Elements to consider even before the training session
The training
environment
COSHH training in the small engineering workshop may be
carried out in a traditional training room environment. Alternatively, if the numbers are relatively
small, the training may be carried out in the workshop, using the existing
workplace and the equipment therein as props for the training. One of the problems with a workshop
environment is that there tends to be a lot of background noise and so it may
be necessary to: turn off equipment, turn off the air compressor and release
the stored pressure in the air lines, turn off the local exhaust ventilation
system(s), etc. Arrangements should be made for dealing with other distractions, such as deliveries, etc.
Consider the aim of
the training course
When carrying out COSHH training for the smaller engineering
workshop, the aim of the training is unlikely to be training in the COSHH
regulation themselves, but is much more likely to be focussed on making workers
aware of the health risks associated with the substances that they may be
exposed to and on the control measures to be used to prevent (or control) that
exposure.
Consideration of the range of substances present
Before embarking on a COSHH risk assessment or on COSHH
related training, it is important to determine what substances hazardous to
health are present in the workshop. Typical
substances hazardous to health that may be found in an engineering workshop
include:
•
Oils and greases
•
Spray lubricants (such as WD40)• Metal working fluids
• Solvents (cleaning materials, thinners, etc.)
• Paints (containing solvents, pigments, lead, etc.)
• Isocyanates (in 2-pack polyurethane paints, etc.)
• Epoxy materials (adhesives)
• Welding and cutting fume (arc, gas and plasma)
• Soldering fumes
• Vapour phase degreasing materials
• Kerosene based degreasing materials
• Dusts (such as from processes like grinding, linishing and polishing)
A list (or inventory) should be made of all of the
substances used, stored or generated in the workshop.
Information
Manufacturers’ (or suppliers’)
safety data sheets are particularly useful for determining if a substance is
hazardous to health. In fact, Regulation 12 of the COSHH Regulations states
that relevant safety data sheets are amongst the pieces of information that
must be made available to employees who are exposed to substances hazardous to
health. In order to carry out a suitable
training session, the trainer must understand the hazards associated with the
substances and this information may be found on the safety data sheet will
provide this information.
The HSE produces a wide range of
informational literature that may be of direct benefit to small engineering
companies and their COSHH issues. These
include a range of free leaflets (such as the INDG series) and priced
publications (such as the HSG series).
Much of this information may also be downloaded (free of charge) from
the internet.
It is recommended that useful
information is made available to workers.
This may be contained in the COSHH risk assessment file or, more
usefully, made available at the point of use (such as in local files on the
shop floor or on notice boards). Workers
should be encouraged to access this information.
The application of the basic principles of COSHH to
the management of health risks from exposure to hazardous substances
The Control of Substances Hazardous to Health Regulations
2002, as amended (COSHH) require that the health risks arising from exposure to substances
hazardous to health are avoided where this is reasonably practicable or that
they are controlled where it is not reasonably practicable to avoid them. In order to comply with the principles of
COSHH, the employer should:
•
Assess the risks to health and decide what
precautions are needed.
•
Inform workers of the risks associated with
exposure to substances hazardous to health and of the control measures to be
used to ensure their health and safety.
•
Prevent workers being exposed to substances
hazardous to health or, where this is not reasonably practicable, ensure that
such exposure is controlled adequately.
•
Ensure that exposure control measures are
followed at all times, and regularly checked and maintained, and that safety
procedures are observed.
•
Monitor workers exposure to substances hazardous
to health and carry out appropriate health surveillance, where the COSHH
assessment has shown this is necessary.
•
Train workers in the use of control measures and
the use of any personal protective equipment that may be required.
•
Provide suitable welfare facilities, such as
washing and areas to consume food away from the work place.
COSHH issues associated with exposure to metal working
fluids
Introduction
The main health effects arising from exposure to metal
working fluids (MWF) are to the skin
and to the respiratory system. These
include: irritation of the skin, dermatitis oil acne and folliculitis; as well
as: occupational asthma,
bronchitis, irritation of the upper respiratory tract, breathing difficulties
or, rarely, a serious lung disease called extrinsic allergic alveolitis. Water based MWF support microbial growth and,
hence, can lead to biological contamination of the MWF, increasing the risks of
ill health arising from exposure. Ill
health effects may also be increased by chemical contamination of the MWF from:
tramp oils, hydraulic fluids, polycyclic aromatic compounds (in neat oils) and
nitrosamines (in water based oils). The (COSHH) risk assessment for the use of
MWF should identify a range of simple control measures that can significantly
reduce the risks of ill health developing.
Health effects of exposure to metal working
fluids
Respiratory
ill health
Workers
exposed to MWF mist and vapour are at risk of developing work-related asthma,
bronchitis, irritation of the respiratory tract and breathing difficulties, as
well as extrinsic allergic alveolitis (which can cause increasingly severe
breathing difficulties in recurrent episodes, following repeated exposure). Exposure
may also cause irritation to the eyes, nose and throat.
Inhalation
of these biological contaminants (such as bacteria or toxins) can lead to
irritation of the respiratory tract and flu-like symptoms, as well as
aggravating existing asthma.
Skin
problems
Dermatitis
can be caused:
•
by bacteria (or their toxic by-products) when
they are present in the MWF in the sump;
•
through contact with sensitising metal (such as
chromium, nickel and cobalt), which can leach out from cutting tools, grinding
wheels and substrates into MWF; and
•
by contact with chemical additives, such as
biocides and corrosion inhibitors.
The
use of unrefined mineral oils may lead to skin cancer on affected skin, such as
hands and the lower arms. Prolonged
exposure through wearing contaminated clothing and the habit of putting oily
rags into overall pockets increases the risks of skin cancer and of scrotal cancer.
These risks are lessened by the use of
highly refined oils, etc.
Routes for exposure to metal working fluids
MWF fluids are usually applied by continuous jet, by a spray
or by a hand dispenser. They can only
cause health effects if they come into contact with the body. The common routes for exposure are:
•
Inhalation of the mist generated during the machining
operation.
•
Direct contact (such as from splashes) with
unprotected skin, particularly hands, forearms and heads.
•
Entry into the body through direct contact with cuts,
abrasions or other broken skin.
•
Ingestion (arising from eating, drinking or smoking
in work areas, or from poor personal hygiene).
Control measures for working with metal
working fluids
In general, the introduction and maintenance of simple
control measures will significantly reduce the risks of ill health developing
from exposure to MWF.
General control measures
•
Ensure that the most appropriate MWF has been
selected.
•
Devise a safe system of work for working with
metalworking fluids and instruct workers in this safe system of work.
•
Ensure that suitable splash guards are provided,
fitted and used appropriately.
•
Minimise the production of MWF mist and vapour,
such as by controlling the volume and rate of delivery of the MWF to the tool.
•
Avoid the use of compressed air to remove excess
metalworking fluids from machined parts, plant or equipment.
Extraction and ventilation
•
Provide suitable extraction systems (such as
local exhaust ventilation), where the need is identified in the (COSHH) risk
assessment.
•
Ensure that any enclosures or extraction systems
provided to remove or control mist or vapour are used properly.
•
Ensure that there is a time delay before opening
the doors on (CNC) machine enclosures to ensure that all mist and vapour have
been removed by the ventilation.
•
Introduce regular monitoring (checks) of the
equipment and arrange for any damaged or defective splash guards, extraction
systems, etc. to be repaired.
•
Ensure that the extraction system is checked and
serviced regularly and that it is subject to statutory examination (by a
competent person) at least once in every fourteen month period.
•
Ensure that there is adequate general
ventilation in the work area - open workroom doors and windows to improve
natural ventilation, where appropriate.
•
Introduce suitable measures to reduce the
potential for contact with MWF .
•
Reduce contact with wet work pieces and
surfaces.
•
Instruct workers not to put bare hands into
fluid sumps and not to use oily rags to wipe them clean.
•
Provide suitable personal protective equipment
and ensure that it is worn as appropriate.
Suitable PPE may consist of gloves (or gauntlets), overalls, aprons,
goggles or face shields.
•
Instruct workers in the risks of contamination
of the inside of gloves (with MWF) when putting them on or taking them off.
Sump fluid control
•
Ensure that waste materials (especially unwanted
food, drink, cigarette stubs) are not disposed of into the sump.
•
Instruct workers to info rm
a supervisor if they observe any layers of scum or large amounts of tramp oil
on top of the sump fluid, or if the sump fluid becomes dirty or smelly.
•
Introduce and follow good working practices when
mixing fluids, cleaning and topping up sumps etc.
•
Monitor the levels of bacterial contamination
using dip slides, or other means of measuring the level of bacterial activity.
•
Consider a contract management service for the
MWF (offered by some suppliers).
Personal Hygiene
•
Provide suitable hand washing facilities,
including running hot and cold water, soap and towels.
•
Provide, and encourage the use of, suitable pre-work
barrier creams and after-work conditioning creams. This barrier cream should be designed to
provide a protective layer between the skin and the MWF, while the after-work
conditioning cream is intended to replace the natural skin oils removed by washing
and by contact with the MWF.
•
Ensure that any cuts and abrasions are covered
with a suitable waterproof dressing.
•
Instruct workers in the need for high standards
of personal hygiene.
•
Instruct workers to wash regularly with soap and
water to remove MWF from skin. Instruct workers to avoid using abrasive or
solvent cleaners.
•
Instruct workers to wash their hands thoroughly
before eating, drinking or smoking.
•
Store personal protective equipment in the
changing facilities provided or another clean storage area.
•
Ensure that a sufficient number of suitable
overalls are provided and that they are changed regularly.
•
Instruct workers not to put oily rags into their
pockets.
•
Provide a laundry service for dirty overalls and
instruct workers not to take hem home for washing.
•
Prohibit eating, drinking and smoking in areas
where metalworking fluids are used.
•
Appoint a responsible person to carry out health
surveillance, as identified by the risk assessment.
•
Carry out asthma health checks.
•
Refer anyone affected by exposure to MWF to an
occupational health professional.
•
In the event of any ill health being identified,
ensure that prompt action is taken to identify the likely cause and ensure it
is prevented or adequately controlled.
•
Keep workers info rmed
of the collective findings of health surveillance.
COSHH issues associated with exposure to oils and
greases
Introduction
It is an inevitable consequence of many aspects of
production and maintenance work that workers will come into contact with greases,
oils and general lubricants. Prolonged
contact with these oils and greases can cause a range of skin problems, such
as: rashes (e.g. oil acne), dermatitis and even skin cancer and testicular
cancer. Contact with hot lubricants,
during servicing or maintenance, may also cause burns.
Routes for exposure
to oils and greases
Oils and greases may be used widely in the workshop. They may be associated with the lubrication
of the moving parts of machinery in the workshop, they may be associated with work
being undertaken or may be contamination on surfaces (such as work benches,
inspection pits, work pieces, etc.). The
common routes for exposure are:
•
Inhalation of the mist generated during the
machining operation or from the use of spray lubricants (such as WD40).
•
Direct contact with unprotected skin,
particularly the hands or indirect (but often prolonged contact) from oil
contaminated clothing, such as overalls.
This may occur when fill or draining a lubrication system or reservoir.
•
Entry into the body through direct contact with
cuts, abrasions or other broken skin.
•
Ingestion (arising from eating, drinking or
smoking in work areas, or from poor personal hygiene).
Hazards associated
with oils and greases
Skin rashes and dermatitis
‘Oil acne’ may be identified by the presence of blackheads,
pimples and pustules on the skin. The
arms are the area most commonly affected (as these are the area most likely to
come into contact with oils and greases), but any other part of the body may be
effected if it comes into contact with oils or oil soaked clothing. Oils may also remove the skin’s own naturally
protective oils, leaving it dry. This
dry skin is liable to crack and is more susceptible to damage caused by cuts
and abrasions.
Skin and testicular cancer
It has been established that
contact with certain mineral oils may cause cancer in humans. The carcinogenic
potential of oil products is usually, but not always, associated with the
presence of polycyclic aromatic hydrocarbons.
Used oils (especially used engine oil) have been shown to have elevated
polycyclic aromatic hydrocarbons levels.
Prolonged exposure to certain mineral oils, and especially to used
engine oil, can lead to the development of warty swellings or sores on the
skin, especially where contact is on the scrotum. These warty swellings are slow to heal and
may be cancerous. It is recognised that
prolonged skin contact with used engine oil can lead to skin cancer and
testicular cancer (from putting oily rags into overall pockets). Consequently, used engine oil is listed as a
carcinogenic substance in Schedule 1 of the Control of Substances Hazardous to
Health Regulations 2002 (COSHH).
Other hazards
Hazards associated with slipping due to oil on the floor or
with burns from hot oils are not considered in this article.
Control measures for
working with oils and greases
The best control measures are those that avoid contact with
oils (such as fully enclosed pumping systems in place of pouring systems for
draining and filling operations), while others limit the amount of contact
(such as hand washing after exposure).
Overalls
Workers potentially exposed to oils should be provided with
a sufficient number of protective overalls.
It is usual for them to have at least three sets of overalls (one set to
wear, one set being cleaned and at least one spare set), although some tasks
may require more sets of overalls.
Suitable arrangements need to be made for the overalls to be cleaned. It is recommended that overalls are dry
cleaned in order to remove oils and greases.
Ideally, overalls should be supplied without (trouser)
pockets, so that oily rags cannot be stuffed into the pockets - reducing the
potential for prolonged skin (scrotal) contact.
Lack of pockets also reduces the risk of other injuries from the tools,
etc. that may also otherwise be put into them.
Aprons
The use of (disposable) plastic aprons should be considered
for certain operations where there is a risk of oil contamination of the
overalls.
Gloves
Appropriate gloves should be worn as a barrier to protect
the hands from contact with oils and greases.
In many cases, disposable gloves are used, while in others, more robust
longer use nitrile gloves are provided.
The type of gloves provided will be dictated by the level of protection
required and the type of work being undertaken.
The thin, disposable gloves reduce skin contact with oil while allowing
fine work to continue.
Suitable washing facilities
Decent washing facilities are necessary to remove oil from
the skin. These should include both hot
and cold running water as well as suitable skin cleansers. Suitable hand drying facilities should also
be provided, such as paper towels. The
use of suitable conditioning creams after washing can help to counter the
degreasing effects of the oil on the skin.
Skin must never be cleaned with solvents, etc. So called “barrier creams” must not be relied on to protect the skin from
exposure to oils. They can, however, be
a useful extra protection and can make it easier to wash oils off of the skin
after exposure.
Use of tissue rolls in place of rags
It is recommended that, where appropriate, the use of rags
for cleaning up is replaced by the use of suitable tissue wipes (usually
supplied in a roll form). Dispensers for
these rolls may be wall mounted at suitable locations in the workshop. This means that clean tissue is readily
available for addressing small spills, cleaning tools, etc. and also that there
is no temptation to keep rags (potentially oil contaminated) in overall
pockets.
Draining and filling of lubrication systems, including
those associated with vehicles
The drainage of used oil from lubrication systems offers
significant risk of contact with the used oil.
These contact risks exist during the draining process, but also in
subsequent handling of the drained oil, such as during transfer to a waste
disposal holding vessel such as an oil drum or tank. The risks may be reduced substantially by the
use of a suitable oil collection vessel that later allows the waste oil to be
pumped from the collection vessel to the waste oil storage vessel. The collection vessel should be fitted with a
wide funnel (for catching the oil) which should in turn be fitted with mesh to
catch sump keys, bolts, oil filters, etc.
Storage and disposal of (waste) oil
Oil, including waste oil, should be stored in suitable,
robust vessels inside a bunded storage area (with a bund capacity of at least
110% of the size of the largest storage vessel) pending collection for disposal
by a licensed collector of such special waste.
Health surveillance
As it is recognised that prolonged skin contact with mineral
oils can lead to occupational dermatitis and, in some cases skin cancer, the
employer should carry out routine skin inspections as a precautionary
measure. Employees should be encouraged
to report sore, red or itching skin, whilst the responsible person should carry out regular, documented and
recorded skin inspections of hands and forearms at monthly intervals. Cases of suspected dermatitis should be
referred to a doctor or occupational hygiene nurse for further
investigation. The results of health
surveillance must be recorded and records must be retained for 40 years.
Information, instruction and training
Employees who are potentially exposed to oils and greases
must be made aware of the hazards associated with these materials and of the
control measures to be used to protect their health. Awareness can also be raised with suitable
notices and leaflets that are available from the HSE.
Care with air-lines
Where compressed air is used to provide breathing air to
air-fed masks, etc., care must be taken to ensure that the workers are not
exposed to oil mists from the compressed air.
Suitable filters should be fitted and maintained and the quality of the
air should be checked regularly.
Summary
Consideration needs to be given to the aims of the training
course. In many cases, the training
needs to be focus on the nature of the hazard to which people will (or may) be
exposed and on the measures that need to be used to avoid or control that
hazard. In the case of COSHH and its
relevance to a small engineering workshop, it may be prudent to focus the
training on examples that affect the workshop rather than on the intricacies
and technicalities of the COSHH Regulations.
This may be achieved by training using examples that are directly
relevant to the workshop.
