Occupational Exposure Limits A New Approach plus COSHH Essentials phase 2 Michael Topping Chemical and Flammables Policy Division Health and Safety Executive

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 21 st 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 QuestionNumber replying YesNo Agree with concerns on current system 41 0 Agree with need for change Agree with key objectives for new approach Total number of responses – 56. No comment from 6.

Respondents Views on the 3 Options

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.

WELs compared to OESs and MELs OESMELWEL Standard must be met Limit must be metLimit must not be exceeded No requirement to further reduce exposure Exposure must be reduced ALARP If standard exceeded, steps taken to comply as soon as reasonably practicable Limit must not be exceeded

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 a) 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

Good Practice Advice Hand finishing in a carpentry workshop:  Good practice = LEV Large scale machining of logs:  Good practice = enclosure and automation E.g. Wood Dust Determinants: - Hazard; Scale of use; Task Designed to keep exposures below the WEL

Providing Good Practice Advice Supporting use of COSHH Essentials as source of good practice advice Electronic package linking WELs, COSHH Essentials, COSHH guidance useful to most / minority of dutyholders or not useful

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 WEL determines COSHH Essentials hazard group R phrase determines COSHH Essentials hazard group YesNo

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

Transferring existing OELs into the new system

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