental legislation for manufacturing and service sectors
in England and Wales, written by the Environment Agency and launched in October 2001.
It will explain how environmental legislation applies to specific industries and what firms need to do to comply. Some specific advice is still being written, but it already contains useful information. Users can help themselves keep up-to-date with the latest information by registering at the site for regular e-mailed alerts.
www.cdc.gov/niosh/homepage.html
NIOSH also has a site packed with information. There is an index of many topics - for example, on reproductive health
and the hazards of firefighting - and links to some very useful databases. It includes databases containing information
on specific chemicals, for example international safety cards, analytical methods and selection of appropriate protective
clothing for specific chemicals.
Like many specialist publications, TSB can fall into the trap of using jargon. We have a glossary section for abbreviations, but this doesn't explain everything! This occasional series is intended to explain some terms we often use. If there are any terms that puzzle you, please use the feedback form and we will try our best to explain ourselves.
COSHH requires employers to carry out a risk assessment when using 'substances hazardous to health'. Most hazardous substances can be identified by warnings on their labels. For example, bleach is a hazardous substance and has a warning label but domestic washing up liquid is not hazardous and does not.
Other substances such as bacteria or natural products might be hazardous in certain circumstances. These are some examples of unexpected hazards:
But there are some exceptions. Asbestos and lead are hazardous but have separate regulations, and risks outside an employer's control, eg catching a cold from a workmate, are not covered by COSHH.
Health surveillance means regularly examining workers exposed to a health risk at work to see if there are any warning signs that it is starting to make workers ill. The first step is to decide whether it is necessary at all.
You need to carry out health surveillance under COSHH if you are undertaking a process specified in the COSHH Regulations (Schedule 6) or if:
Such health effects include asthma (anything labelled R42), dermatitis (anything labelled R43) and cancer (as required by the carcinogen ACoP). At its simplest, health surveillance may be a written record of the fact that someone has been exposed to a substance (as described in Appendix 1 of the COSHH ACoP), but it may need to include medical records.
The effect of exposure to substances can depend on how long workers are exposed to the substance - some effects occur rapidly, some occur after long or accumulated exposure.
Exposure limits are expressed as airborne concentrations over a specified period of time. There are two reference times used when setting limits - 15 minutes for short-term exposure and 8 hours which covers a full working shift.
In general, a short-term limit is set to control a short, peak exposure. One example could be transferring liquids between containers. While doing this, vapours in the air would increase, perhaps to above the exposure limit. But if there is no other exposure during the shift, the average concentration would be below the exposure limit over the full shift.
Short-term limits are used to control these types of peak exposure if a high concentration of substance for a short period of time could cause a health effect.
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You can contact TSB at CRAU@hse.gsi.gov.uk or via the TSB feedback form