Foreword This document has been written as notes to and to augment - PDF document

Foreword This document has been written as notes to and to augment the presentation given by Chris Packham at the Occupational and Environmental Exposure of the Skin to Chemicals conference held at The Pillo Hotel, Ireland, September 2019. Should the reader have comments or questions arising out of these notes or feel that they need additional information the author is happy to hear from them. The document refers to a limited extent to EU/U.K. regulations. However, the general approach to risk assessment is not based on regulations but on the scientific evidence and personal experience of the author. Introduction The presentation briefly addressed just some of the practical considerations that affect how we approach the prevention of damage to health due to workplace skin exposure. This is an aspect of health and safety where success has so far eluded the health and safety community. As an example of this, German statistics show that occupational skin disease represents in excess of 30% of all cases of occupational ill health. As the image at the head of this page is intended to indicate, we are dealing with an almost infinite range of working environments, each with its own particular set of conditions. We also have to accept that the way in which our skin interacts with our immediate environment is far more complex than is often appreciated. This is particularly important when considering how chemicals that we encounter in the working environment can affect our health and how we should assess the risk of damage to health occurring. This document attempts to explain some of the many factors that we need to consider when attempting to produce a risk assessment when chemicals are present in the workplace and there is potential for skin exposure. It is important to recognise that this is not a comprehensive, step-by-step guide on how to perform a risk assessment for skin in the workplace. It merely attempts to make the reader aware of the complexity and the need to ensure a structured approach that ensures the risk that results from the assessment reflects the real potential for damage to health and its severity to occur. The aim is to help the reader recognise the complexity and that there are many traps that await the unwary or uninformed. What is a risk assessment? The European Agency for Safety and Health has a very simple definition of what constitutes a risk assessment: “A risk assessment is nothing more than a careful examination of what, in your work, could cause harm to people, so that you can weigh up whether you have taken enough precautions or should do more to prevent harm .” - Taken from: “Good Practice Information , provided by EU- OSHA”, September 2009 1

This simple definition does not include an in-depth explanation of the complexities that arise when attempting to assess the risk of damage to health due to exposure to chemicals in the working environment, nor the other elements that form an effective skin management system, such as the action required for effective risk management. The diagram illustrates the elements that the author believes form an effective occupational skin management system. Risk assessment for skin is task based What might be described as the ‘traditional’ approach to risk assessment for chemical hazards in a workplace is illustrated in the diagram. The author’s experience is that this is still widely used as an acceptable method of risk assessment for skin exposure to chemicals in the workplace. The procedure is to start by making a list of all those substances associated with the task where the safety data sheets identify them as hazardous, i.e. they have been assigned relevant hazard statements. Information on the hazard is also obtained from product packaging labels. Any exposure to the substances on this list is then identified and from this the risk of damage to health assessed. Unfortunately, as will become clear, where skin exposure is concerned this system is far from ideal. It fails on several counts. It does not reflect what happens to chemicals when we use them and so may not identify the real hazard. A risk assessment on this basis may exclude substances, of which there are many, that, whilst not having been assigned a hazard statement and thus not being shown on the safety data sheet, should skin exposure occur could cause damage to health. A systematic approach to the skin risk assessment Our approach to risk assessment should be based on the fact that it is only when we use any substance as part of a task that there is a hazard and this hazard will depend upon the way in which the substance is used. The implications of this will become clear when we consider the hazard as one of the key elements in our risk assessment. What this means, however, is that our risk assessment needs to start with the task under assessment. 2

As the diagram shows, the author’s approach to risk assessment for skin in the working environment starts with the task. Define task ‘The risk assessment must be specific to the task.’ This is the first step in any risk assessment where chemicals are being used and where skin exposure is concerned. However, if the definition of the task is to be adequate for a valid risk assessment certain conditions must be met. To identify what happens during a task requires at least one visit to the workplace to study what happens during the task under assessment. This will require planning to ensure that the task is actually being carried out at the time of the visit. If the task is one that takes place over an extended time it may not be practicable to watch the whole task. Where the task involves a number of actions where chemicals are used but which may only occur at intervals, so that it is not possible to observe these during the visit then it may be necessary to make repeat visits. Additionally, it may be that there are variations in the task depending on the circumstances. Some of which may not be apparent during the visit. Again, repeat visits may be needed or questions asked of those who will be able to explain these. It may be that occasionally the task has to be modified to meet unusual or one-off situations. Such possibilities could affect any risk of damage to health and should be identified. It is common to find that the person best able to provide this information is the person who actually carries out the task. They should be actively encouraged to partake in the knowledge gathering. Indeed, it is frequently necessary to consider it advisable for there to be a team involved in conducting a risk assessment. There may be a need to engage someone with technical knowledge about the process and the potential effect this may have on the chemicals in use. Identify all chemicals used - and how used At the same time as the task is being defined, we should identify all chemicals used. Note the word ‘all’. There are thousands of chemicals that will not appear on a safety data sheet as they will not have been assigned any hazard statements. Alternatively they may appear but have not been assigned any hazard statements relevant for skin exposure. 3

In the fourth edition of his book on patch testing Anton de Groot lists some 4,900 substances identified by dermatologists as skin sensitisers. Only a small percentage of these will have been classified as H317 – may cause an allergic skin reaction . Consider also the situation where the chemical product is a mixture, some of the constituents being classified as hazardous, others not. As the latter will not appear on the safety data sheet but, as will be shown, may present hazards should skin contact occur, relying on the information in the safety data sheet could result in an invalid risk assessment. One of the most common causes of occupational irritant contact dermatitis is water (wet work and wearing of occlusive gloves). Yet one would not expect to see a safety data sheet for water. Indeed, it is not uncommon to find that water is not even regarded as a chemical. Not only do we need to ensure that all chemicals, and their respective hazards, are identified but we need to establish how they are used. In using chemicals, it is almost inevitable that they undergo changes, as the next section will explain. These can result in major alterations in the chemical’s properties and resultant hazards. This is also covered, both in the U.K. Control of Substances Hazardous to Health (COSHH) regulations themselves and in the Approved Code of Practice for COSHH (AC0P). What are we really handling? Among the definitions of what constitutes a substance hazardous to health in the COSHH regulations is 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 In the sixth edition of the ACoP for COSHH the following statement appears: “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.” Neither of these mention the safety data sheet as the source of hazard information. How significant could this be? Determine the chemical hazards present during the task We purchase chemicals to use to achieve some outcome. In the process they will almost inevitably undergo some form of change. The table briefly draws attention to some of these. 4