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COSHH and the Vehicle Dismantler

Have you complied with the requirements of COSHH by formally risk assessing the use of substances – holding the supplier’s material safety data sheet is not enough on its own!
In this article, Safety and Health practitioner, Phil Wass takes a close look at issues surrounding vehicle dismantling and the Control of Substances Hazardous to Health Regulations, (COSHH) . Phil is an advisor to MVDA members and a regular contributor to their quarterly magazine.

In your yards, potentially dangerous substances will be taking many forms – such as the chemical blend used in your parts washers (probably a mix of kerosene and hydrocarbon), used engine oils, substances used in tyre fitting (such as vulcanising cements, buffing solvents and bead sealers), oxygen and propane (used in your cutting activities), you may also use metal markers (to I D your parts) and tyre stamp ink and you will also be encountering air conditioning system gases (such as R134A – tetrafluoroethane), etc.

Now the tricky thing about exposure to workplace chemicals and substances is that, although some will present an immediate reaction in those exposed, many will not seem to be creating any problems at all (i.e. they are long term ‘sensitisers’, etc.). Therefore you will be lulled into a false sense of security and so will your workforce – for most of us generally truly believe that we are invincible and that problems occur in others and will never affect us – do you not agree?

Phil Wass
Phil Wass is a Chartered Safety and Health practitioner and has a Masters Degree in Occupational Health and Safety. He is Managing Director of Wass Management Limited who specialise in all aspects of health and safety training, advice and guidance. Phil is an advisor to the Motor Vehcile Dismantlers' Association and understands the needs of the industry. He regularly carries out work for MVDA members.

If you have any health and safety issues, visit Wass Management Limited, email Phil or you can contact him on 01773 541441
Someone exposed to a dangerous substance over a long period of time will have never had an ‘accident’ at work – but they may suffer debilitating ill health in later years (or even die prematurely in some severe circumstances) as a direct result of exposure to something they encountered whilst at work. In fact, sadly, industry in general has already had far too many bad experiences along these lines in the past - where many workers have been unacceptably affected by such exposure before appropriate action to withdraw (or better control) such substances was taken (e.g. asbestos, creosote, ‘trike’ – used in de-greasing, etc.).

So let us now focus on the process entailed should you wish to be fully compliant with the requirements of ‘The Control of Substances Hazardous to Health Regulations’ (COSHH) – first put in place in the mid 1980’s with the objective of better protecting workers exposed to dangerous substances in the workplace.

All substances coming into a workplace (via your official suppliers) will carry a consistent ‘black and orange’ labelling system required by something called the ‘CHIP’ Regulations. These regulations also place a requirement on your suppliers to make available to you something called the ‘Material Safety Data Sheet’.

By the way, at this stage it is worth me acknowledging that I do appreciate that you will obviously find it difficult to obtain similar such information for substances that you did not source directly yourself – such as used engine oil.

Now back to the material safety data sheet, I still commonly find that many companies believe that this document is a ‘COSHH assessment’ - but it is not - this is just the starting point (i.e. the source document) to enable you to originate the COSHH assessment. I also commonly come across substance data sheets which are ‘years old’ and therefore ‘years out of date’. If, under section 8 of the data sheets that you are holding, there is reference to OES’s (Occupational Exposure Standards) and MEL’s (Maximum Exposure Limits) then your sheets are also out of date and you need to request new updated versions which quote WEL’s (Workplace Exposure Limits) within this section (i.e. section 8) instead.

Once armed with the up to date substance data sheet/s, the COSHH assessment process can then commence and requires you to consider (and document if you employ 5 or more people) the following:
  • What is the specific activity within which you use this substance?
  • How is the substance used (e.g. ‘neat’, diluted, etc.)?
  • How much of the substance is used at a time and at what intervals?
  • What is the potentially vulnerable exposure route (into the body) of your workforce when using this substance?
  • Never place your head or body close to the front of an un-deployed airbag when removing it from the vehicle?
  • In what ‘physical form’ are you using the substance (i.e. liquid, powder, etc.)?
  • What are the specific hazards to human health identified (both short term and long term) should this substance not be used carefully?

Once this information is established, you are then required to decide on appropriate control measures to prevent or control exposure. This may involve a decision to source an alternative (less hazardous) substance if the one in use (or about to be used) is unacceptably dangerous. It may involve using the substance in an alternative form (e.g. in pellets rather than as a powder). It may involve careful consideration of any available ‘engineered’ solutions for safe use should this be appropriate (such as enclosure of the process, providing mechanical ventilation, etc.). Finally (and only as a last resort) appropriate personal protective equipment should also be specified for use and its use then effectively controlled. If the substance does have significant potential for long term ill health effects then a health surveillance programme may also be required. Finally, if the substance has potential environmental impacts (i.e. should it be accidentally released) then some appropriate emergency arrangements may also need to be put in place as well (i.e. such as the availability of drain covers, absorption granules, etc.).

As I said earlier, many of your workforce will believe that they are ‘invincible’ and that they will never be affected by such issues, however it is a fact that in many cases they just take longer to become ‘sensitised’ than others.

As an employer you of course also have a duty to identify, inform and train your workforce in all such workplace substance hazards and their effects – whether they should have immediate or long term potential for harm.

The most embarrassing past example of unacceptably controlled hazardous substance exposure from the ones which I have already previously quoted in this particular article - has to be asbestos. Unlike exposure to a dangerous piece of equipment, the effects are not seen ‘there and then’ and only appear many years later - but as this example clearly indicates they can still have real potential to wreck lives when the symptoms of exposure do finally occur. Also, very sadly indeed for those affected by this particular example, by the time serious symptoms do occur it is very often too late to do anything at all about it.

So, do please give some thought to the substances that you currently use. What is their potential to cause harm to your workforce? Are you controlling them effectively? Have you complied with the requirements of COSHH by formally risk assessing the use of the substance – remember that holding the supplier’s material safety data sheet is not enough on its own!

If you need additional help with issues such as this (or anything else) then you can always get in touch with me directly for further advice and guidance. If this article has been helpful and you would like more of these ‘specific’ vehicle dismantling and depollution safety topics to be covered in this way in the future then please let us know.

I would like to express my appreciation to Ray Kirk of Albert Looms in Derby for his input into certain technical aspects contained within this article.

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