21	Chemicals and dust

This is an excerpt from the TUC book "Hazards at Work: Organising for safe and healthy workplaces", the best-selling guide to health and safety at work. To buy a copy order here (if you are a safety representative on a TUC training course please speak to your tutor about getting a discounted copy)

BASIC FACTS ABOUT CHEMICALS AND DUST

According to estimates in March, 2007 by the Department for Environment, Food and Rural Affairs (DEFRA), around 30,000 chemicals are made, sold and used in significant amounts. DEFRA goes on to state that the current system has generated proper assessments on only a few hundred. The true extent of work-related health damage from hazardous substances is not known and estimates vary widely. In the latest figures available from the International Agency for Research on Cancer (IARC) in 2006, out of approximately 900 substances they have considered:

• 101 are carcinogenic to humans
• 69 are probably carcinogenic to humans
• 245 are possibly carcinogenic to humans

According to a TUC briefing for safety representatives in January 2007, it has been estimated that one in three of all occupational diseases recognised in Europe every year are caused by exposure to workplace chemicals. The TUC believes that around 18,000 deaths a year in the UK are caused by cancers caused by workplace exposure. There are many tens of thousands of others who suffer from skin problems, breathing problems or neurological damage caused by exposure to chemicals.

The 2006 TUC safety representatives survey showed overall that:

• chemicals or solvents were a major concern to 14 per cent of safety representatives
• dusts were a major concern to 11 per cent of safety representatives

In the private sector there was more concern, with the figures showing that:

• chemicals or solvents were a major concern to 25 per cent of safety representatives
• dusts were a major concern to 19 per cent of safety representatives

Safety representatives need to be aware of the potential damage to health arising from the use of such substances. Unlike physical hazards, where the hazard is visible and the effects immediate, the harmful effects of toxic substances are not always obvious. The hidden hazards of chemicals, dusts and other toxic substances present a real threat to workers’ health and may be one of the greatest single causes of health damage:

• chemical technology is used in most work processes
• thousands of substances are in daily use world-wide
• hundreds of new substances are brought onto the market each year

A huge range of substances and processes are used to make the goods and provide the services we take for granted. Hazardous substances are used in almost every workplace – offices, hospitals, hairdressing salons, gardens, kitchens and so on.

Every day people at work are exposed to substances which may cause:

• cancer
• reproductive disorders
• nerve and brain disorders
• liver and kidney diseases
• heart and lung disease
• skin disease
  
• allergies and sensitization

What is a hazardous substance?

The extent of hazardous substances varies enormously between different jobs and industries. All workers in all workplaces face some risks, and safety representatives need to know how to deal with the problems. Hazardous substances are defined by the COSHH Regulations (see below). Some examples of substances that may be harmful include: acids; many forms of dusts; herbicides; aerosols; inks; metals, e.g. nickel, beryllium; cleansers/detergents; oils; cutting fluids; paints; correcting fluids; disinfectants; pesticides; drugs and anaesthetics; resins; solvents, degreasers; dyes; welding/soldering fumes; fumes; glues and adhesives and hardeners.

How do hazardous substances affect us?

Not all people respond in the same way. Some are more susceptible (that is, they respond at lower doses) than others, depending on various factors such as age or state of health.

The main responses of the body are:

• Irritation of the breathing system. Substances can irritate the nose and upper lung passages, causing sneezing and coughing and, in some cases, bronchitis. They may also damage lung tissue.
• Irritation of the skin and eyes. A common reaction is dermatitis – a rash. Solvents can remove the protective oils from the skin. This makes it dry, rough and sore. Some chemicals (for example, hydrochloric acid and caustic soda) may cause irritation in dilute form, but when concentrated can cause chemical burns. The eye is extremely vulnerable if substances make contact.
• Sensitisation of the respiratory system. Some substances can cause ‘sensitisation’. Once a worker is sensitised any further exposure, even very small, may bring on an allergic response of coughing and wheezing.
• Sensitisation of the skin. Sensitisation can also occur if a substance gets on the skin. Further contact, even if tiny, may cause itching, rashes and discomfort.
• Long-term effects. Some effects only emerge after years of exposure, or manifest themselves years after exposure. These are called chronic effects. Often very low doses can cause these – there may be no shortterm (acute) effects to warn people of the risk. Lung damage caused by dusts or heart disease caused by smoking are two examples of long-term effects.
• Cancer, which is the long-term effect of most concern. This is a disorder of cell growth. It arises from a complex interaction between a harmful agent or agents (carcinogens) and the body. A number of chemicals are known or suspected cancer agents. The effect of exposure to a carcinogen may not be seen for many years, and early identification is often
  difficult.
• Reproductive disorders. Some substances can cause loss of sex drive, and infertility in both men and women. They can damage the sperm or the egg (mutagens) or the foetus (teratogens). There is a lack of reliable evidence on this for most industrial chemicals.

What are the risks?

History has shown that the hazards are often not recognised until too late. Signs of damage may take so many years to develop that all substances should be treated with caution. In particular, care is needed if laboratory experiments show potential harm, or if a substance with a similar structure has been known to harm humans.

Risk depends upon toxicity and dose:

• Toxicity is potential to cause harm. This varies with the substance; route of entry into the body; and the body’s response. For example, caustic soda may cause a chemical burn, silica may cause fibrosis of the lung. Carbon tetrachloride may cause dermatitis by defatting the skin and, after absorption, also affect the brain, blood and liver.
• Dose is the amount of the substance that is absorbed into the body. This depends on the concentration of the substance in different organs and tissues and the time it remains and stays active. Some substances accumulate in the body. In these cases, repeated low doses may cause harm.

How do hazardous substances enter the body?

The ease with which substances enter the body depends on their physical and chemical make-up. It could be a gas or vapour, an aerosol, fume, liquid, dust or fibre. For an aerosol, dust or fibre, particle size is important as this affects how far it can travel into the lungs. Once inside the body the substance’s effect will depend on its solubility in body fluids (such as water and natural oils) and how the substance reacts with the body's own chemicals.

The most common routes of entry are:

• Inhalation: breathing is the most common route of entry. Aerosols, fumes, vapours and gases can cause harm anywhere in the respiratory system and may also be absorbed into the blood stream. Particles of dust and fibre can also cause harm. Large particles are filtered off in the nose; smaller ones, or those breathed through the mouth, settle on the walls of the windpipe or throat and are coughed up and either spat out or swallowed. The smallest particles of dust and fibres can be inhaled down into the lungs where they can cause local damage or be absorbed into the blood stream.
• Skin absorption: the thickness of the skin and its natural covering of sweat and grease provide some protection. This means only a few substances are readily absorbed by this route, such as organic solvents and phenols. Substances can also enter the body through cuts.
• Ingestion: the swallowing of substances is most likely when contaminated fingers are placed in the mouth, or used to handle food or cigarettes. In addition, inhaled particles may be coughed up and then swallowed.

Acute and chronic effects

Substances may have acute or chronic effects:

• An acute response is immediate – for example, inhalation of chlorine irritates the respiratory tract. Acute responses usually clear up once the individual has been removed from the problem.
• A chronic reaction is much slower and often builds up after repeated exposures over days, weeks or years – for example, dermatitis of the hands due to repeated contact with solvents. Most chronic diseases require a much longer period for recovery and in some cases damage is permanent. Chronic and acute effects from a particular substance may be very different from each other and protecting against only one kind of effect may not control the hazard of the other.

Standards

Workplace Exposure Limits (listed in the HSE publication EH40/2005) currently exist to control workers’ exposure to many substances used at work.

But there are problems:

• The limits could give a false sense of security and do not always represent safe conditions.
• Some argue that many limits are still based upon the questionable Threshold Limit Values, developed many years ago in America.
• Women may be adversely affected at lower levels than men, and research often concentrates on men rather than women.
• Some chronic (long-term) effects may be unknown. Limits are often lowered as more information comes to light.
• Standards do not exist for many potentially harmful substances.
• Little is known about the effects of mixtures of substances that workers are exposed to.
• Supposed safe limits sometimes differ between different countries.

LEGAL AND OTHER STANDARDS FOR PREVENTION AND CONTROL

A considerable number of laws and regulations apply to chemicals and dusts. General duties can be found in the following chapters of Hazards at Work:

• SRSC Regulations 1977 – Chapter 3, with reference to safety representatives’ rights and consultation
• Health and Safety at Work etc. Act 1974 – Chapter 12
• Management of Health and Safety at Work Regulations 1999 – Chapter 13
• Workplace (Health, Safety and Welfare)Regulations 1992 – Chapter 45

The HSE’s guide to the COSHH regulations

The eight steps below are based upon the HSE guide COSHH: A Brief Guide to the Regulations (INDG136rev3).

COSHH Step 1: Assess the risks
The first step is to decide whether there is a problem with the substance(s) your company is using. This is called a risk assessment. The employer must:

• identify the hazardous substances present in your workplace
• consider the risks these substances present to people’s health Assessing the risk involves making a judgement on how likely it is that a hazardous substance will affectsomeone’s health. Employers should ask themselves:
• how much of the substance is in use and how people might be exposed to it
• who might be exposed to the substance and how often
• is there a possibility of substances being absorbed through the skin or swallowed?
• are there risks to employees at other locations, if they work away from the main workplace?

Legal responsibility for the assessment rests with the employer, but others can do some or even most of the work of preparing it. Except in very simple cases, whoever carries out the assessment will need to:

• have access to and understand the COSHH Regulations and relevant ACoPs
• be able to get all the necessary information and have the knowledge and experience to make correct decisions about the risks and the actions needed

Safety representatives should be involved in assessments as they have valuable contributions to make. They must also be informed of the results of the assessment.

COSHH Step 2: Decide what precautions are needed
If the employer identifies significant risks, they must decide on the action to take to remove or reduce them to acceptable levels. To decide whether risks are significant, employers can compare controls with:

• advice from COSHH Essentials
• the results of monitoring workers’ exposure with workplace exposure limits (WELs) published in EH40/2005
• good standards from the industry sector

Action must be taken if there are risks to health. If there are five or more employees, the employer should make and retain a record of the main findings of the assessment, either in writing or on computer.

The record should be made as soon as practicable after the assessment. It should include a record of:

• enough information to explain the decisions taken about whether risks are significant and the need for any control measures
• the actions employees and others need to take to ensure hazardous substances are adequately controlled

The assessment should:

• be reviewed when there is reason to suspect the assessment is no longer valid
• be reviewed when there has been a significant change in the work
• be reviewed when the results of monitoring employees’ exposure shows it to be necessary
• state when the next review is planned

COSHH Step 3: Prevent or adequately control exposure
The COSHH Regulations require prevention of exposure, so employers should:

• change the process or activity, so that the hazardous substance is not needed or generated
• replace it with a safer alternative
• use it in a safer form, for example, pellets instead of powder

If prevention is not reasonably practicable, the employer must adequately control exposure. This can be done using one of the following measures, in order of priority:

• use appropriate work processes, systems and engineering controls, and provide suitable work equipment and materials. For example, use processes which minimise the amount of material used or produced, or equipment which totally encloses the process
• control exposure at source, for example, by using local exhaust ventilation; and reduce to a minimum the number of employees exposed, the level and duration of their exposure, and the quantity of hazardous substances used or produced in the workplace
• provide personal protective equipment, but only as a last resort and never as a replacement for other control measures which are required

COSHH Step 4: Ensure that control measures are used and maintained
COSHH requires employees to make proper use of control measures and to report defects. It is the
employer’s responsibility to take all reasonable steps to ensure that they do so. This is why employees must be given suitable training, information and appropriate supervision (see Step 8 for a more detailed explanation).

COSHH places specific duties on employers to ensure that controls are kept in efficient working order and good repair. Engineering controls and respiratory protective equipment have to be examined and, where appropriate, tested at suitable intervals. COSHH sets specific intervals between examinations for local exhaust ventilation equipment, and records of examinations and tests carried out (or a summary of them) must be kept, for at least five years.

COSHH Step 5: Monitor exposure
Under COSHH, employers have to measure the concentration of hazardous substances in the air breathed in by workers where their assessment concludes that:

• there could be serious risks to health if control measures failed or deteriorated
• exposure limits might be exceeded
• control measures might not be working properly

COSHH Step 6: Carry out appropriate health surveillance
COSHH requires employers to carry out health surveillance in the following circumstances:

• where an employee is exposed to one of the substances listed in Schedule 6 of COSHH, and is working in one of the related processes – for example, manufacture of certain compounds of benzene – and there is reasonable likelihood that an identifiable disease or adverse health effect will result from that exposure
• where employees are exposed to a substance linked to a particular disease or adverse health effect, and there is a reasonable likelihood under the conditions of the work of that disease or effect occurring, and it is possible to detect the disease or health effect

COSHH Step 7: Prepare plans and procedures to deal with accidents, incidents and emergencies
This will apply where the work activity gives rise toa risk of an accident, incident or emergency involving exposure to a hazardous substance, which goes well beyond the risks associated with normal day-to-day work. Employers must prepare procedures, and set up warning and communication systems to enable an appropriate response immediately any incident occurs.

COSHH Step 8: Ensure that employees are properly informed, trained and supervised
COSHH requires employers to provide employees with suitable information, instruction and training about:

• the names of the substances they work with or could be exposed to and the risks created by such exposure to those substances
• access to any safety data sheets that apply to those substances
• the main findings of the risk assessment
• the precautions they should take to protect themselves and other employees
• how to use personal protective equipment
• the results of any exposure monitoring and health surveillance
• emergency procedures which need to be followed

The full text of the HSE guide COSHH: A Brief Guide to the Regulations (INDG136rev3) can be found at www.hse.gov.uk/pubns/indg136.pdf

Workplace exposure limits (WELs)

The HSC has established WELs for a number of substances hazardous to health. These are intended to prevent excessive exposure to specified hazardous substances by containing exposure below a set limit. A WEL is the maximum concentration of an airborne substance, averaged over a reference period, to which employees may be exposed by inhalation. WELs are listed in the HSE document EH40/2005 Workplace Exposure Limits. Correctly applying the principles of good practice in COSHH should mean that exposures are controlled below the WEL.

Registration Evaluation and Authorisation of Chemicals (REACH)

Around 100,000 different substances are registered in the EU, of which around 30,000 are manufactured or imported in quantities above 1 tonne. Adequate data on the environmental and health effects is available for only a small proportion of these chemicals. In December 2006 the European Commission approved a new set of regulations on chemicals called REACH. This will be implemented within the UK over the next two years.

REACH is based on the belief that industry itself should be responsible for ensuring that the chemicals it manufactures and puts on the market in the EU do not adversely affect the health of those workers exposed to them through their employment, the public who come in contact with them as users, or the environment. REACH will also simplify the control of chemicals in the European marketplace and replaces a large number of other directives with a single system of registration, evaluation and authorisation. REACH was primarily intended as a measure to protect the environment and consumers, but it also has implications for workplace safety.

The main themes of REACH are registration, evaluation and authorisation of substances manufactured or imported into the EU. There will be a duty on industry to collect, collate and submit information to the new European Chemicals Agency which will be set up in Helsinki from 2008. This information will have to cover all substances (with a few exceptions) if they are manufactured or imported into the EU in quantities above 1 tonne per year. In addition certain substances that are carcinogenic, mutagenic or toxic to reproduction will have to be authorised. Industry will also have to prepare risk assessments and control measures for those people using the substance. This should increase both the labelling of products but also the information on the data sheets that accompany them.

A consultation paper The Enforcement of REACH in the UK was launched by DEFRA in March 2007 at www.defra.gov.uk/corporate/consult/reachenforce/ consultation.pdf The Government will consider the responses received in order to inform the development of the national legislation that will supplement REACH to ensure that it can work as intended. (The TUC has produced a Briefing for Safety Representatives on REACH at www.tuc.org.uk/h_and_s/tuc-12870-f0.cfm)

WHAT CAN SAFETY REPRESENTATIVES DO?

Safety representatives should check that their employer is implementing the COSHH Regulations 2002 (amended), and fully involving safety representatives in implementation.

The TUC encourages safety representatives to use their rights under the SRSC Regulations to engage in the COSHH assessment process (see Checklist below).

Keep the workforce informed and involved

Workers are concerned if they think they are working with hazardous substances. Safety
representatives can:

• give them the facts about hazardous substances
• discuss whether management plans are adequate
• provide an opportunity for workers to express/register their concerns – by holding meetings, conducting surveys and using body mapping and risk mapping techniques
• inspect the workplace regularly, and
• encourage workers to report problems to management and safety representatives

Safety representatives should report their concerns and those of their members to management in writing. Use Chapter 7 above for ideas on how you can make sure that management get things done.

Risk management

Safety representatives should urge their employer to implement fully the COSHH Regulations 2002 (as amended). Ensure that the employer prepares and implements a plan to manage the risks. Safety representatives should:

• be involved by management in the process of tackling hazardous substances
• monitor how management is following its plan
• keep the workforce informed of progress

Risk assessments

Safety representatives should ask for copies of the risk (COSHH) assessments that the employer has done to check that they are preventing exposure to hazardous substances, and make sure that their employer is notifying them of any cases of suspected ill health within the workplace. Where control measures are in place then safety representatives can check that they are being adhered to and maintained and also that they are being effective in preventing ill health.

Training and information

Safety representatives should monitor that where there are potential risks, their employer has given all their workforce appropriate training and information on both the symptoms of ill health and how to avoid it. In addition, a system of health surveillance should be in place wherever there are risks.

Checklist

Download the Chemicals & Dust Checklist (PDF)

FURTHER INFORMATION
(in alphabetical order)

Department for Environment, Food and Rural Affairs (DEFRA) (see Section 6.3 for contact details)

• Latest developments on REACH
• Consultation on the Enforcement of REACH in the UK

Hazards magazine factsheets (see Section 6.2 for contact details)

• No. 63: Reproductive Health at Work: Women
• No. 61: Body Mapping: Body of Evidence
• No. 54: Cancer and Occupation
• No. 53: Toxics Use Reduction
• No. 41: Solvents and Brain Damage
• No. 40: Multiple Chemical Sensitivity
• No. 39: Asthma and Work
• No. 37: Fumes from Burning Plastic
• No. 33: Cutting Fluids/Machining Fluids
• No. 31: Substitution of Hazardous Substances
• No. 23: Wood Preservatives
• No. 22: Pesticides Safety
• No. 16: Chemical Exposure Standards
• No. 12: Textile Chemical Hazards
• No. 11: Polychlorinated Biphenyls
• No. 7: Diesel Exhaust Fumes

£1.50 each for union subscribers. £6 for nonsubscribers

Hazards magazine website

Excellent news and resources on the Hazards web resource page

HSE COSHH Essentials website

The HSE has a specific web page giving advice on controlling the use of chemicals for a range of common tasks.

HSE COSHH website

The HSE has a specific web page which draws together HSE information on controlling hazardous substances in one place. This includes details of the latest publication on workplace exposure limits (WELs), EH40/2005 Workplace Exposure

HSE priced and free publications on hazardous substances

• For all the latest documents containing general standards and guidance on hazardous substances, go to the HSE web page
• Alternatively, obtain a free copy of the latest HSE Books catalogue, CAT 34, by telephoning 01787 881165

International Agency for Research on Cancer

News and resources

Labour Research Department (see Section 6.2 for contact details)

• Hazardous Substances at Work: A Safety Representative’s Guide £4.25

London Hazards Centre (see Section 6.2 for contact details)

• The Chemical Hazards Handbook
• Chemical Safety Legislation
• Formaldehyde

Pesticide Action Network

News and resources

TUC (see Section 6.1 for contact details)

• The TUC hazardous chemicals web page
• TUC ‘ESCAPE’ route for dangerous substances
• REACH – a TUC Briefing for Safety Representatives
• Essential information for safety representatives. Keep up to date on health and safety by reading Risks, the TUC’s weekly e-bulletin for safety representatives.

Trade union information

• Many unions provide guidance on chemicals and dusts. The website addresses of all trade unions are on the TUC website
• Hazards magazine has listed the health and safety pages of most trade unions
• Contact your union, or visit your union’s website to find out if it produces any guidance. For example, BFAWU produces a guide to COSHH and Chapter 23 of the Unite – T&G section safety representative’s handbook covers hazardous substances

Copyright © Trades Union Congress 2008