Health and Safety
Executive / Commission
Toxic Substances Bulletin
Issue 48, and the end of my second year as editor of TSB. Unfortunately it will also be my last, as I will be moving on to other work in HSE managing the Priority Stress Programme. I am sure that many of our readers will also have an interest in psychosocial issues as well as physical chemical health and safety and will be observing the development of new management standards for stress with interest.
The past two years have been very interesting for me and I have enjoyed my involvement in the work to bring a new focus to chemical health and safety issues. The recent publication of the ACTS Discussion Document on the future of the OEL Framework is an exciting culmination of a lot of hard work by people in HSE and by members of the Health and Safety Commission's Advisory Committee on Toxic Substances.
We have included a short interview with one of the Members of ACTS to get a personal view on the development of this work. Although the view is one from a Member nominated by the CBI, I think I can safely say that these personally expressed sentiments are also shared by the rest of the Committee. The development of this work by ACTS and the move to develop a strategic 4-5 year plan which will be outcome focused is an exciting development. We also hope to be able to report in the next issue on the development of a new HSE chemical strategy. Watch this space…
In this issue we also have articles featuring new chromium guidance prepared in partnership with industry giving advice on substitution; updates on the development of the asthma strategy; and an interesting article describing the long arm of HSE in tracking down the origin of illegally imported asbestos products. From Buenos Aires to Birmingham to Tampa to Sao Bernardo do Campo!
The Internet version of TSB seems to have been very well received. Already we are getting around 1500 hits per issue and this is an increasing trend. We do not advertise TSB as such and rely on readers to let others know, so keep up the good work.
Finally, as in past Editorials, I extend the offer to readers to use the TSB e-mail to give us feedback on the journal as well as suggestions for future articles and reports of good practice to share with others.
Chris Rowe, Editor
The Advisory Committee on Toxic Substances (ACTS) held its 77th meeting on 14 March 2002. A full list of Agenda items is available on the HSE website at http://www.hse.gov.uk/aboutus/hsc/iacs/acts/acts77.htm Some of the items discussed were:
ACTS agreed HSE should consult on a range of limit values.
ACTS agreed HSE should publish a CHAN and targeted guidance for aluminium recycling and ask HSC for permission to consult on adding dioxins to Schedule 1 of COSHH (see news item).
ACTS agreed that it needs to consider the way it communicates with those who work with substances and the way it evaluates the impact of its work.
The paper informed ACTS of four factors that were used in prioritising substances: the health hazard; risk factors affecting release of the substance to the workplace atmosphere, such as volatility and dustiness; numbers of employees exposed; and the type of workplace controls in place to restrict worker exposure, for example containment or exhaust ventilation.
ACTS suggested utility as a fifth factor, which would be a generic limit band that features across workplaces.
The paper sought ACTS agreement to a course of action to deal transparently with limit values in EH40 that have uncertain scientific basis. Of 100 substances where the occupational exposure limit (OEL) is less protective than COSHH Essentials, ACTS agreed to look at these substances as part of the wider examination of the limit setting framework. Of 20 substances where the OEL is more protective than COSHH Essentials, ACTS agreed they merited further examination.
ACTS agreed to a residential meeting in July to have a strategic discussion to consider a 3-4 year outline plan of work. ACTS also agreed to the terms of reference for COWG and a new format for ACTS papers which would include three new headings that would look at communication plans, evaluation plans and relevant control systems for exposure.
ACTS members agreed to work as close as possible to the Code of Practice.
Contact: Ravi Govin, CRAU1, 7NW, Rose Court, 2 Southwark Bridge, London SE1 9HS
The British Occupational Hygiene Society (BOHS) have organised a series of one-day roadshows on e-COSHH Essentials and the new OEL framework, with speakers from HSE. Seminars at Cardiff (12 June 2002), Sheffield (19 June 2002) and Birmingham (26 June 2002) will be held in June. These will cost £69 for non-BOHS members, which includes tea, coffee, buffet lunch and VAT.
Please contact e-COSHH, BOHS, Suite 2, Georgian House, Great Northern Road, Derby DE1 1LT Tel: 01332 298101 Fax: 01332 298099 for details and to book a place on the roadshow.
'Revitalising health and safety' commits HSE to reducing the number of new cases of occupational ill health per year by 20% by 2010. One of the key pieces of legislation for hazardous substances is the Control of Substances Hazardous to Health Regulations (COSHH). But before HSE can target its efforts effectively, it needs information on how well COSHH currently works in practice.
As part of the enforcement phase of the Good Health is Good Business campaign, structured questionnaires were completed following visits to 43 Home Counties engineering companies. Approximately 75% of visits were purely preventative inspections although a minority of visits were in response to complaints (not necessarily health based), accidents or reports of ill health.
This snapshot is not statistically accurate as inspectors tended to visit workplaces with higher hazard and risk. However, it shows that there is still significant non-compliance with COSHH in many parts of the engineering industry. Typical areas of poor compliance were:
Formal enforcement action was taken almost as often at solely preventative inspection visits as it was in following
up complaints of whatever nature. This suggests that preventative inspection remains a very important strategy in seeking
to raise standards of compliance and reduce ill health at work.
In September 2000, TSB featured an article on the need to substitute a safer form of chromium, trivalent chromium, for hexavalent chromium (a carcinogen) in the electroplating industry. It described the aims of a working party of the Surface Engineering Association (SEA) (which contains representatives from industry and HSE) to:
This work is an example of HSE and industry working together to deliver the 'Revitalising health and safety' targets and, in particular, the target of reducing work-related cancers in the occupational health strategy 'Securing Health Together'.
Since we published this article, a survey of chromium platers has been completed by the British Surface Treatment Suppliers Association (BSTSA) for the SEA. The survey found some firms were unaware of the need to change from hexavalent chromium, and the availability of safer alternatives. In general, firms needed more information on the advantages of using trivalent chromium.
The working party has used the results of this survey to design a booklet Trivalent chromium plating and distributed it widely to platers. It contains a successful case study of a plater switching to trivalent chromium and lists the advantages - both to health and the savings on chemicals and disposal costs.
But, for some applications, engineering coating still uses hexavalent chromium. Here, the need is to make sure that firms know how to handle hexavalent chromium safely and the working party has designed a Hexavalent Chromium Health and Safety Training Document to help BSTA sales representatives train customers in their workplaces.
SEA can be contacted at: finishes@waverider.co.uk or Tel: 0121 237 1123.
Last July, ACTS examined results from a pilot survey of occupational exposure to dioxins and asked HSE to investigate the feasibility of a range of options for improving occupational control. ACTS have now endorsed a package of measures designed to reduce occupational exposure to dioxins.
The package includes:
As it is important to find out how successful these measures are in improving occupational control, ACTS also endorsed
HSE's proposal that the impact of these measures would be evaluated in three years' time.
The Health and Safety Commission (HSC) recently launched a consultation on changes to exposure limits for potentially harmful substances to protect workers against ill health.
HSC sets two types of occupational exposure limits - Maximum Exposure Limits (MELs) and Occupational Exposure Standards (OESs).
The consultative document (CD182) contains proposals for the control of eight substances or groups of substances. These are:
* Chloroethane is included in proposals for a second Indicative Occupational Exposure Limit Value Directive. Member states need to take into account recommendations made in IOELV directives in national OEL deliberations.
The seven OESs are being withdrawn because HSE considers it impossible to set health-based limits for these substances or, in the case of sulphuric acid, there is evidence that the current OES is not sufficient to protect health. Chemical Hazard Alert Notices (CHANs) have been issued for subtilisins and sulphuric acid mist, available on HSE's website at: www.hse.gov.uk/pubns/chindex.htm
CHANs offer interim good practice advice. Employers will find them useful when following the requirements of the COSHH Regulations. There are no CHANs for glycidyl ethers as HSE believes these substances are no longer used in the UK, except possibly on a laboratory scale.
If HSC approves the changes contained in CD182, they will come into force on the publication of EH40: Occupational Exposure Limits early in 2003.
Comments on proposals in this CD should be sent to: Chris Rowe, HSE, 7NW, Rose Court, 2 Southwark Bridge, London SE1 9HS before 7 June 2002.
CD182 is available on the HSE website www.hse.gov.uk/condocs/cd182.htm. Copies are also available free of charge from HSE Books, PO Box 1999, Sudbury, Suffolk CO10 2WA (Tel: 01787 881165. Fax: 01787 313995).
TSB47 reported on HSC's decision to set up an Asthma Project Board to develop and implement an action plan aimed at reducing the incidence of occupational asthma by 30% by 2010. The Asthma Project Board met on 21 January 2002. Details of members and notes of the meeting will shortly be available on HSE's website.
The Board had a useful brainstorming session and explored the main themes. A wide range of activities will be needed to produce the desired change but first we need to consider the priority actions for the plan.
Examples of recent developments include a conference on occupational asthma for general practitioners and occupational health professionals, which took place on 26 March. The TUC have published asthma training materials for trades union safety representatives. These materials were funded by HSC's Training Initiative fund. These are available as a priced publication from the TUC, Congress House, Great Russell Street, London WC1B 3LS, website www.tuc.org.uk
Another component of the action plan is an ACOP on the control of substances that cause occupational asthma. HSE will turn the revised ACOP into Appendix 3 of the main ACOP under the COSHH Regulations 2002, which should be published in summer/autumn 2002. The ACOP text will be repeated along with control guidance sheets and case studies in COSHH Essentials style guidance for the top eight causes of occupational asthma from March 2003.
The Board will have met again in May and plans to launch the action plan on HSE's website in summer 2002. 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
Since the last issue of TSB, HSE has produced new or revised guidance on a range of relevant topics. Here is a round-up of some of the leaflets and publications. These publications are available from HSE Books, PO Box 1999, Sudbury, Suffolk CO10 2WA. Tel: 01787 881165. Fax: 01787 313995. Website: www.hsebooks.co.uk
Free leaflets are also on HSE's website.
Surface cleaning: Solvent update including the reclassification of trichloroethylene (EIS34) was published in February 2002.This information sheet advises managers on proposed changes affecting health, safety and environmental controls on the use of solvents, and halogenated solvents in particular. These changes take into account the reclassification of trichloroethylene (trike) to a category 2 carcinogen (Risk Phrase R45 - may cause cancer) and related restrictions arising from the Solvent Emissions Directive.
Topics covered include: background; the implications of the reclassification of trike under COSHH; flammable substances; Existing Substances Regulation review of trike; the Solvent Emissions Directive.
This is available on HSE's website at www.hse.gov.uk/pubns/eis34.pdf
Skin problems in the printing industry (IACL101(rev1)) was published in March 2002.
HSE believes that there is a need for better recognition and understanding of dermatitis, better skin care provision and more rigorous monitoring and surveillance to deal with problems in the early stages. This leaflet details a series of simple steps to help employers in the printing industry prevent the disease and reduce the incidence of dermatitis.
This leaflet was withdrawn in February 2007.
The safe use of gas cylinders (INDG308(rev1)) will be published in May 2002. This revised leaflet is aimed at everyone who uses, owns, fills or repairs gas cylinders at work. It states simply what the main causes of accidents are, and how to reduce the risk of an accident. It also gives advice on repairing, filling and handling gas cylinders.
This free leaflet is now withdrawn (6 May 2004)
ACTS has published a Discussion Document on proposals to revise the Occupational Exposure Limit (OEL) Framework.
Research by HSE - including a survey of TSB readers - has shown that OELs are not being used by much of industry. The ACTS Working Group (which contains representatives from industry, trade unions and independent experts) has discussed ways to improve OELs including: what stakeholders want from OELs; practical ideas to make OELs easier for firms to use; and ways to make setting OELs faster and more efficient.
The aim of this document is to start a debate about what everyone wants from exposure limits. For example:
By contributing to the debate, you can help HSE set up a robust system of limits which will help to control hazardous substances and contribute to the 'Revitalising health and safety' target to reduce occupational ill health by 20% by 2010.
The working group will consider the responses to this document, alongside other research on the operation of the current system, and make formal proposals for changes to the OEL framework. Subject to approval by HSC, these will be published in a formal consultation document in 2003. Any changes to the COSHH Regulations would not occur until 2004.
The full text of the Discussion Document can be viewed or downloaded on the HSE website at http://www.hse.gov.uk/disdocs/dde19.htm. Copies can also be obtained free of charge from HSE Books, PO Box 1999, Sudbury, Suffolk CO10 2WA (Tel: 01787 881165) or from http://www.hsebooks.com. The consultation ends on 30 July 2002.
TSB talked to a member of the ACTS Working Group, Dr Mike Kingsland, about his personal viewpoint on the proposals. Dr Kingsland is a Confederation of British Industry (CBI) representative on HSC's Advisory Committee on Toxic Substances (ACTS).
TSB: Can you tell me about your involvement in the preparation of this Discussion Document?
MK:
As part of a tripartite working group reporting to ACTS. The group started by brainstorming and moved to more focused and detailed discussions as agreement was reached on the process and options to present for review.
TSB: This seems to be a very complicated scenario. Are you convinced that it can really be made simpler?
MK:
I think reality often is complicated and has a tendency to become more so with time. It is therefore good to stand back, at an appropriate time, and ask what are we trying to achieve, what has changed, what options are available and what have we learnt from the past?
I don't think it will ever be as simple or black and white as we might like but I am convinced that we can make it simpler than at present and, perhaps more importantly, make it easier to understand.
TSB: Why is now the right time for ACTS to publish this Discussion Document? If business is comfortable with the current system, why advocate change?
MK:
The direct answer is that it is a combination of factors:
TSB: Is the idea of complying with 'good practice' a get-out for employers not to do a proper job of protecting their workers?
MK:
No, I don't think so.
One of my memories of school was the school rule that said, 'Any breach of common sense is a breach of school rules'. Isn't 'good practice' common sense?
Good practice should aim to achieve the required objective and do so by proven and practicable means. I do not believe that we will be lowering our standards, merely trying to be more efficient and practical in the ways that we meet them.
I also think we have an opportunity to integrate this development with other recent developments such as COSHH Essentials.
TSB: What do you think we need to achieve a better system?
MK:
A system that really works and is easily understood and enforceable. A means to effectively communicate to the appropriate audiences. An effective and fair enforcement system.
Under the initiatives 'Revitalising health and safety' and 'Securing Health Together', the Government has set stringent targets for a 20% reduction in cases of work-related ill health by 2010 and to achieve a 10% reduction by 2004. This target is a significant challenge for HSE and industry.
Measurement of work-related ill health is notoriously difficult. Occupational ill health often has a prolonged latency before the onset of symptoms (eg asbestosis can occur more than 20 years after exposure). Often the relationships between exposure and ill health are poorly defined and occupational factors are difficult to separate from others (eg environmental, consumer, dietary and lifestyle exposures).
Therefore, the effect of measures taken to reduce exposure on the number of cases of ill health may not be apparent for several years. How then to demonstrate a 20% reduction in cases of work-related ill health by 2010?
For substances which affect the body internally, it is the amount of a substance which is absorbed - the body burden - that determines the risks to health. So even though we may not be able to quantify the risk to health that is posed by a specific set of exposure conditions, it is likely that by reducing body burden we will reduce the risk to health.
Biological monitoring is an effective tool to assess body burden since it enables the total amount absorbed by all routes (inhalation, ingestion and skin absorption) to be measured. For this reason, biological monitoring is also useful for assessing the efficacy of controls, especially personal protective equipment. By taking measurements now and regularly over the years, it is possible to show how tighter control measures and better working practices can reduce the amount of a substance that gets into a worker's body during the working day.
Using biological monitoring data to inform decisions on control strategies will be particularly useful for substances for which a 'safe' level of exposure cannot be identified, for example those to which Maximum Exposure Limits (MELs) have been assigned. Such chemicals are often carcinogens or sensitisers, and exposures should be kept as low as is reasonable practicable. A simple biological monitoring strategy coupled to investigation of high values and the introduction of remedial measures can gradually but visibly reduce substance intakes.
The Health and Safety Laboratory has been gathering data on the levels of methylene-bis-orthochloroaniline (MbOCA) in urine for more than 20 years now. In that time, urinary MbOCA levels have fallen 20-fold.
Figure
1: Levels of MbOCA in urine, 1977-2000These data were used to develop a Benchmark Biological Monitoring Guidance Value (BMGV) for MbOCA. A Benchmark BMGV represents the 90th percentile of biological monitoring results from a representative sample of workplaces with good occupational hygiene practices. This enables employers to compare the substance intakes of their workers with substance intakes of individuals working in well-controlled conditions.
HSE is currently working on Benchmark values for polyaromatic hydrocarbons (PAHs), cadmium and acrylamide and this approach could be applied to many other chemicals where biological monitoring methods are available. It could also be used as a basis on which to develop 'in-house' guidance values. Biological monitoring can be a simple, pragmatic tool to demonstrate the efficacy of improvements in workplace control of chemicals.
Currently, there is interest in the occupational hygiene community in studying exposure patterns to isocyanates, particularly the transient exposure peaks which operators are exposed to. Little is known about the isocyanate concentrations and duration of these peaks, and it is considered possible that they may play a significant part in the mechanism by which individuals acquire respiratory sensitisation.
Traditional measurement techniques, relying on laboratory analysis, give no information regarding exposure patterns: the result obtained is the average airborne concentration over the sampling period. This is a limitation of all such methods, including HSE's measurement method, MDHS 25/3, which is currently the only isocyanate measurement method to have gained approval by the International Organisation for Standardisation (ISO).
The MDA Isologger is a commercially available instrument which is capable of generating time-resolved exposure data for isocyanates. It is the first commercially available isocyanate monitor specifically designed for use as a personal sampler, and for this reason it was considered to be potentially extremely useful.
HSL has investigated its performance both in the laboratory and in the field. The laboratory evaluation involved checking the Isologger using standard atmospheres of monomeric isocyanates. Overall, the instrument performed well enough to be considered as potentially useful in the field.
The field evaluation involved studying the instrument's performance in a number of real workplace situations. Although industrial uses of isocyanates are many and varied, three processes were identified as having the potential for significant operator exposure, and so were included in the field study. These were:
The field evaluation showed that the instrument performed reasonably well when used to monitor exposure to TDI in soft foam plants.
However, the work also revealed that the instrument has a poor response to isocyanate pre-polymers and so is of little use for monitoring isocyanates in the MVR industry. This is unfortunate, since there is a large exposed population in this industry and also the potential for high concentration exposure peaks. The low and inconsistent response of the Isologger to pre-polymeric isocyanates has also been reported by other researchers. The airborne isocyanate concentrations at the two sites spraying MDI-based foams were extremely low, and very little meaningful data was generated at these sites.
The printout of data from the Isologger illustrates the type of time-resolved data that can be generated when the instrument is used to monitor personal exposure to TDI.
Figure
2: Time-resolved data from the IsologgerIn this example there is a clear exposure peak, during which the operator experienced an isocyanate exposure approximately 15 times higher than his average exposure over the sampling period. This peak corresponds with the operator entering an enclosure to clear a blockage.
A parallel sample taken using the MDHS 25/3 methodology indicated a time-weighted average TDI exposure over the sampling period of 0.018 mg/m3, which is approximately half the MEL. Based on this result alone, it may be concluded that control is adequate. However, the Isologger data clearly demonstrates the potential for high transient exposure. Data such as this can be used to clearly illustrate the need for good working practices, and also the use of RPE for maintenance procedures which involve entering enclosures.
Work is ongoing at HSL to improve the instrument's response time (currently 2 minutes), which should make it possible to link it into HSL's exposure visualisation system. If successful, this will provide a valuable tool for studying exposure patterns in an area where this has not previously been possible.
HSE publishes enough of it so it would seem reasonable that we should know the status of our guidance. And we do. But do others in the health and safety system know the difference between material that is contained in an Approved Code of Practice (ACOP), and that which is guidance?
If you do, then fine, but if, like a lot of people, you are not sure then this article might help you.
HSE operates under the law: principally the Health and Safety at Work etc Act 1974 (HSWA), which is based on 'reasonable practicability'. HSWA and associated regulations frequently set goals. ACOPs and guidance can advise on meeting such goals.
have a special legal status in criminal proceedings. They can be used in a court of law. They are admissible in evidence and, when the Code is relevant to the offence but not observed, the defendant must show that the law has been complied with in some other way.
- advice on how to keep the law - lacks this special status, but it will seek to illustrate practices which will help to secure legal compliance. In some instances it may help employers who strive towards a standard better than the legal minimum and where it does this it should be clear that this is the expectation.
Often, published material will include the law (specific regulations); an explanation of what this law means or requires; ACOP setting out preferred, specific duties to ensure compliance; and some guidance advising on ways to secure legal compliance.
In practice, guidance is likely to be doing one or more of the following:
More and more genetic tests are being developed. But what are their implications for our daily lives? The Human Genetics Commission has been set up to discuss the ways in which we can use these tests - and ways in which we shouldn't. Their website (www.hgc.gov.uk) contains discussion on topics from the use of tests by insurance companies through to the implications for employment.
The section on employment is thought provoking. For example, would you be willing to take a test to see if you were potentially at extra risk from hazardous chemicals used at work? You might like to know if your individual genes mean that you were more likely to become ill from exposure to small amounts of chemicals used at your work which would not affect most people. This would mean you could take extra precautions - but if you took a genetic test as part of the recruitment process, you might never get the job. And making tests compulsory would interfere with your right not to know - not everyone wants to be told that they are more likely to get an illness.
The potential consequences of accurate, reliable tests are complex and everyone needs to discuss the ethics of testing now.
A working group of HSC's Occupational Health Advisory Committee (OHAC) is monitoring the implications of genetic testing for the workplace.
12 clicks a day keeps the inspector away...or busy readingA free, Internet version of COSHH Essentials was launched by HSE on 30 April 2002. This is an interactive version of the simple step-by-step risk assessment which helps firms assess the risk to health from hazardous chemicals and comply with COSHH even faster than before.
For example, the programme automatically works out the volatility of solvents from the boiling point and operating temperature and calculates the right hazard group from the R phrases on your safety data sheet. The system allows you to assess single chemicals, ready made mixtures and ones you prepare yourself.
There is also a comprehensive set of help screens if you need a bit of guidance to decide which options to choose, and a progress bar at the top to keep track of what stage you have reached in the assessment. If you get distracted, the system allows you to come back to an assessment using an individual reference number for the next 30 days. After this, the assessment is wiped to ensure privacy for users.
The website is easy and fast to use and it has hypertext links to other relevant guidance and leaflets. All you need to do now is print out the assessment summary and copies of the relevant control guidance sheets. And, if you change your processes slightly, eg start using a new paint, you can rerun the assessment and only have to enter the changed information - COSHH Essentials will do the rest.
Please note, the content of external sites may not reflect HSE policy.
Mr C Rowe Editor
Mrs S Wassell Assistant Editor
Ms P Kiley Content Editor
Mr D Kyle
Dr J Groves
Mrs E Ball
Mr S Campbell
Dr R Rajan
Dr R Rawbone
You can contact TSB at CRAU@hse.gsi.gov.uk or via the TSB feedback form