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Chris, I would be very grateful for a copy of the document. Gill From: [log in to unmask] [mailto:[log in to unmask]] On Behalf Of Chris Packham Sent: 22 September 2012 22:56 To: [log in to unmask] Subject: Re: [OCC-HEALTH] Direct entry SCPHN Anne Thanks for your comments. Yes, risk assessment is sometimes taught. However.... One of the problems I encounter with regard to risk assessment is that some of the teaching on this misses some important points. This is particularly the case where skin exposure to chemical hazards is concerned. This is not unique to occupational health. I question the quality of teaching on this aspect in many courses, whether for occupational health or health and safety, e.g. NEBOSH diploma. The complexity of risk assessment for chemical exposure is frequently underestimated. Even some of the HSE guidance is flawed and, if followed closely, could result in invalid risk assessments putting worker health at risk. One classic example is the ACoP for COSHH. Regulation 2(1)(e) states: "(e) which, not being a substance falling within sub-paragraphs (a) to (d), because of its chemical or toxicological properties and the way it is used or is present at the workplace creates a risk to health". In other words any chemical could, under certain circumstances, become a hazard, not just those which carry risk phrases. This is correct. One of the most common causes of occupational contact dermatitis is wet work, i.e. exposure to water. Yet in the proposed method for a risk assessment in the ACoP it recommends relying on safety data sheets, which only need to show chemicals with risk phrases for the risk assessment. I can easily demonstrate, using COSHH essentials, how one can arrive at an invalid risk assessment. I still see frequent references to COSHH safety data sheets, ignoring the fact that these are not produced for COSHH (as paragraph 13 in the COSHH ACoP confirms) but for CHIP. This is just one example of why so many of the risk assessments I see are at best questionable and frequently incorrect. The information on the safety data sheet is limited and only intended as information about the chemical as supplied. Now we normally purchase chemicals to use for a particular purpose. In the process we frequently change the chemical (contaminate, mix, react, dilute, heat, oxidize, etc.) resulting in very different hazardous properties to what we started with. Indeed, identifying the true hazard is actually very often the most difficult part of any risk assessment and may require specialist knowledge (chemistry, toxicology, dermatology, etc.). I have produced a simple A4 two page document on this. It shows the elements in a risk assessment, the sources of information and those factors that, if not taken into account, can result in a possibly invalid risk assessment. I will happily e-mail this to anyone who e-mails me to request it. Chris Chris Packham FRSPH, FIIRSM, FInstSMM, MCMI, MBICSc EnviroDerm Services Unit 10, Building 11, The Mews, Mitcheldean, GL17 0SN Tel: +44 (0)1386 832 311 Mobile: 07818 035 898 ******************************** Please remove this footer before replying. OCC-HEALTH ARCHIVES: http://www.jiscmail.ac.uk/lists/occ-health.html CONFERENCES AND STUDY DAYS: http://www.jiscmail.ac.uk/cgi-bin/filearea.cgi?LMGT1=OCC-HEALTH ******************************** Please remove this footer before replying. OCC-HEALTH ARCHIVES: http://www.jiscmail.ac.uk/lists/occ-health.html CONFERENCES AND STUDY DAYS: http://www.jiscmail.ac.uk/cgi-bin/filearea.cgi?LMGT1=OCC-HEALTH