Schedule 2A of the COSHH Approved Code of Practice (L5) contains relevant information on the current best practice for control of exposure to hazardous substances.
When handling any hazardous material, it is important to consider factors other than exposure to the materials as part of a general risk assessment. For example, consideration should be given to safely setting up apparatus and storage and labelling of chemicals. These should be assessed as required by
SHE Code 6 - Risk Management.
Carcinogens
Prevention of exposure to carcinogenic substances must be the first objective in view of the serious and often irreversible nature of the disease. Appendix 1 of the COSHH ACoP gives guidance on the control of carcinogenic and mutagenic substances. In addition Schedule 1 of the ACoP lists additional substances which should be treated as if they are carcinogenic.
Poisons
Special care and training will be required when dangerous poisons are to be used. Dangerous poisons are defined as those substances contained in the Poisons List Order and Schedule I of the Packaging and Labelling of Dangerous Substances Regulations (there is a specific legal requirement to keep such poisons locked up), and also those substances prohibited or controlled by the Carcinogenic Substances Regulations.
Licensed Chemicals
STFC would require a license to purchase and hold certain chemicals. Staff must contact their site SHE Group prior to purchase of any chemicals which fall in the following three categories.
- Duty Free Alcohol - DL and RAL have licenses to purchase limited quantities of industrial denatured alcohol (IDA) and absolute ethanol free of excise duty for research purposes.
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Drugs (PDF - 112kB - link opens in a new window) or
Drug precursors (PDF - 24kB - link opens in a new window) - STFC is required to obtain a licence before it can purchase or hold any controlled drug or purchase or hold category 1 drug precursors and is required to register its holdings of category 2 substances.
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Chemical weapons and their precursors (PDF - 66kB - link opens in a new window) - STFC sites may purchase and hold up to 5g of any Chemical Weapons Convention (CWC) schedule 1 substance for research purposes but must register and keep records of quantities and location. Any requirement over 5g would necessitate an individual site license.
STFC must keep records of the purchase of CWC schedule 2 and 3 substances but is unlikely to fall under the reporting requirements.
Where any of these substances are brought onto STFC sites by facility users it is usual for the visiting institution to obtain an extension to their own license to cover the additional work on the STFC site.
REACH
REACH (Registration, Evaluation, Authorisation and restriction of Chemicals) is a piece of European legislation which mainly affects producers and importers of large quantities of chemicals. However there are also important issues for ‘end users’.
Safety Data Sheets
New revisions of safety data sheets should contain additional information relating to the specified use for which the chemical was purchased:
Section 1 – this should now contain a subsection which identifies the use for which the substance was purchased ‘Recommended Use’ and any ‘Uses advised against’.
Section 16 – this should now contain information on recommended control measures related to the ‘Recommended Use’ in section 1.
Authorisation
As part of the registration process under REACH, substances may be categorised as ‘Substances of Very High Concern’ (SVHC) where they have intrinsic properties set out in REACH’s Article 57. Authorisation to use an SHVC is required from the
European Chemicals Agency (link opens in a new window) (ECHA) unless used in quantities of less than 1 tonne per annum and it is used for pure research and development. The R&D exemption is strict, in that the substance must be central to the project. For instance, the use of trichloroethylene in a degreasing plant to clean items used in a research project would not qualify the use of trike for exemption.
There are currently 22 substances on the SVHC ‘authorisation (link opens in a new window)’ list and 151 on a ‘candidate (link opens in a new window)’ list of substances which could be added to the authorisation list. Both lists are updated twice a year. Substances on the ‘authorisation’ list have a ‘sunset date’ beyond which it would be illegal to use the substance unless an exemption exists or an authorisation has been granted.
Substances harmful to the Environment
Although not requiring a license, staff purchasing substances on
UK Environmental Red List (PDF - 17kB - link opens in a new window) should have stringent control measures in place for their use to prevent escape into the wider environment. They should never be disposed of down a foul drain.
Disposal Arrangements
