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Dr. H.J. Hardwick. Dr. J.D. Green.
JDC/JJ/99 5th February, 19-95
The Control of Substances Hazardous to Health
14 th - 15th January, 1985;
Meeting held in London
Delgates from B.A.T.:
Dr. S.R. Evelyn.
Dr. J.D. Green.
This note describes briefly the possible future
requirements
that will be placed upon employers as a result of
the proposed regulations
relating to the control of hazardous substances in
the workplace. Certain
:6 pects of particular reference to the tobacco
Industry are highlighted
nd therefore It may be appropriate for these
notes, albeit in a slightly
modified form, to have a wider circulation within
BAT, UK&E.
The new regulations, which are detailed In the
consultative
document entitled "Control of Substances Haxardous
to Health", will, when
approved, require employers to carry out certain
duties relating to the
exposure of employees to substances that are
regarded as hazardous to
health. The meeting to which this note relates was
held to explain and
discuss the various aspects and Implications of
the proposed legislation.
In determining the substances to which the
regulations apply
the lists contained in a previous H.S.C. document,
Classification,
Packaging and Labelling of Dangerous Substances
Regulations, are of
considerable assistance. If a substance Is
classified an very toxic,
toxic, harmful, corrosive or irritant then it
should be considered under
the COSHH regulations. Furthermore, carcinogens,
dangerous pathogens,
and dusts should be also considered. Complications
can occur with
manufactured formulation& (eg adhesives, paints)
however, assistance here
can be obtained fror. data sheets or further
disclosures.
Having determined that a substance to which the
ODSHV regulations
apply is being, or will be used, then there In a
requirement to assess
exposure of employees. Reference here must be made
to concentrations
prevailing and the exposure time. These
considerations allow an est1mote
of risk to be made. 'The related Code of Practice
(draft) specifies that
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BATCO doCUrnent for Province of BritiSh Colurnbia
5 Novernber 1999


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NPO:ure Is not to exceed the control limit or the
recommended limit
:
her available (HSE, Guidance Notes EH.40).
Discussion at the meeting
however suggested that pressure from the workplace
(employees and employers)
would require a considerable margin for error to
be included.
Control of exposure is an important duty of the
employer under
these proposed regulations. Control may be brought
about by elimination
or substitution of the substance, ventilation
including fume cupboards
and hoods, containment in enclosure (eg for
laboratory-type operations a
glove box) or finally personal protection.
Personal protection Is regarded
as a final line of defence and not to be regarded
as satisfactory until
all the other control measures have been examined
for suitability.
In order that those employees concerned are able
to use the
required control measures, information must be
supplied to them and suitable
instruction given in the use, and necessity of
usingv the equipoent
provided to effect the control.
'Where employees are exposed to substances
hazardous to health
then health surveillance is a requirement.
Approved procedures are
detailed in the Code of Practice (draft) relating
to the COSFH proposals.
Eealth surveillance records must be kept and
monitored for the
employees concerned.
Proposed Regulations and B.A.T.
Two examples of where we may be expected to act
upon the COSHR
regulations are given below:
Nicotine
Reference to the "Classification, Packaging and
Labelling of
Dangerous Substances Regulations" shows that
nicotine is classified &a a
.,toxic" material. As such, it comes within the
orbit of the COSHH
regulations. The recommended limit in Guidance
Note EH.40 is 0.5mg.s-3
and a note relating to the danger of skin
absorption is made. Consequently,
it may be required of us to have the exposure of
employees to nicotine
assessed and controlled. This may involve air
sampling and analysis and
surface contamination monitoring. Chemical
knowledge of nicotine in
tobacco would suggest that the greatest
concentrations would he present
in areas where steam was used as a processing aid.
If concentrations of
nicotine approached, or exceeded the recommended
limits, then after
consideration of exposure time of employees then
control measures any be
required. Depending also on the estimated
exposures health surveillance
and record keeping may be necessary. These
measures would apply principally
to factory-related situations but also be
necessary for specific laboratory
areas where nicotine was the major concern.
CC)
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QJ_11
BATCo document for Province of British Columbia 5
November 1999


j~m CMUO
R=2&
and Devejapffli
WPI
Carcinogens
Th:r:u:r:cf:w Indu atrial laboratories that do not
deal with
some known0 p t d carcinogenic comp ounds. Perhaps
the prime example
in B.A.T. at GR&DC Is the extraction and analysis
of nitrosamines. In
the laboratory concerned control measures have
been introduced to reduce
the exposure to the nitrosamines being examined.
The assessment of
exposure was not based upon measured values but on
consideration of
working procedures. No regular monitoring is
carried out to determine
the nitrosamine levels in the area. Health
surveillance is carried out
as recommended by a medically qualified
practitioner in the form of a
liver-function test. Records are kept in relation
to these tests.
In this case therefore, we are complying with some
of the
requirements and with the spirit of the COSRH
regulations.
Further Cases
Tobacco dust may also require attention under the
COSHH
regulations and it is likely that further cases
will come to light
for attention in the future. It is important that
careful consideration
be given to any new substances being introduced
into the working
environment.
J.D. GREEN
cc. :;r. C. I. Ayres.
Dr. R.A. Crellin.
Dr. S.R. Evelyn.
Mr.T.C. Mitchell.
CX:)
BATCo document for Province of British Columbia 5
November 1999