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Occupational Exposure Limits A New Approach plus COSHH Essentials phase 2. Michael Topping Chemical and Flammables Policy Division Health and Safety Executive Email: michael.topping@hse.gsi.gov.uk. COSHH Essentials – Phase 2. Expands the scope
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Occupational Exposure Limits A New ApproachplusCOSHH Essentials phase 2 Michael Topping Chemical and Flammables Policy Division Health and Safety Executive Email: michael.topping@hse.gsi.gov.uk
COSHH Essentials – Phase 2 • Expands the scope • Direct advice – no need to go through risk assessment • 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 in motor vehicle repair • Flour 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: • Cancer - 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
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. • makes a real contribution to health protection
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.
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.
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 • 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
Hand finishing in a carpentry workshop: Good practice = LEV Large scale machining of logs: Good practice = enclosure and automation Good Practice Advice Determinants: - Hazard; Scale of use; Task Designed to keep exposures below the WEL E.g. Wood Dust
Providing Good Practice Advice Electronic package linking WELs, COSHH Essentials, COSHH guidance useful to most / minority of dutyholders or not useful Supporting use of COSHHEssentials as source of good practice advice
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 No R phrase determines COSHH Essentials hazard group WEL 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
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/