Section 2 vs Section 16 Query (2024)

One of the things I check is that Section 16 tallies with the content of Section 2 & 3

Some times I find there are more actual H statements(not numberof statements) listed in 16 than appear in 2 and/or 3 which then provokes some awkward questions back to the provider of the SDS

"Can you tell me why Section 16 lists H412 that does not appear in either Section 2 or 3?"

One of the things I check is that Section 16 tallies with the content of Section 2 & 3

Some times I find there are more actual H statements(not numberof statements) listed in 16 than appear in 2 and/or 3 which then provokes some awkward questions back to the provider of the SDS

"Can you tell me why Section 16 lists H412 that does not appear in either Section 2 or 3?"

Exactly this; I'm confused as to why all H statements mentioned in section 16 aren't mentioned in 2 and/or 3. I'm trying to complete RA's (using the HSE's COSHH E-tool) and I'm stuck on completing some of them because I don't know whether to include H statements mentioned in section 16 or not. A Kurdziel - If the concentrates are so small, why mention them? For me, if they are mentioning them, then they are acknowledging there isa risk there - no matter how small - and therefore surely should be mentioned in section 2 as well??

‘All things are poisons, for there is nothing without poisonous qualities. It is only the dose which makes a thing poison.’ So said a fella going by the name Paracelcus a long time ago.

Consider something like a bottle of co*ke - look carefully and it might contain phosphoric acid - not something I'd like to drink, but its use is fine in the bottle of co*ke bcause of the end concentration is so low. Now back to Safety Data Sheets - there might be a valid reason for including the 'H' statements for the ingredients of a product - perhaps incompatibility on disposal or on spill clean up? The 'H' statements are all listed because perhaps if you ended up flushing 100litres down the drain you might breach your environmental permit for instance

I would be cautious about conducting risk assessments for COSHH based purely on the safety data sheet, despite that this is the approach that COSHH essentials takes. Indeed the ACoP for COSHH actually does not recommend this approach. If you consult the latest edition of the ACoP this is what you will find:

Paragraph 10 - Employers should regard a substance as hazardous to health if it is hazardous in the form in which it may occur in the work activity. A substance hazardous to health need not be just a chemical compound, it can also include mixtures of compounds, micro-organisms or natural materials, such as flour, stone or wood dust.

This is in accordance with the actual COSHH regulations. Regulation 2(1) includes the following:

“(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” - COSHH Regulation 2 (1) Interpretation

There are thousands of chemicals that have never been assigned a Hazard Statement that can cause damage to health, particularly where skin exposure is concerned. For example, in his book on patch testing Anton de Groot lists 4900 chemicals knows to dermatologists as skin sensitisers. Only a small percentage of these will have been assigned H317 and appear as such on a safety data sheet. The most common cause of occupational contact dermatitis is exposure to water. When did you last see water on a safety data sheet.

Risk assessments for chemical exposure must start with the real hazard when the chemical is used, not what is on the safety data sheet. Otherwise you could well end up with an invalid risk assessment.

You do not use Section 16 it is purely explanatory.

Section 2 is what you purchase to handle i.e. the object of your assessment

Section 3 details what hazardous substances itcontains above their notifiable threshold if it is a mixture.

The Classification Labelling & Packaging Regulations set the rules

You do not use Section 16 it is purely explanatory.

Section 2 is what you purchase to handle i.e. the object of your assessment

Section 3 details what hazardous substances itcontains above their notifiable threshold if it is a mixture.

The Classification Labelling & Packaging Regulations set the rules

Svick, exactly as Roundtuit says, ignore Section 16 in your COSHH assessment - as pseudonym says, if we used Section 16 for labelling then we wouldn't drink co*ke.

But please say if the explanations here are understood?

I once used 'painting a door' as an analogy to try to explain COSHH etc:

You would sand the old paint off the door - potentially exposing you to paint / wood dust, then you would apply filler to any cracks etc (potentially exposing you to filler), then an undercoat (paint) then clean your brushes (solvent cleaner), after a bit you would end up applying the final coat (more paint) and finally clean up afterwards - solvents etc - what I tried to emphasise was that when cleaning the brushes etc you'd be exposed to paint AND solvent, when sanding down it would be wood dust AND whatever else was on the door etc ..

Got to admit though I still doubt if they got my point!

pseudonym - And the solvent would contain chemicals, possibly toxic, from the paint and take these into and through the skin to reach internal organs that the paint on its own would not! That's the point about the 'real' hazardd during the task.

I agree, however, than many either do not get the point - or perhaps prefer to look the other way.

An example of a COSHH assessment that requires knowledge of the use of a material are 'cutting oils', these are used in CNC machines to cool/lubricate the cutting tool. Ofparticular importance arethose which are diluted with water before use. They are sold as a 'concentrate'.

In the MSDS of the concentrate Hazard Statements and symbol warnof eye irritation and skin irritation, but make no mention of the added hazard when diluted with water and when used in the machine - a mist is created which may cause asthma after repeated exposure.

The cutting process (2000 -20000 rpm) takes place when the CNC cabinet is closed, usually protected by an interlock, which contains the mist until the cabinetis opened. The higher speeds will have created mist droplets which persist/linger around and can exit as a cloud in the operator's breathing zone and circulate into the factory. Droplets 0.3 - 3.5u are suspected of causing asthma, and can contain bacteria. For this reason the HSE inspectors are insisting all older CNC cabinets be retro-fitted with an LEV to reduce mist in the cabinet andprevent a cloud of mist exiting when the door is opened.

Oh sorry, that explanation is long. But this is the explanation I have to provide to clients to explain why they or similar companies have had ImprovementNotices, and why the hazard will be included in the COSHH assessments and also in the machine PUWER and Risk Assessments.

MSDS from Kuwait Oils, Quaker Chemicals and others make no mention of respiratory hazard of the diluted substance used in CNCs.

Edited by user24 October 2018 19:31:56(UTC)|Reason: typos

Because an SDS as mandated by the various global interpretations of GHS is prepared relative to the product as supplied and shipped- not as used in a particular country, industry, business.

That is why EU legislation clearly states an SDS it is to allow an employer to conduct an assessment.... not just issue an SDS instead of.

What we are now meant to be seeing in Europe are e-SDS - extended documents that also consider hazards associated with uses notified to, and considered by the supplier of the substance or mixture.Suppliers are not required to "guess" what an end user may use their product for, and in future if an e-SDS specifically precludes how a product is currently used within your business you will have no claim or defence unless you can demonstrate you did communicate back along the supply chain.

Because an SDS as mandated by the various global interpretations of GHS is prepared relative to the product as supplied and shipped- not as used in a particular country, industry, business.

That is why EU legislation clearly states an SDS it is to allow an employer to conduct an assessment.... not just issue an SDS instead of.

What we are now meant to be seeing in Europe are e-SDS - extended documents that also consider hazards associated with uses notified to, and considered by the supplier of the substance or mixture.Suppliers are not required to "guess" what an end user may use their product for, and in future if an e-SDS specifically precludes how a product is currently used within your business you will have no claim or defence unless you can demonstrate you did communicate back along the supply chain.