How does the health and safety practitioner satisfy themselves that they have adequate knowledge on this complex issue and can recognise the myths and the misinformation that they will encounter? While for inhalation exposure there are Workplace Exposure Limits, for skin there are no such limits and the COSHH regulations only require that skin exposure be ‘adequately controlled’, with no clear definition of what, for skin, this means.
Another issue confronting the person responsible for the skin exposure risk assessment is identifying the real hazard that exists when one or more chemicals used during the performance of a task. It is common to find that the use of chemicals can change their properties resulting in a change in the hazard. There are many chemicals that, though capable of causing damage to health due to skin exposure, have not formally been classified as hazardous.
Correct identification of the real chemical hazard is frequently the most difficult part of a skin exposure risk assessment.
So the person responsible for ensuring that skin exposure in the workplace does not result in damage to health is faced with four hurdles that they must overcome:
- Firstly the prevention of damage to health due to skin exposure is complex and often requires specialist knowledge.
- Secondly, it is not easy to demonstrate to an employer whether the organisation is achieving regulatory compliance.
- Thirdly, whilst with physical hazards an accident is sudden and obvious with occupational health the fact that the effect may not be immediately apparent makes it easier for management to ignore or postpone the need for action.
- Fourthly they need to be confident that they have correctly identified the real hazard, particularly where more than one chemical is used during a particular task.
It is not uncommon to find a view that: "We don’t have any hazardous chemicals here.” This arises from the belief that if there isn’t a hazard shown on a safety data sheet then there is no skin hazard. The reality is that almost any substance, even water, can, under certain conditions, cause occupational skin disease.
Fortunately the Approved Code of Practice (ACoP) for COSHH no longer promotes the concept that a risk assessment can be based on the safety data sheet. Paragraph 35 states:
When deciding whether the substances used or produced in the workplace are covered by COSHH, employers should also consider the following:
- Different forms of a substance may present different hazards, eg substances may not be hazardous in solid form but may be hazardous when ground into fine powder or dust that can be breathed into the lungs.
- Nanoparticles (ie particles less than 100 nanometers) may be more toxic than larger particles of the same chemical substance.
- Impurities in a substance can make it more hazardous, eg crystalline silica is often present in minerals which would otherwise present little or no hazard.
- Some substances have a fibrous form which may present a potentially serious risk to health if the fibres are of a certain size or shape.
- Some substances have a known health effect but the mechanism causing it is unknown, eg certain dusts of textile raw materials cause byssinosis.
- Exposure to two or more substances at the same time or one after the other may have an added or synergistic effect.
- Epidemiological or other data, eg reports of illness due to new and emerging agents, indicate that a biological agent that does not already appear in The Approved List of biological agents could nevertheless cause a hazard to health.
- One-off, emergency situations arising out of the work activity, such as a dangerous chemical reaction or fire, could foreseeably produce a substance hazardous to health.
- ‘Wet work’ is one of the most frequently and consistently reported causes of irritant occupational contact dermatitis. ‘Wet work’ is the term used to describe tasks involving prolonged or frequent contact with water, particularly in combination with soaps and detergents.
Perhaps it is time for many health and safety practitioners to review what they have in place in terms of risk assessment for skin exposure to ensure that these are adequate.
Chris Packham works for EnviroDerm Services.
01386 831777chris@enviroderm.co.uk
