JSP 375 Vol 2
MoD Health & Safety Handbook
52 If, however, the substances in use are particularly toxic, carcinogenic, have a specified MEL or the
information supplied by the supplier does not match with other sources of authoritative guidance such as
HSE guidance notes etc. then extreme caution will be warranted. These cases should always be
referred for specialist advice unless you are absolutely certain that exposure is not significant. It is also
important to use your own judgement and look for obvious discrepancies. For example: if all the control
measures recommended by the supplier are in place but there are obvious problems such as fine dust
deposits on people or surfaces, particles visible in the air, complaints of discomfort or ill health amongst
the workforce then you should seek specialist advice. So your answer to Question (a) would therefore
be No and CONCLUSION 5.
(b) Would the process present significant risks to health if no controls were in place?
53 Assuming that your information sources are satisfactory you should now be able to decide whether
the health hazards posed by the products are significant. This requires a balanced judgement combining
your conclusions on work practices with the properties of the substance(s). From this information it
should be apparent in most cases whether the potential consequences of exposure are serious or not.
Risk phrases such as may cause death or may cause cancer are clear indicators of hazards that must
be taken seriously. Conversely phrases such as prolonged contact may cause minor skin irritation will
generate little concern if the exposure is of limited duration. As a general principle if a substance is
capable of causing adverse health effects at the expected exposure levels and a realistic route of entry
can be identified then the risks to health will be significant.
54 An example may help to clarify these concepts. Consider two applications of the solvent 1,1,1
Trichloroethane. Because of its affect on the earth s ozone layer, we are no longer able to use 1,1,1
Trichloroethane, but we have continued to use the example here because it relates to situations with
which many will be familiar.
54.1
This substance was used as a solvent in Typists correction fluid and the symptoms of
exposure were potentially significant [Harmful by inhalation or if swallowed. Avoid contact with skin
and eyes]. However, the volume used to correct a typing error coupled with the limited exposure
time indicated no significant risks to health by inhalation. The suppliers data sheet would also
show that ingestion can cause serious problems but realistically we can discount this route of entry,
as no normal person would drink the fluid and the prospect of accidental ingestion was remote.
On the other hand...
54.2
The use of 1,1,1 Trichloroethane as an industrial degreasing agent presented the same
potential problems as the correction fluid [Harmful by inhalation or if swallowed. Avoid contact with
skin and eyes]. However, if the solvent was applied with a rag to a large aircraft component it gave
an entirely different conclusion regarding the risks to health. Clearly, inhalation of significant
amounts could have become a real possibility because the volume of solvent was so much greater,
the surface area over which it was applied was much larger and the exposure time would have
been longer. Skin contact was also likely to present a significant risk to health, while if eating,
drinking or smoking occurred in the workplace then the risk of accidental ingestion also became a
major consideration.
In this case the risks to health are very serious
55 In both examples on the potential risks to health, no mention has been made of control measures.
Control measures must be considered separately otherwise serious potential health risks will be masked
by preventative methods and the dangers posed by a plant breakdown or failure of controls may not be
appreciated.
56 When answering "Would the process present significant risks to health if no controls were in
place?" several factors must be taken into account:
56.1
What is the potential of a substance to cause harm? This can be judged from the
symptoms of over exposure and whether the substance has any classification which makes it
particularly noteworthy. E.g. is it a carcinogen, does it have a maximum exposure limit etc.
Leaflet 5 Annex F
Page 8
April
2003
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