HSE Health & Safety

Executive

Ways for SMEs to assess and control risks from hazardous substances

Report of an international workshop held on 26 & 27 November 2001

Prepared by TNO for the Health and Safety Executive 2002

RESEARCH REPORT 014

HSE Health & Safety

Executive

Ways for SMEs to assess and control risks from hazardous substances

Report of an international workshop held on 26 & 27 November 2001

S C H A Tijssen & I H M Links TNO - Environmental Toxicology

Schoemakerstraat 97 PO Box 6011

2628 VK Delft The Netherlands

In a lot of companies little attention is given to assessment of exposure to chemicals and to adequate control of risks. This especially applies for small and medium sized enterprises (SMEs).

In November 2001 the workshop "Finding ways to help small and medium sized firms assess and manage the risks from hazardous substances" was organised to share information on developments in Europe of tools for assessment and control. The participants of several institutes involved in this field agreed on statements on what is necessary to help SMEs:

● Small firms need simple tools that describe what they have to do in plain language.

● Any tool developed should have a sound scientific basis.

● An electronic tool is worth developing for the future as more and more workplaces and individuals access the Internet.

● Quite a few of the tools presented use safety data sheets as a starting point. Agreement on the fact that the more accurate these are the better for workers health.

The results of the workshop have led to action points to take this work forward.

This report and the work it describes were funded by the Health and Safety Executive (HSE). Its contents, including any opinions and/or conclusions expressed, are those of the authors alone and do not necessarily reflect HSE policy.

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First published 2002

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Summary In a lot of companies little attention is given to assessment of exposure to chemicals and to adequate control of risks. This especially applies for small and medium sized enterprises (SMEs). In November 2001 the workshop “Finding ways to help small and medium sized firms assess and manage the risks from hazardous substances” was organised by TNO and sponsored by HSE to share information on developments in Europe of tools for assessment and control.

In order to accomplish a successful workshop, participants involved in this field were invited from several institutes: INRS (France), BAuA (Germany), TNO (The Netherlands), IOM (Scotland), The Dutch Ministry of Social Affairs and Employment (The Netherlands), HSE (United Kingdom), and the University of Liege (Belgium). Also representatives from CEFIC and TUTB (Trade Union Bureau) were invited. Each institute presented recent developments of their instruments for assessment and control. Next, all participants were divided into four groups to discuss one of the following issues: 1. How can the accuracy of safety data sheets be improved? 2. Further validation of COSHH Essentials Hazard Bands and for the other tools presented at this

workshop. 3. Further validation of the exposure-rating system for COSHH Essentials and for the other tools

presented at this workshop. 4. Development of an Internet tool for small and medium sized enterprises to help them assess and

manage the risks from hazardous substances.

The results of the discussion in each of the four were shared plenary and the participants agreed onstatements on what is necessary to help SMEs: · Small firms need simple tools that describe what they have to do in plain language.· Any tool developed should have a sound scientific basis.· An electronic tool is worth developing for the future as more and more workplaces and individuals

access the Internet. · Quite a few of the tools presented use safety data sheets as a starting point. Agreement on the fact that

the more accurate these are the better for workers health. The results of the workshop have led to action points to take this work forward. A distinction was made between short term objectives, and medium and longer term actions.

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CONTENTS

1 INTRODUCTION 1

1.1 BACKGROUND 1

1.2 AIMS OF THE WORKSHOP 1

1.3 PROGRAM OF THE WORKSHOP 2

2 RESULTS 3

2.1 CURRENT DEVELOPMENT IN EACH COUNTRY 3

2.2 RESULTS OF THE FOUR SYNDICATES 11

3 CONCLUSIONS 15

4 ACTION POINTS 16

4.1 SHORT TERM OBJECTIVES 16

4.2 MEDIUM AND LONG TERM OBJECTIVES 16

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1 INTRODUCTION

1.1 BACKGROUND

All employers are legally bound to assess exposure to chemicals and to ensure that risks are controlled. However, in a lot of companies little attention is given to this assessment and options for control are used only limitedly. This especially applies for small and medium sized enterprises (SMEs).

In this field a lot of European organisations are active in developing instruments to help these SMEs to assess and control risks of hazardous substances. A lot of work has been done and some methods are already available. However, although solutions to the problem of assessment and control of exposure to chemicals in SMEs have been developed, a number of issues remain. For example, how national authorities can ensure that SMEs are aware of what guidance is available to help them; how to ensure that the guidance is simple enough for their needs; and how to ensure that guidance is technically valid so that SMEs protect their workers from the ill health effects of hazardous substances.

In 2000 a workshop was organised to share experiences on what (European) organisations are developing to help SMEs, and to discuss how the various projects interlink and how work can be taken forward for the benefit of workers in SMEs in the European Union.

HSE (Health and Safety Executive, UK) has taken forward the idea of organising another workshop to continue the work that has been done before. This resulted in the workshop “Finding ways to help small and medium-sized firms assess and manage the risks from hazardous substances” that was held on the 26th and 27th of November 2001. The main purpose of this workshop, sponsored by HSE and organised by TNO (Nederlandse Organisatie voor toegepast-natuurwetenschappelijk onderzoek, The Netherlands), is to share information between several European institutes on the development of best practice guidance for small and medium-sized firms (SMEs) on assessing and managing the risks from hazardous substances. This report reflects the contents, conclusions and action points of this workshop.

1.2 AIMS OF THE WORKSHOP

The main aim of the workshop was to share information on developments in Europe of tools for assessment and control for small and medium sized enterprises (SMEs). Several institutes are involved in this field and the goal was to reach agreement on where the various projects interlink. By the end of the workshop, delegates will agree on statements on what is necessary to help SMEs . The results will lead to action points to take this work forward.

One of the European tools that is already available in a detailed version is the COSHH Essentials, which is guidance for SMEs in Great Britain. This tool was developed by HSE in collaboration with industry and trades unions. Another aim of the workshop was to obtain information to help build the technical base of the COSHH Essentials. In addition, HSE is also interested in discussing the merits of a free electronic tool on the Internet for SMEs to help them assess and manage the risks from hazardous substances.

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1.3 PROGRAM OF THE WORKSHOP

In order to accomplish a successful workshop, participants were invited from several institutes: INRS (France), BAuA (Germany), TNO (The Netherlands), The Dutch Ministry of Social Affairs and Employment (The Netherlands), HSE (United Kingdom), IOM (Scotland) and the University of Liege (Belgium). Also representatives from CEFIC and TUTB (Trade Union Bureau) were invited.

Each institute presented recent developments of their instruments for assessment and control. IOM is not developing an instrument, but took the opportunity to share their experience (as being an SME itself) in assessment and control of risks.

Next, all participants were divided into 4 groups to discuss one of the following issues: 5. How can the accuracy of safety data sheets be improved? 6. Further validation of COSHH Essentials Hazard Bands and for the other tools presented at

this workshop. 7. Further validation of the exposure-rating system for COSHH Essentials and for the other

tools presented at this workshop. 8. Development of an internet tool for small and medium sized enterprises to help them assess

and manage the risks from hazardous substances. The results of the discussion in each of the 4 groups were shared plenary.

Finally, the workshop was reviewed and an action plan was developed. A distinction was made between short-term objectives, and medium and longer-term actions.

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2 RESULTS

2.1 CURRENT DEVELOPMENT IN EACH COUNTRY

2.1.1 The Netherlands (Ministry of Social Affairs and Employment and TNO)

Ministry of Social Affairs and Employment In The Netherlands, the Ministry of Social Affairs and Employment in The Hague develops policy on improving working conditions and is, together with the Labour Inspection, responsible for upholding the law on working conditions. Policy on toxic substances in SMEs is a part of the work of this Ministry.

In 2000, about 50% of the SMEs had no “validated” risk assessment, although many workers within SMEs are exposed to hazardous substances. Implementation of regulations on assessing and controlling risks of hazardous substances gave good results in large companies and “high tech” sectors, but poor results in SMEs. From studying the reasons why, it was observed that SMEs lack awareness and knowledge of hazards and risks. Furthermore, SMEs focus on production and do not allot time for items related to working conditions and environment. In spite of the efforts made to improve risk assessments in companies, such as updating regulations and informing the sectors at risk, most SMEs have yet to introduce policies on toxic substances. In 2000, the Ministry improved regulation on quartz and solvents and introduced a new instrument, the covenant. Within this framework, agreements were also made on toxic substances in the printing, car repair, furniture, bakers, and construction industries. Results from the covenants are expected in 2004.

In the near future a new national strategy on handling dangerous substances will be introduced in the Netherlands, called SOMS (Strategy handling of dangerous substances). The essence of this new strategy is a “chain approach” of substances, such that risks have to be assessed from manufacturing/mining of the substance, to getting rid of the product containing the substance. The main objective of SOMS is to improve the quality, availability, and communication of information on substances.

The Ministry is still struggling with the following questions: • Should we introduce the COSHH Essentials in the Netherlands? • How can we promote communication on hazardous substances? And what can be the role

of the Internet in this? • How can the government support direct technical advising?

TNO The work of TNO in the field of risk assessment and control in SMEs, consists of two studies. One is focussed on the development of trade specific knowledge systems, while in the other a generic instrument for risk assessment and control is being developed. The Ministry of Social Affairs and Employment finances both projects.

Some years ago, TNO performed a study on hazardous substances policies in SMEs, dealing with worker exposure and health. This study was done in 5 trades. Information was obtained by means of interviews with stakeholders such as representatives of trade-organisations, occupational health services, labour inspection, and employers. Information was gathered on aspects such as risk assessment, elements influencing hazardous substances policies, and

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sources of relevant information on occupational hygiene aspects. General conclusion was that tackling the problem trade specifically has the highest potential of success. Furthermore, it was concluded that there are various ways for improvement and that it is impossible to give one solution that can be applied SME-wide. Four areas for improvements were indicated: • The limited risk perception of the SME employer. • The limited communication between relevant actors, such as labour inspection,

occupational health services, and employers. • The difficulty (SME) employers have to comply with legislation. • The limited availability of relevant information, such as information on exposure, on risks,

on control, and useful instruments. The current TNO research mainly focuses on the availability of information and instruments.

Trade specific knowledge-system A system with (already existing) relevant information on exposure, risks, and control is being developed. The choice was made to design the system with the employers being the primary users, because they are primarily responsible for the policy on hazardous substances in their company and most of them lack relevant information to deal with this properly. Making the system available to employers is a part of the project. At this moment, a pilot study is done in the stained glass and the rubber industry. These trades are very different with respect to organisation and availability of exposure data. The pilot studies should lead to a generic approach and framework, which can be used to develop a trade-specific information system for SMEs in any trade. It is important that the system is supported by all relevant actors. Therefore, in each trade, a group of representatives (such as the trade organisation, occupational health service, labour inspection, suppliers, and employers) forms a sounding board, with a central role throughout the process. This board will supply TNO with relevant information and act as a go between to others in the trade. TNO and the sounding board have several meetings throughout the development of the system, to decide on contents, structure and lay-out of it In both trades, the choice was made for a system that was task based. Together with the sounding board, the most relevant tasks (which were assumed to be tasks with the highest risks) were selected. For the stained glass a paper version of the system was developed, while for the rubber industry an electronic version is being developed. Rough content of the trade specific knowledge system: • An introduction with general background information, such as legislation and principles of

control. • Central part of the system consisting of task based information sheets, with information on:

the task, the exposure moments, the risk class (1-4), Occupational Exposure Limit(s), health effects of used or emitted substances, known exposure levels, and control strategy.

Experiences so far The communication on hazardous substances within the trade has increased or started where it was absent. The risk perception among the sounding board and represented organisations involved is also increased. There is a lot of relevant information available in a branch of industry. By combining this with the information from other sources, a system is made with brief but practical and relevant information, ready for use by the employer (and others). Developing a trade-specific system is time consuming (and expensive), but this may largely improve once a generic approach is available.

It is important that the system is implemented properly in the trade so that employers are stimulated to use it. Even an excellent system or instrument may fail if it is not supported by a proper implementation process. In the pilot study, the trade is made owner of the system and is responsible for future use, including the implementation. Support from relevant actors is important in this. One of the other responsibilities of the trade is the update of the system and to

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add new information (e.g. other tasks). Next step is to get the system recognised by the labour inspection. When recognised, an employer will know that he complies with legislation when working according to the information presented in the system. Last but not least, it is tried to connect the knowledge-system to other instruments directed at the control of dangerous substances (e.g. the environment).

Generic tool Another part of the TNO project is the development of a generic tool for SMEs to assess and control exposure to chemicals. SMEs in the Netherlands fail to do this adequately. As stated before, the main causes are a lack of practical information on risks, a lack of suitable information on control measures, and the absence of easy-to-use tools. The tool that is being developed combines parts from existing instruments into a tool that is rewarding for the SME­employer. The goal is that the employer’s awareness of the risks of exposure to chemicals increases when using the tool.

Information on characteristics of SMEs and information on existing instruments were collected to make up a list of criteria and make a first draft of the tool. This draft also includes ideas for the implementation of the tool. At this moment, the draft is being discussed with experts, such as policymakers from the Ministry, toxicologists, and representatives from umbrella - and trade organisations. Criteria for the tool, besides being directed at chemicals and compliance with the Dutch law: • It should be part of a company’s policy and not be used as a only-once obligation. • It should not only focus on assessment, but also on risk-control. • It should be tuned to the SME employer, which means it should be practical, simple, easy

to use, written in plain words, flexible, and recognisable. In short, the tool should focus on raising awareness and offering solutions, which is more important than a scientific evaluation of the exposure.

From the evaluation of several European instruments it was concluded, among other things, that UK’s COSHH Essentials (especially the control section) and the Austrian “Chemische Arbeitstoffe” are both practical and appealing. Colour schemes of the Austrian method show what is good and bad and at the same time visualise what needs to be done to improve the situation. Information and training is seen as a strong aspect of the Swedish Wisp. It includes a helpful visualisation method that combines measurements with a presentation on video to show the employees how exposure differs between tasks. A teamwork process is an aspect that is provided for in the Finish Strategy on hazardous substances. This method emphasises co-operation within the company. In general it is seen that all the instruments studied, contain useful aspects.

Since TNO wants to develop a tool that will be used and not disappear into the drawer, it should be more than instructions on paper. The tool should not only focus on the contents of assessment lists etc. (the instrument itself) but also on implementation of the policy in the company. TNO is of the opinion that the only way to succeed, is to work together with the SME employer. He is the expert on the company-process, whereas TNO and the Ministry are experts on exposure and control. Organisations that are familiar to the SME employer e.g. trade organisations or health and safety services have an important role in the implementation of the policy on hazardous substances.

Based on the information described above, an instrument was compiled. It is not finished yet, but will probably become a brochure with roughly the following contents: • Introduction (why this instrument, what are hazardous substances, legal obligations). • Listing of the hazardous substances:

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- Inventory of hazardous substances and the workplaces where they are used or formed.- Inventory of the hazard based on information in MSDS.- Assessment of exposure (kind of exposure, route, frequency, and exposure time).

• Evaluation of the risks of use of this substances (combination of hazard and exposure, by means of a matrix).

• General suggestions for risk-control (source control, ventilation, separation, and personal protective equipment).

• Literature: a list of (technical) definitions and addresses of organisations for more information on hazardous substances.

TNO still needs to put in details for the implementation. The idea is to plan two meetings with a group of employers. One, done by e.g. an occupational hygienist, to introduce the instrument. Another, after the employer had some time to test the instrument in his company, to evaluate the results and to share experiences on control measures. The support of experts should be available during this process.

The instrument is a generic framework. It can be seen as a first introduction and offers a way to deal with risks of hazardous substances. In the end, trade-specific instruments are a better way to achieve the objective that SME employers assess and control risks of hazardous substances, because the information is more customised and recognisable for the employer.

2.1.2 Germany [Bundesanstalt für Arbeitsschutz und Arbeitsmedizin (BAuA)]

Introduction In Germany, occupational safety and health legislation on hazardous substances is laid down in the “Hazardous substances ordinance” of the Chemical Act. The Federal Ministry of Labour and Social affairs is the competent authority of the “Hazardous substances ordinance”. Furthermore, Germany knows sub-legislation (technical rules) and support (leaflets and practical guidelines). The Committee on hazardous substances advises the Federal Ministry of Labour and Social Affairs. The Committee has 40 members spread over 5 subcommittees: (1) protection measures, (2) hazard information and communication, (3) occupational medicine, (4) workplace risk assessment, and (5) occupational exposure limits.

In a research project, performed by BAuA (Federal Institute for Occupational Safety and Health) in1994, it was concluded that SMEs largely lacked basic qualifications, were unaware of their legal obligations to control hazardous substances, and many lacked the basic knowledge needed to fulfil those obligations. BAuA concluded that a more intense external support was needed. In supporting SMEs, BAuA came across the following problems: • Hazard identification (for many substances/products information is lacking). • Toxicological data gaps (makes classification of substances difficult). • Hazard communication (SDS difficult for SMEs and gaps in information). • Adequate precautions (are difficult to find). • Monitoring of OEL (relatively few OELs, no practical monitoring strategy and no OELs for

dermal exposure).

Sub-legislation Technical rules (sub-legislation), such as TRGS (“Technische Regeln fur Gefahrstoffe”) 500 are used to provide SMEs with information. In TRGS 500 “Protective measures: minimum standards (1998)” protective measures are described which can be used when handling chemical agents. In TRGS 440 (2001) a procedure to identify and assess risks caused by hazardous substance in the workplace is given. The basis for the risk assessment is (toxicological)

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information from the producer/supplier of the substance. The so-called “Column model” and the “Health effect (W-) factor model” make comparison of substitutes of a substance possible/easier. In several TRGS 6xx substitution of a hazardous substance (group) is described. In TRGS 420 task/ process– and substance specific criteria are given.

An example of a trade -specific guidance is the GISCODE, a hazard-based product code to which control measures listed in WINGIS (occupational safety & health information, protection measures for each product code) are added. GISCODEs are available for wood preservatives, paints, cleaning agents, polyurethane products, epoxy resins, surface treatment of wooden floorings, bitumen products and primers/adhesives.

The implementation of Directive 98/24/EEC in Germany includes the following: • Basic regulations (no legislation on details). • Workplace risk assessments. • Structured occupational safety and health concept. • Use of OELs in control strategies. • New concept for medical surveillance. • Strengthening of the position of SMEs.

BAuA focuses on a simple control scheme that helps employers with little chemical competence to identify hazardous chemicals at the workplace and select effective control measures.

Toxicological data and hazard banding Within a simple control scheme for SMEs, complex toxicological data obtained from different studies have to be transformed into a limited number of useful parameters ("hazard bands"). Only rarely, it is possible to use OELs for this purpose because of the low number of occupational limit values officially established. Using R-phrases instead may lead to considerable loss of toxicological information. BAuA thinks that the following procedure might represent a satisfactory alternative: In human health risk assessment for „existing“ substances in accordance with Council Regulation (EEC) 793/93 each chemical substance is evaluated to identify the exposure levels which mark the border of concern. The general approach and the methods behind are harmonised and agreed upon within the EU member states. As examples the reports on 2(2-methoxyethoxy)ethanol (NL), 2(2-butoxyethoxy)ethanol (NL), 1-vinyl-2-pyrrolidone (UK), nonylphenol (UK), but-2-yne-1,4-diol (D), and aniline (D) are outlined. It is shown, that the so-called „MOS approach“ to identify critical exposure levels easily could be modified for the purpose of hazard banding in support of the generic control approach. The results are compared to those obtained with the R-phrase based procedure. Marked differences indicate that it is essential to use all the substance specific toxicological information availa ble for the decision on a certain hazard band and support the approach with the principle of precaution to overcome uncertainties arising from the database.

Evaluation of exposure data BAuA has collected occupational exposure levels from a variety of industries for different control strategies (of the COSHH Essentials). Few exposure data were found on the highest control strategies. Predicted exposure levels (the COSHH Essentials) have been compared with measured exposure levels. For solids, predictions correlate fairly well or good with measured exposures, e.g. filling, and weighing powders in the plastic industry. For solvents, measured data are in most cases located at the lower end of the predicted exposure range, e.g. screen printing industry. This means that controls based on predictions would have provided an adequate protection, but this may also lead to overprotection. Examples of comparison

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between predicted exposure and measured exposure were given: furniture industry, carpenter’s workshops, and optician’s workshops.

2.1.3 United Kingdom (HSE)

Evaluation of the paper version of the COSHH Essentials and future developments To obtain a quantitative view of the impact of the COSHH Essentials, HSE commissioned market researchers to undertake telephone interviews with 500 firms who purchased the guidance. The target sample of firms was restricted to establishments with up to 249 employees. The survey found that 80% of firms who purchased the guidance have used it and only 5% of these found it fairly difficult to use. More than three-quarters (80%) of the firms that used the guidance have made some improvements to their workplace control of chemicals. The majority of respondents who took no action did so because the guidance reassured them that their existing control measures were sufficient. Only one in twenty of the firms that purchased the guidance have found it to be not relevant to their work.. 94% of purchasers would recommend the guidance to other businesses.

Most purchasers have the Internet available or are likely to do so soon; a majority (67%) expressed their interest in an Internet version. In addition, the majority supported the development of integrated health, safety and environment advice on chemicals. Furthermore, 75% checked existing control, 50% provided information or training to workers, about 40% changed control measures used, 25% changed work procedures, and less than 20% choose for a substitute.

Planned developments of the COSHH Essentials are: • Control guidance sheets for the “local authority” sector. • Process emissions (fumes/ gases and dusts). • Incorporation of control guidance sheets covering the top 8 causes of occupational asthma. The intention is to implement these developments through the Internet version.

Additional possible ideas are: • Protective measures against residual risk (RPE, skin exposure). • Activities such as maintenance, sampling, and cleaning. • Procedures (monitoring, permits to work, health surveillance, and records).

Developments towards integrated guidance on chemicals A cross government initiative that will help small firms manage the health, safety, and environmental risks from chemicals in the workplace was announced recently. The innovative new Internet based system will bring together advice in these areas and tailor it to address the needs of individual firms. The project has been made possible through funding from the Treasury's Invest to Save Budget and illustrates the UK’s commitment to the delivery of modern and joined up government. It will help meet commitment made in relation to the Chemical Agents Directive to provide firms with integrated guidance on health and safety.

HSE and the Environment Agency are collaborating on the development of the system, which is expected to take three years. The Treasury is contributing £250,000 to the cost. The project recognises that smaller companies in particular often face difficulties when trying to comply with a plethora of legal duties. Currently, firms that use chemicals in the workplace may have to consult many different guidance documents and agencies, in order to ensure that they have all the information needed. This project will allow information on the health, safety, and environmental risks from chemicals to be accessed through a single electronic gateway. It will also give its customers user-friendly advice relevant to the circumstances of each enterprise.

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Aims are: • Reduce small firms’ costs in complying with chemicals legislation. • Provide a compliance measuring tool. • Help reduce risks. • Help modernise the government. • Straightforward, comprehensive, and comprehensible guidance. • Integrated advice for small businesses on health, safety, and environment. • Practical, targeted. • Links with other guidance. • Free access.A framework is expected in 2003 and a full system by 2004.

COSHH Essentials and Global Harmonisation Classification criteria of the Globally Harmonised Hazard Classification and Labelling Scheme (GHS) were compared with those of the EU. Currently the COSHH Essentials uses the EU classification system. The HSE concluded that current EU-based and proposed GHS hazard grouping schemes result in identical COSHH Essentials control solutions for most substances. Where there are differences, the GHS scheme generally gives a more stringent control solution. Furthermore, it was concluded that GHS classes assigned on basis of human data with no consideration of potency could result in very stringent control solutions. The COSHH Essentials process is being used by the International Labour Organisation to develop guidance for developing countries. This guidance will use the Global Harmonisation System of classification.

Electronic COSHH Essentials A demonstration of the Internet version of the COSHH Essentials (CD-ROM based) was given. Users of the Internet will be able to access this free interactive tool which will help them to carry out a risk assessment and put the right control solution in place.

2.1.4 France [Institut National de Recherche et de Sécurité (INRS)]

In France, the INRS has been developing a method for assessing risks from chemicals in co­operation with the CNPP (National Centre of Protection and Safety). Employers of SMEs have to have a policy on risks of hazardous substances, including occupational health, safety, and environment. This is difficult for the employers, because of the diversity of substances, complexity of regulation, the lack of knowledge on risks, the few private experts in industrial hygiene in France, and la ck of tools that are able to cover the whole field. Tools are needed that identify risks, propose compatible solutions/control measures, and provide the workers with information.

The method/tool of the INRS consists of three steps: • An inventory of chemicals and products. • Ranking of potential risks. • Assessment of risks. The potential risk is determined by the hazard of the substance and the potential exposure to the substance. For a majority of the substances, the hazard is assessed based upon the R-phrases of the substance. The potential exposure is determined based upon the frequency of use and quantity of the substance used. With the hazard and potential exposure, a score for the substance is calculated and the potential risks are ranked. The number of workers exposed may also be included in this calculation. (Examples see copies of transparencies). The result from

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this step is a priority list of workplaces. The next step is to collect more information per workplace on physical properties of the substance (physical state, dustiness, boiling point) on use pattern (open or closed system, temperature of the process) and pattern of control (ventilation). Furthermore, information on task duration and chemicals used per task is collected. For a workplace, a risk score is calculated by this information. At the end workplaces and tasks are ranked and control measures can be taken for the tasks with the highest risk. A similar method is developed for safety.

The method is a basis for discussion within a company. So far, the INRS method has been used with success in several firms. An electronic version in being developed.

2.1.5 Belgium (University of Liege)

The University of Liège used the INRS method and the COSHH Essentials in making risk assessments for two companies. In Belgium, the occupational physician is an external advisor for (small) firms for prevention and protection at the workplace. The safety officer is the expert on occupational hygiene within the company. The occupational physician, safety officer, and company provide information and knowledge needed to make a risk assessment.

The tasks/companies involved were a company (80 employees) filling and mixing a wide range of chemicals and a company (950 employees) painting and coating. Retrieving all the information needed was very time consuming, especially because a lot of data were missing or inconsistent. As an example some MSDSs were missing, not up-to-date, inconsistent, or did not correspond with the products that were actually used. Solutions for the difficulties the University of Liège came across were proposed. To make (toxicological) information on substances easier accessible an Internet site has been build (http:/www.regetox.med.ulg.ac.be).

For the future the following questions remain unanswered: • How can we proceed in collecting basic information? • Who can we assure the accuracy of MSDS? • If we create a database what information should it contain? • How can we integrate the addition rule in the risk assessment according to the COSHH

Essentials?

2.1.6 Scotland (IOM)

Presentation of a case-study

Background-information: • UK is ambitious regarding occupational health targets (including 20% reduction in the

incidence of work-related ill health; 20% reduction in ill-health to members of the public caused by work activity; 30% reduction in the number of work days lost due to ill health, all by 2010), published in Securing Health Together.

• To achieve these targets, also SMEs need to do a risk assessment. The provision of good guidance is necessary but only a part of what needs to be done.

Results risk assessment at IOM’s: • The IOM is a SME with 90 staff. Despite all the necessary in-house expertise, they still

need to work hard to comply with health and safety legisla tion.

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Conclusion: • To improve health and safety at work in small businesses, the legislation needs to be

streamlined and integrated so that SMEs know what to comply with, the guidance is more accessible, and the benefits are more obvious (immediate financial benefits such as tax breaks or real reductions in insurance costs) and the deterrent for failing to comply greater (i.e. more enforcement or policing).

• Accept that improvements in health and safety at work will increase costs and demands on small businesses.

Recommendations: • Make sure that the benefit of doing nothing (cost saving) is less than the benefit of doing

something and that benefits are not only a longer term issue. • Make Health and Safety Management “do-able” (i.e. SMEs know what to do). • Make sure that there is a uniform, comprehensive enforcement.

2.2 RESULTS OF THE FOUR SYNDICATES

2.2.1 Syndicate 1: How can the accuracy of safety data sheets be improved?

Starting point:Information on safety data sheets is often incorrect. This leads to problems when using instruments like the COSHH Essentials.

Current situation: • Safety data sheets are needed by law. • Good consistent approach within the EU is available but safety data sheets are not read or

understood, especially by SMEs, and difficult to produce. • Insufficient information available on safety data sheets. • R-phrase (risk-phrase) & boiling point are often inaccurate and not good for sound

approach. • Safety data sheets often contain unhelpful information, e.g. wear suitable protective

clothing.

Intended situation: • Use of simple language. • Use of accurate information, in particular on R-phrases & boiling point. • Standard phrases. • Use of (more) color & symbols. • Use of communication experts, instead of only using technicians, to write the SDS. • Common access to accurate data in a central database. • Production of simple safety data sheets.

Actions in the short term: • Discussion with (small) users & suppliers to find out what the real needs are. • Integrate production of safety data sheets with the one-stop-approach (safety, health and

environment). • Organize a tri-partite workshop (with the support of big companies).

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Actions in the longer term: • Develop a database, sponsored by the European Union, using standard phrases with expert

system available. • Make sure that the database is not only for pure substances but also for preparations. • Make sure that this database is a freely available tool through the Internet.

2.2.2 Syndicate 2: Validation of hazard banding for COSHH Essentials and for the other tools presented at this workshop

Starting point:The hazard banding of instruments like the COSHH Essentials has been validated but HSE welcomes advice to validate it still further.

Current situation: • The hazard banding of the COSHH Essentials has been validated but further validation

would be useful. However, the goal is to keep it pragmatic. • There is a lack of toxicity data and sometimes this is rewarding for the user of the SDS (i.e.

leads to a low(er) risk).

Intended situation: • OELs (occupational exposure limits) take preference over R-phrases in defining the hazard

band. • R-phrases are used as surrogates in the absence of OELs. • It is acceptable that R-phrases lead to a more protective system, due to a higher level of

uncertainty. • If the R-phrase leads to a too restrictive band, the supplier or producer can set an in-house

developed OEL, which can be published through the safety data sheet – however, a general approved procedure to develop OELs should be made.

• Lack of toxicity data should not be rewarding.

Actions: • Harmonise the R-phrases rating system and make sure that the system how to incorporate

the OELs in hazard bands is transparent in the guidance. • Put hazard bands on safety data sheets • Consider having an European Union committee for hazard banding, but avoid to give it a

too official status. • Develop an approach how to handle data-gaps (e.g. if no toxic data are available, the

highest hazard band should be assigned).

2.2.3 Syndicate 3: Validation of the exposure-rating system for COSHH Essentials and for the other tools presented at this workshop.

Starting point:The exposure banding of instruments like the COSHH Essentials has been validated based on expert judgement but not validated by exposure data.

Current situation: • The exposure banding of the COSHH Essentials is not validated sufficiently. • Overall goal of this validation is to validate the result of using the tool and to check if there

is an adequate control of the risk.

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• Problems with existing data: - Not all is documented. - Information is not task-based; and by putting the data in a model (like EASE), the

“circumstances” under which they have been collected, are lost. - Furthermore, the pattern of use is unknown and the task duration is not known either.

Therefore, task-related information should be gathered. - Next problem is if it is also proven that control measures have their effect. According to

HSE, the COSHH Essentials does. - Classification of control might be difficult: e.g. would good LEV in a dirty workplace

be control 1 or 2? • Validation is especially an expert-issue. The user of the tool (i.e. the SME employer’s)

interest is to have a tool that offers good results. • In the COSHH Essentials 3 exposure aspects need to be compared with the hazard: quantity

(high, medium, low), dustiness (or volatility) (high, medium, low), or control (general ventilation, engineering control, containment, special). This leads to (3 x 3 x 4 =) 36 exposure categories that need to be validated.

Intended situation: • The tool should be validated with measurement data. • The validation should be done adequately but with a minimum set of data (to save costs). • The validation should focus on three aspects:

Decisions: If two different users use the system, do they make the same decisions? (precision)

Qualitative: Is the result of use by an SME employer the same as it would be in case of use by an expert?

Quantitatively: Are the suggestions for control as offered by the instrument the same as they would be if based on other information?

• Criteria for acceptability are essential. • The table shows what should be validated. Part of this validation is already covered by

existing information from measured data – these parts can be crossed of.

Table 1 Exposure rating categories

Quantity

Small Medium Large

Dustiness Low 1 2

3 4 Medium

High 1 2 3 4

1 – 4 = control

Actions: • Goal is to fill in the cells of the table above in a co-ordinated manner, with a minimum set

of parameters (data) and by doing so, to obtain a well validated instrument.

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2.2.4 Syndicate 4: Development of an internet tool for small and medium sized enterprises to help them assess and manage the risks from hazardous substances.

Starting point:What is the opinion of the group regarding the development of an internet tool for SMEs to help them assess and control risks of chemicals?

Current situation: • There are data gaps that make updating of databases not easy. • Some industry’s data are confidential. • Competence is needed to do risk assessment & exposure assessment. • The format of a safety data sheet is uniform between member states. • There is a difference in substance information and task information between producers of

chemicals, formulators of preparations and users:

Figure 1 Differences in information level

Substance information Task information

High Maker Low

Formulator of preparations

Low User High

Intended situation: • SMEs are able to do a risk assessment. • Therefore, an adequate tool needs to be available. • Preferably, this tool is available through the Internet. • In addition, this tool should fit to the knowledge of the SME-employer who, in general,

knows little about risks and more about how to work with a product.

Actions: • Develop three internet-tools with different levels for different uses of the tool (one for the

maker/manufacturer, one for the formulator and one for the user). An example of a tool for a user is a product-code like GISCODE, based on a combination of product and task. Manufacturers should communicate this codes to the formulator.

• Make sure that there is a link between syndicate 1 and 4: there should be risk assessment by user of the product. And there should be a link between the product and the way of use.

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3 CONCLUSIONS

The participants of the workshop agreed on the following points: • Small firms need simple tools that describe what they have to do in plain language. • Any tool developed should have a sound scientific basis. • An electronic tool is worth developing for the future as more and more workplaces and

individuals access the Internet. • Quite a few of the tools presented use safety data sheets as a starting point. Agreement on the

fact that the more accurate these are the better for workers health. • There is full support for the work of the European Commission with regard to hazardous

substances (as is the development of a Chemical Agents Directive guideline).

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4 ACTION POINTS

A framework for the action planning was created by answering the following questions: 1. What are the things that need to be done in the short term? 2. How can well-validated controls in small and medium-sized workplaces be achieved? 3. What needs to be done in the longer term?

4.1 SHORT TERM OBJECTIVES

The short term objectives that emerged were:

• The CEFIC representatives agreed to approach UNICE to ask whether they would be prepared to organise and fund a workshop for suppliers and users of safety data sheets, with government representatives and experts also being invited. The aim of the workshop would be to convince suppliers and users of the importance of achieving accuracy and simplicity when drafting safety data sheets and to ask them their views on how this could be achieved. This links in well with the view of the 2nd syndicate that, after harmonization, hazard bands should be put on safety data sheets.

• A HSE representative will circulate the background concept of the one-stop shop of the COSHH Essentials to all participants of the workshop. All participants will consider what the success criteria for such a project would be, how it can be linked to the Dutch “SOMS­project” and the international “White-paper discussion”, and will also consider whether it is worthwhile having a meeting in about a year's time on the one-stop shop. If the consensus is to have a meeting, the participants need to consider how this would be funded and organised.

• An e-mail network will be set up to discuss how to prioritise the validation of exposure data used to arrive at control solutions. A BAuA representative agreed to start this off.

• Another BAuA representative explained that BAuAs project on dusts will support this work and he promised to inform members of this network about the ongoing results.

• A HSE representative agreed to circulate two documents: "How to evaluate a study" and "Data to collect regarding evaluating exposure".

• One of the CEFIC representatives agreed to approach ILO with a view to exploring whether they could collect information (exposure data) on a formal basis.

• Participants of the workshop agreed that the issue of OELs taking precedence over R­phrases in the COSHH essentials should be taken forward as a one stop shop issue.

4.2 MEDIUM AND LONG TERM OBJECTIVES

• It was agreed that there is duplication in research that is done, and instruments that are being developed. Therefore, it seems a good idea to set up a database to inform participants of the workshop of who is doing what. It was mentioned that there's already a database called HEROX, but that there is still a need to agree on key-words. It was agreed that members should e mail TNO with ideas as to how this could be taken forward.

• Participants of the workshop also agreed to e-mail TNO with their top three ideas for medium to long term objectives to take this work forward. It was agreed that it would be best to do this after members have seen a copy of the draft of this report.

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