If you’re working with chemicals, safety data sheets (SDSs) are essential, so that you are aware of the hazards and risks associated with using and handling the material. SDSs also help you understand how different substances react under certain circumstances and if there are any special precautions that need to be taken. Morag McWilliam and Tristan Pulford explain in this article how this is important because materials need to be stored and handled correctly. There are further implications with regard to regulations such as DSEAR (Dangerous Substances and Explosive Atmospheres Regulations) and COSHH (Control of Substances Hazardous to Health).
If you missed part one of this article you can catch up here.
The Importance of Safety Data Sheets.
You are legally required to have SDSs for any chemicals used in your workplace. This means that if you work with chemicals and don’t have up-to-date SDSs available for them, your company could have enforcement action taken against them by Health and Safety Executive or the Environment Agency depending on the circumstances.
Every manufacturer or supplier must make the SDS available to the user of any chemical classified as hazardous. This can cause challenges where the product is produced by a company, and then shipped to other sites for further manufacturing, however, the SDS is still required. (In practice, this can be done either by transporting the chemical with a hard copy or providing a link to the document online.)
Who needs to read and understand the contents of an SDS?
Anyone who is handling or potentially exposed to the material through the course of working with it, storing and transporting it and cleaning up accidental spillages and releases of it should read and understand the information on the SDS and how it relates to their actual or potential contact with the material. As well as operators, it is important to remember to ensure that cleaning and maintenance staff and contractors read and understand the information.
(Please also section on substances hazardous to health below regarding the use of the information in the SDS for the completion of risk assessments required by the Control of Substances Hazardous to Health Regulations, 2002 (as amended).
Potentially Explosive Substances and DSEAR.
Some of the substances used, whether they be dust, fluids or gases may fall under the DSEAR Regulations. Obviously to comply with these regulations the first step is to identify that the substances being handled are potentially explosive.
HSE define a dangerous substance (with regards to DSEAR) as:
“Dangerous substances are any substances used or present at work that could, if not properly controlled, cause harm to people as a result of a fire or explosion or corrosion of metal”
If a SDS is created properly then Section 2 (Hazards Identification) should be the only section that is required to identify whether the substance may fall under DSEAR.
Any substance which is listed as flammable, very flammable, oxidising or corrosive falls under DSEAR, if it is a dust, fluid or vapour. In experience, however, section 2 can be badly filled in or may include a note at the bottom stating “Maybe explosive when in powder form” or equivalent.
This can also be confirmed within section 9 (Physical and Chemical Properties) which includes details about the potentially explosive properties. It should be noted that any fluid with a flash point above 60 °C does not fall under DSEAR unless it is handled above this temperature under the current regulations.
Substances hazardous to health.
Working with substances hazardous to health is usually governed by the COSHH Regulations *, which require the employer to assess the risks to health which arise from the use of hazardous substances.
You will need to use the information contained in the SDS to complete your COSHH assessment.
However, it is important to note that copying the hazard information directly from the SDS does not constitute a suitable assessment. For this, you must take the information in the SDS and apply it to the substance is how it is being used in your operations.
(*Some materials such as Lead and Asbestos (not exhaustive) are governed by separate Regulations, but the SDS information should still be used in any assessment of work with these materials.)
SDSs list the known hazards associated with a substance together with information on matters such as physical properties, exposure limits and first aid measures. As well as it being a legal requirement to hold current SDSs for the materials handled on-site, they are a useful resource for completing risk assessments required under Regulations such as COSHH and DSEAR.