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Dealing with hazardous chemicals and materials

These regulations relate to those who work with hazardous materials in large quantities and in dangerous environments.

You can find all 40 regulations that relate to dealing with hazardous chemicals and materials here [opens in new window].

You can find all the regulations that relate to Dealing with hazardous chemicals and materials below to the left.

Tell us what you think should happen to these regulations and why, being specific where possible:

• Should we scrap them altogether?
• Could their purpose be achieved in a non-regulatory way (eg through a voluntary code?) How?
• Could they be reformed, simplified or merged? How?
• Can we reduce their bureaucracy through better implementation? How?
• Can we make their enforcement less burdensome? How?
• Should they be left as they are?

75 comments on “Dealing with hazardous chemicals and materials”

1. Steve Hawkins on September 7, 2011 at 3:58 pm said:

   The Company I work for tests fuel valves for Gas Turbines, this invloves using a liquid with a flash point of 140F at high pressure. If the valve or rig leaks then the fuel escapes as a mist. The problem we have as a company is how do we interpret the DSEAR 2002 ( Dangerous Substances and Explosive Atmosphere) in the workplace and what the fire and explosion risks are. There are probably many ways to find out if this mist is dangerous, one is to try it and risk an explosion or the other is to hire a consultant. The problem with hiring a consultant is that you rarely get pragmatic advice, it is not in the consultants interest to be pragmatic as he can earn more money and take on less risk if his advice is on the safe side. The cost of installing ATEX electrics , additional ventilation and sniffers will make me uncompetitive with US competition. The solution is to force regulators to give examples of adequate compliance with a number of worked examples, in this case we could have probably adapted a petrol station risk assessment. This requirement would ease interpretation and reduce ambiguity as theRegulators worked through their own regulationComment Tags: Moog Controls DSEAR

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2. PETER FINCHAM on August 3, 2011 at 11:16 am said:

   IMPROVEMENT IN SUPPORT AND IMPROVED AWARENESS OF EU REACH POLICY
   WHICH I SEE IS NOT LISTED WITHIN REGULATIONS ON THE LEFT HAND SIDEComment Tags: EU REACH REGULATIONS

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3. Andrew Smith on July 22, 2011 at 6:15 pm said:

   I discovered, this week, that British Standards for work place first aid kits were revised as of June this year and will become mandatory from 1/1/2012. This will mean all first aid kits will have to be replaced or suplemented in only a 6 month window. I got this from a first aid supplier when I ordered new kits for a new site. They were not happy as al their current stocks are not complient, and their catalogues out of date at a stroke. The Idea is a good one, including burns dressings etc. but 6 months!!! 18 m onths to 2 years would be more appropriate.Comment Tags: First Aid Kits

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   • Ron Hunter on July 23, 2011 at 12:06 am said:

     Andrew, leaving aside the fact your off-topic, please bear in mind that British Standards are not law. Avoid being conned by salesmen!
4. Fred Forshaw on July 22, 2011 at 9:43 am said:

   I m a black powder shooter of 45 years and obviously have always had a Police Explosives Licence. Recently I have had to apply to the HSE for a “Recipient Competent Authority Transfer Document ” as well as an Explosives Licence. This extra EU document consists of nothing more than a matrix of meaningless numbers. I am a Registered Firearms Dealer – I have no idea what this “Transfer Document” is, or what it means – neither do countless other dealers and black powder shooters that I have spoken to. The Recipient Competent Authority Transfer Document raises meaningless EU documentation to a truly stellar level. It achieves nothing, means nothing to those to whom it is issued, and is a good example of the UK gold-plating EU directives. This insane doument should not be applied to private indivduals’ use of black powder.Comment Tags: Authority, Competent, Document, Recipient, Transfer

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5. Rubinah Chowdhary on July 20, 2011 at 6:29 pm said:

   BIOCIDAL PRODUCTS DIRECTIVE/REGULATION [BPD/R]

   Posing as regulation to safeguard the environment and consumer health, and to create a single EU market, the European Biocidal Products Directive/Regulation (BPD/R) has the support of politicians and environmentalists who like its ‘green’ label, but have not troubled themselves to look into exactly how these objectives might be achieved. Those not on the regulatory gravy train, who have delved a little further conclude that it is vastly disproportionate to hazards posed and too complex to be rationally implemented. The BPD/R has been referred to as an ‘unmitigated disaster’ at stakeholders meetings. The World Trade Organisation sees it as a trade barrier based on unsound science.

   Multinationals (MNCs) were effectively given a free hand in Brussels to shape the BPR/R and tailor it to their own requirements – full control of the future European Biocides market. By volunteering to foot the bill for regulation, MNCs effectively become paymasters for the regulatory apparatus, controlling the content and direction of the BPD, as well as future market participants, leaving little room for challenge from concerned parties.

   The BPD(R) requires registration of all biocidal actives at a cost of Eur 5-6 million per chemical raw material. Complexity adds yet another hurdle, with thousands of pages of regulatory and technical guidance notes to be read for any comprehension of compliance requirements. The requirement is to submit dossiers (enough paperwork to fill a small room) with the obligatory cheque to dedicated authorities in Europe, who may or may not find it pertinent to respond to queries from unheard of small UK companies.

   Hundreds of small UK businesses without resources to attend key meetings in Europe, or hire consultants, lawyers and large regulatory teams required now find themselves floundering in uncertainty in the wake of this unhealthy collusion. UK small businesses painstakingly built up over several generations will find themselves facing enforcement action for simply continuing to operate in their own backyard. The outcome is that SMEs are forced out of active manufacturing by insurmountable regulatory hurdles and into downstream (blending) activities, and downstream industry left entirely reliant on being able to secure Letters of Access from Active manufacturers to register and market their goods in the EU.

   Other than MNC domination of the EU market for hygiene product, and regulatory dissent and chaos in Europe, what can the BPD/R be expected to achieve wrt public health and the environment? Numerous low cost biocides with longstanding safety and efficacy profiles will be removed from the market, to be replaced by high cost products with sufficient profitability to commercially justify the high registration costs. At a time where microbial resistance and emerging diseases are of increasing concern globally, limiting access to affordable biocidal products does not bode well for consumer health or choice.

   On the environmental front, as the UK continues to lose its manufacturing industries to lesser regulated countries, the impact on the global environment and worker exploitation and health doesn’t bear thinking about. The unnecessary import/export movement of chemical goods due to over-regulation carries a considerable environmental footprint if fuel and potential marine pollution impacts are taken into account.

   The BPD/R cannot thus be justified on either environmental or consumer protection grounds, and sets a dangerous regulatory precedent in creating a homogenous MNC dominated market, where perfectly functional compliant small companies can suddenly be deemed non-compliant. Hypothetically speaking, by blocking the rights of a small business owner to make a living, the BPD/R contravenes the spirit of Article 23 (1) of the UN Declaration on Human Rights. By disallowing SME access to the European market in a manner proportional to their market share, the BPD/R contravenes a number of EU Competition directives and harms competitiveness and diversity in the EU market. It makes a mockery of requirements the European Small Business Act website to: Design rules according to the ‘Think Small First principle’, ‘Help SMEs to get most out of the EU’s Single Market’, ‘Create an entrepreneurial environment’, ‘Adapt public policy tools to SME needs’, etc.
   In answer to the question of whether the BPD/R should be scrapped, the answer is yes. BPD/R will effectively bring about what amounts to industrial eugenics; destruction of marketplace diversity and operational rights of small businesses to the benefit of a few. The acid test for an acceptable form of the BPD/R is where there is no market disruption i.e. where SMEs remain in upstream areas, and are allowed to share the regulatory burden in a manner proportional to their market share.Comment Tags: Biocidal Products, over regulation, small business, SME

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   • Martin Watt on March 20, 2012 at 2:31 pm said:

     I agree with most of what is said here. I have been involved with the essential oils trade for nearly 30 years. The biocides regulations were one more factor that pushed the larger producers to upsticks and leave for India China and the USA. We lost thousands of jobs as a result and vast amounts of expertise.

     The cretins in the advisory committees in the EU just will not listen to arguments against what they want to do. Please take a look at this web site to see exact details of the damage these and related regs do.
     [Text Deleted]
     Secondly, many smaller companies simply ignore this crazyiness from the EU and rarely are prosecutions mounted. Therefore millions are wasted on instituting such regulations.
     martin
6. Paul Blacklock on July 20, 2011 at 3:39 pm said:

   PERIODIC INSPECTION OF TRANSPORTABLE REFILLABLE LPG CYLINDERS

   Objective

   We seek on behalf of ourselves, and indeed the whole of the UK LPG industry derogation from the future application of one aspect of The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR), which are implemented in the UK by the Carriage of Dangerous Goods by Road Regulations which sit under the Health & Safety at Work etc. Act 1974, requiring us to subject our transportable refillable welded steel LPG cylinders to hydraulic pressure testing at 15 years after purchase (the requalification period).

   Background

   The UK is essentially a discrete market. LPG cylinders in the UK are manufactured for national carriage only. Neither Calor Gas nor our UK competitors distribute our cylinders outside of Great Britain. European LPG distributors historically do not distribute to the UK. A derogation from the European Regulations in this aspect would not raise any issues of competition or restraint of trade.

   Until 1999, LPG cylinders in the UK were manufactured to required British Standards, and tested in accordance with BS EN1440. The tests in BS EN1440 require external visual examination, and, additionally, at least one of the following:
   o Internal visual examination
   o Hydraulic pressure testing
   o Pneumatic pressure testing

   To comply, Calor Gas undertakes external and internal visual examination for all cylinder sizes. Additionally, larger cylinders (i.e. 18kg – 47kg) are hydraulically tested at the re-qualification interval (15 years). Smaller cylinders (i.e. <18kg) are immersed in a water bath each time they are filled.

   From 1999, LPG cylinders were required to be manufactured to BS EN1442. Calor Gas has been purchasing cylinders manufactured to BS EN1442 since 2003, and it is estimated that we have approximately 3 million cylinders in circulation.

   The European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR) require that all transportable refillable welded steel LPG cylinders should be subject to hydraulic pressure testing at the requalification interval (15 years) in place of the internal visual examination..

   So, Calor Gas’s LPG cylinders manufactured to BS EN1442 will require hydraulic pressure testing starting from 2018. This will require significant investment in new testing equipment and significantly reduce the process efficiency of the activity owing to the substantial additional time mandated under the Regulations to undertake the additional hydraulic testing. The estimated additional cost for Calor Gas will be £2 million over just the first ten years and this will provide no additional safety benefits (calculations available). For the UK LPG industry as a whole the total extra burden of these Regulations is likely to be around £4 million over the same period.

   Independent Validation of Current UK Practice

   Calor Gas commissioned ABB Engineering Services (ABB ES) to carry out a comprehensive and independent review of the legislation and the current operational practices to determine whether the additional cylinder testing requirements would provide any additional level of safety not provided by the existing regime. ABB ES is an international technical consultancy with over 500 engineers and specialists. ABB ES has thousands of years of combined operating and functional knowledge particularly in pressure systems and extensive expertise in legislation and codes, contributes to many international standards and produces guidance for national regulators.

   Their conclusion was:

   “ABB ES believe that there is no need to perform periodic hydraulic pressure tests on LPG cylinders as any manufacturing or fabrication defects would have been detected during the initial manufacturing inspections (QA/QC) hydraulic pressure test and no new defects can form that would not be detected during the other routine inspections required by the legislation and performed to a high standard by Calor GB and Ireland.”

   Their report (copy available) outlined a number of reasons supporting their conclusion. The core of their rationale was their finding that extending the requirement to test cylinders hydraulically did not result in a higher level of safety:

   “In the UK and Ireland, over 10 million cylinders have been subject, over the last 20 years, to periodic inspection as detailed in EN1440 without the use of hydraulic tests. During this time the entire population has been inspected without any safety issues attributable to the method of inspection. Over the last five years, for which statistics are available, in Calor GB filling plants…the failure rate of cylinders inspected (according to EN1440) using the external and internal visual examination and pneumatic leak test was 7.19%, compared to the failure rate of the cylinders inspected (to the regime required by ADR) using the external and internal visual examination and hydraulic test, which was 5.08%. It should also be noted that under the ADR regime the failure rate due to the hydraulic test alone was 0.0054% – i.e. practically all the cylinders which failed the periodic inspection failed due to the detailed external and internal visual examination – if they had passed the detailed external and internal visual examination, they passed the hydraulic test too. The small number of failures during the hydraulic test was primarily due to external cylinder base corrosion. Since the introduction of improved external inspection methods in 2006 there have been no failures at hydraulic test.”

   What would Calor Gas like to see happen?

   Calor Gas would like to be allowed to continue with their present practices, proven safe, based on the existing requirements in the current version of European Standard EN1440, of undertaking internal and external inspections of their smaller LPG cylinders, accompanied by post fill leak checks without the expensive and unnecessary hydraulic test at recertification. We believe we may be able to advance a case for a derogation for larger cylinders, too, but the evidence is not yet to hand.

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   • Andrew Smith on July 22, 2011 at 6:04 pm said:

     I agree with your thoughts, though I would have to add why do I have to have my CO2 fire extinguishers hydralically tested every 5 years in additiona to annual inspection? How many Calor Gas Cylinders fail in service each year? How many dangerous occurancies can be attirbuted to cylinder failiure? I think this is yet another example of good intentions running away with themselves, Safe does not exist, everything has risk, it’s about managing risk. We would all be very safe in padded cells!
7. Mike Edwards on July 20, 2011 at 9:35 am said:

   The Reach regulations.
   I represent a small powder coating company that continually receives requests from customers to confirm if any of the products used on their work contains the items listed.
   We as users do not know we pass the letters onto suppliers who fail to respond for whatever reasons we do not have the ability to tell these suppliers that if we do not get theinformation we will stop purchasing from them.
   The customers still place orders with us because our quality & prices are good.
   Which questions the problem regarding required information.

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8. Stephanie Trotter, OBE on July 18, 2011 at 5:57 pm said:

   I am commenting on behalf of CO-Gas Safety, the carbon monoxide and gas safety society. This is an independent registered charity which tries to stop people dying or being injured by unintentional carbon monoxide poisoning.
   We don’t want anything reduced but a tidying up might be a good idea.
   Gas Safety (Installation and Use) Regulations 1998 Gas Appliances – safety precautions
   (9) Where a person carrying out work in relation to a gas appliance he shall immediately thereafter examine-
   (a) the effectiveness of any flue;
   (b) the supply of combustion air;
   (c) its operating pressure or heat input or, where necessary, both;
   (d) its operation as to ensure its safe functioning.
   And forthwith take all reasonable practicable steps to notify any defect to the responsible person and, where different the owner of the premises in which the appliance is situated or, where neither is reasonably practicable, in the case of an appliance supplied with liquefied petroleum gas, the supplier of gas to the appliance, or in any other case the transporter.
   (10) Paragraph (9) shall not apply in respect of –
   (a) the direct disconnection of the gas supply of a gas appliance; or
   (b) the purging of gas or air from an appliance or its associated pipework or fittings in any case where purging does not adversely affect the safety of that appliance, pipe or fitting.
   We do not think para (10) is necessary and should be removed.
   Surely re (b), you cannot know whether or not the safety of that appliance pipe or fitting has been adversely affected, without testing with a flue gas analyser?

   [text deleted]

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9. Stephanie Trotter, OBE on July 18, 2011 at 5:40 pm said:

   I am commenting on behalf of CO-Gas Safety, the carbon monoxide and gas safety society. This is an independent registered charity which tries to stop people dying or being injured by carbon monoxide poisoning.
   We don’t want anything reduced but a tidying up might be a good idea.
   Landlord’s Gas Safety Check
   For example, the law on landlords’ gas safety checks is very confusing to landlords. In the Gas Safety (Installation and Use) Regulations 1998, there is a duty at Reg. 36(2) to ensure that the gas fitting and flue is maintained in a safe condition, so as to prevent the risk of injury to any person in lawful occupation.
   There is also a duty under Reg. 36 (3), without prejudice to (2), to have each appliance and flue checked for safety.
   It is not uncommon for landlords to be confused into thinking that a safety check is a service or at least a check with an analyser of the flue gasses.
   This is not only confusing to the landlord but extremely dangerous to anyone exposed to flue gasses, particularly if a registered gas installer has not been required to either service or use a flue gas analyser to analyse the flue gasses for some years. We know of at least one death [text deleted] which we think was caused by this confusion. We suggest that the following is added to the existing legislation with regard to a landlords’ safety check.
   ‘The person undertaking the check must either undertake a service according to manufacturer’s instructions or, following procedures outlined in BS7967 part 4, use Flue Gas Analysers meeting EN50379 to measure the combustion gasses for PPM (Parts Per Million) of CO and also the CO/CO2 ratio and make and keep a record of those measurements.’
   We have the support of Pimlico Plumbers for this change. Please note that British Gas does not undertake landlords’ gas safety check without first obtaining a contract to service.
   We are waiting to hear from Phil Bentley, MD of British Gas to see if he will support our proposed change and in effect, to preach what his firm practices. Meanwhile, we consider we should send you this in case we don’t receive it in time. [text deleted]

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10. Wayne Smith on July 15, 2011 at 2:09 pm said:

    REACH
    We have a major issue with the complexity of providing information down the supply chain are causing major problems. Our members have started to receive extended safety data sheets (ESDS) of over 100 pages. These comprise the new REACH Annex II style SDS along with attached exposure scenarios (ES) for the variety of end-uses for which the substance has been registered.

    The major problems for downstream users/formulators (DU) such as the paint and ink manufacturers who comprise our membership are summarised below:

    1. Size of ESDSs
    ESDSs received to date range from 58 to 118 pages. Given that a typical paint or ink will contain 20-50 substances, a number of these substances will be supplied with ESs for each end-use. REACH requires that these ESs be passed along the supply chain. If DUs follow the exact requirements of REACH, they will simply forward the ESs relevant to the end-uses to which they are supplying the product. This is likely to result in a customer receiving a document of between 100-500 pages!

    Many coatings end-users are SMEs (e.g. vehicle refinish shops) or one-person operations (e.g. painters/decorators). They will not have the expertise or time to decipher these to extract the important information, and so will be more at risk than before – surely not an intention of REACH.

    2. Complexity of ESDSs
    In the ESDSs seen so far, there seems to be no standardised format. Some are in the 4-section style and some in the 9-section style given in earlier draft guidance from ECHA and some with sections 2.1 and 2.2 reversed. In addition, some of these have the ES for each use as a separate chapter, whilst others have all uses together, but are split into the ES information section e.g. under “Control of Worker Exposure”, they have Use 1, Use 2 etc. This makes it virtually impossible for the DU to analyse the information in order to ensure that there is no conflict between the ESs for the substances and the SDS for the mixture.

    3. Extracting the information to make a product ESDS
    To avoid the problems in 1 above, of having to pass on a large quantity of irrelevant information, it could be possible to produce an ES for the product, based on the most important, risk-determining substances in the product. This approach is acknowledged in draft ECHA guidance. This suffers from the same problem of complexity, as highlighted in 2 above, making it impossible to find the relevant information from the ESs received.

    4. Language
    Once the above problems are sorted out (if possible), any products sold in different Member States will have to have the ESDS translated into the different languages of the countries involved. This is an incredibly expensive process. Due to the individual nature of the ESDS-producing process, each ESDS will have to be translated separately, making it a completely unfeasible proposition.

    The answer to the above problems, as we see it, is for industry to standardise the format of ESDSs and ESs. It would be preferable for this to be done in a way to allow electronic data exchange up and down the supply chain. This could produce a system that might work. We are aware of two current projects that should help:

    - ECHA guidance on the format of ESDSs and ESs
    - The ESCom XML project for electronic data interchange

    In order for our industry to be able to meet the requiremenmts of REACH, we need more time to allow these projects to be completed. We need to have either the timescales for the delivery of ESDSs delayed for say 12 months, or some assurance from enforcers that they will not take action until the relevant projects are complete and can be put into practice.

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11. Colin Bayley-Williams on July 15, 2011 at 12:02 pm said:

    EHS law is essential to protect everyday workers and employers. The fundamentals behind HASAWA have not changed in decades. The resulting EU legislation and National regulations have led to an ever increasing battle to understand the thinking behind the beauracracy of the methods needed to comply. I’m sure that the people who write these have not worked in industry. Small manufacturing firms (5 or more people) are now inundated with Risk assessments and litigation worries. Even EHS professionals such as myself find it hard to keep abreast of all the legislation relating to everyday business. From COSHH, PUWER, WEEE, ROHS, CDM, LOLER, Battery waste directives, etc. To fully understand and try to comply with all these regulations becomes a burden to industry. For example, the latest WEEE regs requires producers to invent the perpetual product, re-use, repair, recycle, and replace. To which nothing new will be invented or developed in fear of not being seen to be environmentally compliant.

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12. Ron Hunter on July 14, 2011 at 2:28 pm said:

    This consultation page is erroneously headed “These regulations relate to those who work with hazardous materials in large quantities and in dangerous environments”.
    Difficult to invite sensible and proportionate debate when the purpose of a fair amount of the Regulations listed is incorrectly defined.
    Perhaps someone in authority could divulge exactly how the UK intend to respond to the EU challenge to our current Control of Asbestos Regulations (CAR 2006), which have failed to implement the requirements of the parent Directive? HSE are (perhaps understandably) somewhat tight-lipped on the matter?

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13. Mark Emmerson on July 13, 2011 at 1:26 pm said:

    No changes required.

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14. John Angle on July 12, 2011 at 11:24 am said:

    No change necessary

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    • Alan barlow on July 13, 2011 at 10:43 am said:

      Whilst I realise that DEFRA have the lead on the REACH regulations it is worthy of note that included in these regulations is asbestos (which I believe is currently under the authority of the HSE). The regulations in their current form do not allow for municipal and national museums and galleries throughout Europe to display items containing asbestos, nor indeed does it allow for the movement of such articles.

      In fact it means that any museum or gallery that has an article on display that contains asbestos is in breach of the requirements.
15. Clive Davey on July 12, 2011 at 9:34 am said:

    This legislation is good it has taken many years for work places to become safer yet some employer still do not have the basic points in place such as risk assessment and workers are still being injured because of slack employers we need to keep this in place and tighten up on bad practice. government get a life and tackle bad employers.

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16. Bob Chapman on July 11, 2011 at 11:43 am said:

    In the list of regulations there is no mention of the REACH regulation. This is described By the European Chemical agency as the biggest change to chemical regulation in the EU since the EU was formed. I think this illustrates the problems that people dealing with regulations have. It is as if the HSE do not know what regulations do apply to the chemical industry. In defence of teh HSE I would like to point out that the HSE produced some good guidance to the older CHIP regulations on the classification of chemicals. However the new guidance produced by ECHA on the new REACH and CLP (Labelling) regulation is very poor to both read and understand. Therefore my suggestion is that before any change is introduced and especially enforced it should be subject to a statutory lead in period where its operation is monitored but not enforced. In particular there should be involvement of the small industrial sector in the monitoring of its ease of use. If the regulation is so complicated that it needs over a 1000 pages as a regulation then I suggest that it is too complicated to be understood by any one person. Always remember the old saying KISS, keep it simple stupid. The big regulations are invariably brought into operation with the involvement of the big organisations/companies. This is because the small companies do not have the number of people working for them to be able to take the time to be involved in teh formulation of the regulation until it has been passed.

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    • Red Tape Challenger on July 11, 2011 at 2:27 pm said:

      Bob Thank you for your helpful comments about REACH. These regulations have not been included as part of the health and safety at work Red Tape Challenge as they are the responsibility of the Department for Environment Food and Rural Affairs (Defra). Whilst HSE is the UK Competent Authority for REACH, Defra have the policy lead. Your comments will be passed on to Defra, who’s regulations will be in the Red Tape Challenge spotlight later in the year
17. Carole Saunders on July 11, 2011 at 10:04 am said:

    No change required

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18. JOHN G PICKETT C.Eng C.Env on July 9, 2011 at 10:41 pm said:

    The Dual and Conflicting Regulation of AWE plc by MOD and HSE by the fact that AWE has to comply with both MOD-JSP482 and MSER 2005 has proved exceedingly and un-necessarily expensive.
    For military explosives manufacturing and storage, JSP482 is a perfect model for safety and practicality. The wording of MSER ( intended primarily for the fireworks industry) had to be bent so much out of shape that HSE had to employ specialists in Military explosives before overworked and beleaguered HID inspector could talk the same language. It is ridiculous that AWE plc. is not treated like every other MoD site (GOCO or not) and subject only to JSP482.

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