Transcript Occupational Exposure Limits A New Approach

Occupational Exposure Limits
A New Approach
plus
COSHH Essentials phase 2
Michael Topping
Chemical and Flammables Policy Division
Health and Safety Executive
Email: [email protected]
COSHH Essentials – Phase 2
 Expands
the scope
advice – no need to go through
risk assessment
 Direct
 70
new control guidance sheets
 Live
on internet from 8 October
COSHH Essentials – phase 2
 Process
generated dusts and fumes
 Rubber
dust and fume
 Foundry work
 Wood dust
 Substances
causing asthma
 Isocyanates
 Flour
in motor vehicle repair
dust
 Service
and retail sheets
 Health surveillance
COSHH Essentials – Phase 2
 Cleaning
services
 Pubs,
clubs and restaurants
 Motor
vehicle repair and maintenance
 Beauty
treatment
Why a New Approach ?
 Chemicals
are making people ill:
- 6,000 – 12,000 cases each year
 Asthma – 7,000 new cases each year
 Dermatitis – workforce survey – 66,000
 Lower respiratory disease – workforce
survey – 200, 000
 Cancer
Why a New Approach ?
 Lack
of understanding of current system
 Concept of OES as a “safe” limit
 Incompatibilities with EU system
 Criteria for setting limits not
comprehensive
 Small firms need practical help
Why a New Approach ?
ACTS concluded:
OELs not realising their full potential
as important tools to help employers
control exposure
Objectives for new system

To provide an easy to use tool that helps duty
holders improve control

Address the difficulties with the current
system

Improve efficiency of the limit setting process
in light of the EU system

To meet needs of industry in 21st Century –
1.3m firms – many <10 employees – wide
range of chemicals and chemical products.
Path to New Framework

ACTS subgroup re-energised
July 2000
 Discussion document published
March 2002
 Consultative document published
October 2003
 New framework implemented
Summer 2004
Discussion Document
Presented 3 options
1. Maintain present system with minor
changes
2. Good practice control advice supported
by a single type of limit
2A Good practice control advice supported
by a two tier system which flags
carcinogens
Responses to Discussion Document
Total number of responses – 56. No comment from 6.
Question
Number
replying
Yes
No
Agree with concerns 41
on current system
41
0
Agree with need for
change
39
38
1
Agree with key
objectives for new
approach
36
31
5
Respondents Views on the 3 Options
Option
Option
Option
Option
1
2
2A
2 or 2A
Key Features of the Proposals
Single type of OEL – to be called WEL.
Emphasis on applying good practice.
Provision of control advice.
WELs linked to good practice advice (e.g.
COSHH Essentials).
All MELs and soundly based OESs
transferred to the new system.
WELs compared to OESs and MELs
OES
Standard must be
met
No requirement
to further reduce
exposure
If standard
exceeded, steps
taken to comply as
soon as reasonably
practicable
MEL
WEL
Limit must be met Limit must not be
exceeded
Exposure must
be reduced
ALARP
Limit must not be
exceeded
Adequate Control
Control of exposure is adequate if:

Principles of good practice for the control of
exposure to substances hazardous to health
set out in schedule 2A are applied

WEL is not exceeded

Exposure reduced so far as is reasonably
practicable for substances with R phrases 45,
46 or 49, or in schedule 1 of COSHH Regs
Principles of Good Practice
a) Control exposure by measures
that are proportionate to the
health risk
Good Practice Depends on Hazard
Good practice for control of a toxic dust such as
CYCLOPHOSPHAMIDE would not be the same as for
a low toxicity dust such as BARIUM SULPHATE
Good Practice Advice
Determinants: - Hazard; Scale of use; Task
Designed to keep exposures below the WEL
E.g. Wood Dust
Hand finishing in a
carpentry workshop:
 Good practice = LEV
Large scale
machining of logs:
 Good practice =
enclosure and
automation
Providing Good Practice Advice
Supporting use of COSHH
Essentials as source of
good practice advice
Electronic package linking
WELs, COSHH Essentials,
COSHH guidance useful to
most / minority of
dutyholders or not useful
14%
5%
95%
86%
Sources of Good Practice Advice
 COSHH
Essentials task-specific control
advice
 COSHH
Essentials control guidance
sheets for dusts and fumes
 COSHH
Essentials sheets for specific
industries – e.g. motor vehicle repair
 Existing
HSE or industry sector
guidance
Linking COSHH Essentials to
WELs
Enter Substance name
Does it have a WEL
Yes
WEL determines COSHH
Essentials hazard group
No
R phrase determines
COSHH Essentials
hazard group
Linking COSHH Essentials to
WELs
 New
EH40 will give for each WEL:
the COSHH Essentials hazard group
 COSHH Essentials control approach for
use at room temperature or reference to
other guidance;
 A simple statement on health effects;
 “flags” e.g. Sk notation

Transferring existing OELs into
the new system
25
20
15
10
5
0
Keep all
Sound only
Sound +
Other
Proposals for transferring
Existing OELs to New System

All MELs transferred into new system as
WELs. - Some flagged for review
 Soundly based OESs transferred into new
system as WELs (92)
 Other OESs (except where no or minimal
occupational use) control advice will be
provided by:



Generic COSHH Essentials system
Substance/process dedicated COSHH
Essentials sheets
CHAN
Future
Simple, free, practical advice
accessed via list of WELs
or COSHH Essentials
Advice on
biological
monitoring
Measurement
methods
Toxicity
reviews
Conclusion
 Innovative
approach designed to help
small firms control chemicals
 System of good practice linked to OELs,
first in the world
 Let us know what you think
 CD on HSE website
www.hse.gov.uk/consult/condocs/