Assessing and managing risks at work_froj

kn OXpOSULO

HSE Health & Safety

Executive

chemica agents)

(GuidanceD for employers and health and safety specialists

(to

Assessing and managing risks at work frD

aExpu to chemical agents

Guidance

HSE BOOKS

for employers and health and safety specialists

© Crown copyright 2001

Application for reproduction should be made in writing to:

Copyright Unit, Her Majesty's Stationeiy Office, St Clements House, 2-16 Colegate, Noiwich NR3 I BQ

First published 2001

ISBN 07176 18269

All rights reserved. No part of this publication may be

reproduced, stored in a retrieval system, or transmitted in any form or by any means (electronic, mechanical, photocopying, recording or otherwise) without the prior written permission of the copyright owner.

This guidance is issued by the Health and Safety Executive.

Following the guidance is not compulsory and you are free to take other action. But if you do follow the guidance you will

normally be doing enough to comply with the law. Health and

safety inspectors seek to secure compliance with the law and

may refer to this guidance as illustrating good practice.

II

Contents 1... Introduction

2... The law

2... Skin and chemical agents

4... Health effects 4... Effects at the site of exposure 6... Effects elsewhere in the body

7... Prevention or cure?

8... Recognising a hazard

11... Assessing health risks 11... Exposure pathways 12... Measuring skin exposure

14... Managing risks 14... Preventing or controlling exposure 15... Elimination and substitution 16... Engineering controls 17... Process modification 18... Working methods 19... Personal Protective Equipment (PPE) 21... Skin care products

22... Health surveillance

24... Information, instruction and training

24... Conclusions

25... Appendix 1 Relevant legislation

27... References and further reading

ill

ntroducfion This guidance provides practical advice to employers and the self-

employed on how to control skin exposure to chemical agents in the

workplace, to protect the health of employees and others who may be exposed. Managers, supervisors, employees, health and safety

professionals, safety representatives and trade union representatives

will also find this guidance useful. If your work activity involves skin

exposure to chemical agents, then you should read this guidance. It gives: • an explanation of how temporary or permanent health effects can

be caused by skin exposure to chemical agents; • examples of chemical agents which are known to cause either

temporary or permanent health effects after skin exposure; • practical advice on how to assess and manage risk of skin

exposure to chemical agents.

•

•1

The aw 2 The law requires that employers make a suitable and sufficient

assessment of the health risks from skin exposure to chemical

agents at work. This is covered by the Health and Safety at Work etc Act 1974 (the HSW Act)1 and the Control of Substances Hazardous to Health Regulations 1999 (COSHH).2 Having completed the

assessment, there is a further duty to take the steps needed to

prevent or adequately control exposure to the hazard, and to use and maintain the relevant controls.

3 Many employers are unaware they have legal duties under COSHH to make sure that employees' exposure to chemical agents by absorption through the skin or contact with the surface of the skin is

either prevented or, where this is not reasonably practicable, adequately controlled. This guidance has been prepared to help employers comply with their legal duties.

4 See Appendix 1 for other legislation (in addition to the HSW Act and

COSHH) relevant to the control of health risks from skin exposure to chemical agents at work.

Skn and chemca agents 5 Skin acts as a barrier to limit the loss of water and other essential

compounds out of the body and the permeation of substances into the body. It is made up of many thin layers of cells and is rich in

proteins and fats. The thickness of the skin varies across the body and is thickest on the palms of the hands and soles of the feet. The skin needs water to function properly. Low humidity can adversely affect the skin by causing it to dry out and crack. Damage to the skin from cracks, cuts, burns or abrasions or from diseases such as eczema and psoriasis impairs the skin's barrier properties and allows substances to penetrate more easily.

6 The term chemical agent covers a wide variety of substances used at work in the form of liquids, solids, gases, vapours, aerosols, fumes, dusts and fibres. It is used to distinguish these substances

from biological agents (such as micro organisms) and physical

agents (such as noise, vibration and friction). ____________

7 Many chemical agents have the potential to cause serious health

effects after skin exposure (often referred to as dermal exposure). Yet, skin exposure to chemical agents happens every day for many workers. If a chemical agent comes into contact with the skin, it may cause health effects, either by provoking a reaction at the site of

exposure or by entering the bloodstream, which could cause or contribute to a toxic effect somewhere else in the body.

3

HeaLth effects Effects at the site of exposure

8 Chemical agents capable of provoking a reaction at the site of

exposure can be divided into three groups: • substances which cause irritation at the site of exposure and may cause irritant contact dermatitis if the skin is exposed to them for

enough time and in sufficient concentration; • substances which sensitise the skin to cause allergic contact

dermatitis; • substances which cause other skin diseases, eg contact urticaria, loss of normal skin pigmentation, skin cancer etc.

Irritant contact dermatitis 9 Substances which cause irritant contact dermatitis include acids,

alkalis, soaps, detergents and some, but not all, solvents. Irritation at the site of exposure can vary from inflammation (redness and

swelling) of the skin which can develop after regular contact with

mild irritants such as weak acids (pH between 4 and 7) or alkalis (pH between 7 and 9), to more severe tissue damage, eg a chemical

burn from brief skin exposure to a corrosive substance. Defatting of the skin (ie the removal of natural oils) can also occur if the skin is

exposed to substances such as detergents and (some) solvents.

This damages the barrier function of the skin by breaking up the

structure of the surface layers of the skin, leaving dry, cracked and

scaly skin.

10 Localised inflammation is a normal response by the skin to skin

damage. Usually, inflammation subsides once the damage to the skin has healed. However if the irritation is particularly severe or a

chemical burn has occurred and destruction of skin tissue has taken

place, the skin will scar instead of healing. If the skin is repeatedly exposed to irritants, a condition known as hyper-irritability may

develop. This means that the skin will become inflamed more readily when it is exposed to irritant substances than would happen to someone with normal skin.

Allergic contact dermatitis 11 Allergic contact dermatitis (or skin sensitisation) is an immunological

response to a chemical agent. The effects are difficult to distinguish from irritant contact dermatitis. However, once sensitisation has been

induced, allergic contact dermatitis may be triggered by very small

amounts of the substance. Sensitisation builds up with time and it

may be weeks or even months before the condition is apparent. By this time the employee will have become sensitised and there is no

remedy other than to prevent further exposure. This means that, once sensitised, a person can never be exposed to the chemical

agent again without suffering an allergic reaction.

Other occupational skin diseases

12 There are also other occupational skin diseases, eg contact urticaria, loss of normal skin pigmentation, skin cancer etc, which can be

caused by skin exposure to chemical agents. Together they constitute

a substantial minority of the total number of cases of occupational skin

disease and are dealt with in more detail in Health suiveillance of occupational skin disease.3

Incidence of work-related dermatitis

1 3 There is no obvious visual distinction between irritant and allergic contact dermatitis; they can look the same in spite of the differences

in underlying mechanism. Early symptoms are redness and irritation,

which can progress to swelling, scaling, blistering cracking and

bleeding. Once the surface of the skin is broken, infection can

develop, making the condition worse. The skin may also develop a

hardness as a natural defence to frequent exposure to certain

chemical agents. The hands are most often affected, but if the agents

are in the form of aerosols, dusts, or fumes, the face and neck can

also be affected. Skin exposure via contact with contaminated

clothing or hand transfer of chemical agents can result in other parts of the body being affected, eg the chest, arms, legs and face.

14 HSE estimated that in 1995 about 66 000 people in Great Britain

were suffering from a skin disease caused by their work. About 95%

of these cases were from exposure of the skin to chemical agents.

6

This caused around half a million lost working days. HSE has estimated that the cost to employers of skin disease caused by work was between £24 million and £59 million in Great Britain in 1995/96. The EPIDERM/OPRA skin surveillance scheme4 funded by HSE,

reports the percentage breakdown of cases of work-related skin disease caused by exposure to chemical agents as: • 15.8% of cases caused by chemicals and materials used in the manufacture of rubber products; • 14.3% of cases caused by soaps and cleaners; • 9.9% of cases caused by wet working; and, • 8.7% of cases caused by an allergic reaction to component materials

in personal protective equipment (PPE) worn at work. For example, many workers have been found to suffer a contact allergic reaction to the proteins contained in gloves made from natural rubber.

15 Industries and occupational groups which have been identified by HSE as being at high risk of work-related skin disease are: • Catering and • Hairdressing • Construction

food processing S Cleaning • Rubber • Engineering • Printing S Offshore • Agriculture • Health care

EXAMPLES OF EXPOSURE

Hairdressers are at high risk of developing either irritant or

allergic contact dermatitis from frequent multiple exposures over long periods to hairdressing products such as shampoos, dyes, bleaches, soaps and detergents.

Construction workers are at high risk of developing allergic contact dermatitis from exposures to wet cement.

Engineering workers are at high risk of developing irritant contact dermatitis from frequent exposures to metalworking fluids.

Effects elsewhere in the body 16 Many substances don't have an effect at the site of exposure but

may be absorbed through the skin and enter the bloodstream. Once

in the bloodstream, they are carried around the body and may then

cause or contribute to a toxic effect elsewhere in the body. This is referred to as systemic toxicity.

1 7 Substances which pass readily through the skin include many low

molecular weight substances and many organic solvents. For any chemical absorbed into the body, the resultant health effects will be

different for different substances and although some effects may become apparent within a few hours or days of exposure, other

effects can take months or years to appear.

EXAMPLES OF SYSTEMIC EFFECT

14 bO CA, also known as methylene bis (ortho-chloroaniline), is

used in the manufacture of polyurethane articles. The prime health concern with MbOCA is bladder cancer. MbOCA readily crosses the skin and this will lead to an increased risk of bladder cancer

Dermal exposure to organophosphate pesticides during sheep

dipping has produced damage to the nervous system in

workers failing to wear appropriate personal protective equipment (PPE).

Preventon or cure? 18 It is always better to prevent a disease rather than to have to cure it.

Employers can and should recognise the presence of health and

safety hazards in their workplace, evaluate the risk of harm occurring and develop measures to adequately control the risk. This will

prevent health effects, including those caused by exposure of the

skin to chemical agents.

1 9 Occupational hygienists and other health and safety professionals can play an important role in the recognition of workplace hazards.

They can evaluate the risks posed to employees' health when

working with chemical agents and can advise on the most

practicable means of either preventing or controlling such risks.

N

Recoqnsng a hazard (COSHH reguaton 6) 20 The first step in carrying out an assessment of risk of skin exposure

is to identify chemical agents either used or generated in the

workplace. The second step is to decide which have the potential to cause health effects following skin exposure.

21 Although many chemical agents are assigned limits for exposure

through inhalation (as published in the HSE publication EH4O,

Occupational exposure limits)5 there are no such limits for skin

exposure. You should therefore make a judgement about the

potential for chemical agents to cause health effects based on

information from various sources.

22 Many chemical agents are known to cause health effects following skin exposure. Some common examples of occupational contact

irritants and sensitisers are listed in Health surveillance of occupational skin disease.3 Chemical agents which are known to be capable of being absorbed through the skin and which may contribute to systemic toxicity are assigned a 'skin notation' (symbol Sk) in EH4O.5 The criteria for assigning a skin notation are that

exposure to the substance via the skin may: • make a substantial contribution to body burden (when compared to the contribution attributable to inhalation exposure at the

occupational exposure limit); and

• cause systemic effects so that conclusions about exposure and

health effects based solely on airborne concentration limits may be invalid.

23 Paragraph 39 of the General COSHH A COP,2 on the need to consider

exposure by routes other than inhalation states that skin exposure:

'should be controlled to a standard such that nearly all the

population could be exposed repeatedly without any adverse

health effect

As there are no published exposure standards available for skin

exposure, the most practicable means of ensuring adequate control is to prevent or minimise skin exposure to chemical agents.

24 Where dermal absorption of a chemical may add significantly to the

total dose received by a worker during their normal working day,

consider biological monitoring as a means of assessing the

effectiveness of control. Biological monitoring is discussed in more

detail in paragraphs 38-39.

25 The CHIP Regulations6 require chemical suppliers to identify the

hazards (or dangers) of the chemicals they supply. This is called

classification. They must give this information to the people they supply the chemicals to. The following risk phrases in the Approved guide to the classification and labelling of substances and

preparations dangerous for supply,7 are applied to classify chemicals which cause effects following skin exposure: • R34, causes burns; • R35, causes severe burns; • R38, irritating to the skin;

N

• R43, may cause sensitisation by skin contact; • R66, repeated exposure may cause skin dryness or cracking.

These risk phrases apply to chemicals having an effect away from the site of exposure: • R21, harmful in contact with the skin; • R24, toxic in contact with the skin; • R27, very toxic in contact with the skin; • R48/21, harmful, danger of serious damage to health by

prolonged dermal exposure; • R48/24, toxic, danger of serious damage to health by prolonged dermal exposure; • R39/27, danger of very serious irreversible effects in contact with the skin.

26 HSE publications can be a good source of information, eg Health surveillance of occupational skin disease.3 This advises health

professionals on suitable and necessary health surveillance for workers at risk from skin exposure to irritants, sensitisers and other

non-infective skin damaging agents. Trade associations and trade

journals can be another good source of information, as experience within the industry may suggest a health risk from a particular substance or process.

Assessng heafth hsks (COSHH reguaUon 6) 27 The COSHH assessment should firstly identify wherever chemical

agents which have the potential to cause health effects are used at work. The next step is to assess the potential for skin exposure to those chemical agents and therefore the risk Consider patterns of use of the chemical agent and worker activities. The aim is to identify how, how often, and for how long people are exposed and which

parts of the body are exposed

23 For some jobs it may be quite straightforward to assess the

potential for skin exposure and visual observations may be enough to confirm this In other cases skin exposure will be less predictable or less obvious and exposure measurements may be required to

identify sources and exposure pathways.

Exposure pathways 29 The link between a hazard source and a worker is called an

'exposure pathway'. Skin exposure normally occurs by one of three

pathways: immersion, deposition or surface contact.

30 Immersion occurs when the skin comes into direct contact with a

liquid or solid. A common example of this pathway is the poor practice of hands being put into a solvent during the manual

cleaning or degreasing of mechanical components

31 Deposition occurs when droplets dusts fumes or aerosols impact or

settle onto the skin Aerosols may be generated as part of a work

activity (eg spray painting) or they may be incidental to it (eg emissions

from a nearby process). Common examples of this pathway include:

splashing during the handling of liquids, dust generation from powder

handling, and exposure to aerosols during paint spraying.

32 Surface contact occurs when the skin touches a contaminated

surface. This can be a major source of skin exposure during

cleaning and maintenance operations, such as exposure to

oils/greases during repair and maintenance of machinery.

/1

33 Transferring contamination by hand to other parts of the body is an

important source of skin exposure. Chemical residues on hands are

frequently transferred to the eyes, nose and mouth and may also

contaminate food and tobacco products. Contaminated clothing can

also be a source of skin exposure, particularly to the hands, when

removing contaminated PPE.

Measuring skin exposure 34 Measuring skin exposure can be useful in judging the effectiveness

of control measures, such as any PPE that may be worn. Routine

exposure measurements can also be useful in identifying any trends in workplace exposure. Methods for assessing skin exposure fall into

five categories: • surrogate skin methods; • removal techniques; • use of fluorescent tracers; • biological monitoring; • modelling.

Surrogate skin methods

35 Surrogate skin methods involve workers wearing chemical collection

pads. After a specific task has been completed, the pad is removed

and analysed for chemical content. Two general approaches have

been used: patch samplers covering small skin surface areas and

garment samplers covering whole anatomical regions, eg gloves, coveralls. The validity of these methods rests on the ability of the

sampling medium to capture and retain chemicals in a manner

similar to skin. Although none of the garment samplers in common

use has been systematically tested for retention efficiency, surrogate skin sampling has proved to be useful as a simple and cost-effective

method for measuring skin exposure.

Removal techniques 36 Removal techniques include skin washing and wiping. These

measure only what can be removed from the skin at the time of

sampling, rather than the actual skin loading. Water-alcohol wash

solutions are generally used to assess hand exposure, while

/2

wiping techniques can be applied to work surfaces. Sampling of work surfaces can be useful as it provides an estimate of dermal

exposure potential and can be an effective way of showing that a

cleaning or segregation policy is working. Handwash sampling

procedures can normally be standardised to ensure that they are

operator-independent. Skin-wiping procedures are inherently

operator-dependent however, so they are much more variable.

Use of fluorescent tracers

37 Skin exposure can also be quantified directly and non-invasively by measuring deposition of fluorescent materials which are then viewed

under ultra-violet light. Imaging using fluorescent dyes has been

used to quantify skin exposure and has proved very useful for worker education. This technique has a major limitation, as the use

of a fluorescent tracer usually requires introducing a foreign substance into the production system, although some contaminants

are naturally fluorescent.

Biological monitoring 33 Biological monitoring can be used to indicate how much of a

chemical has entered the body. It is especially useful when:

• there is the likelihood of significant absorption through the skin; • control of exposure relies (wholly or partly) on PPE;

• there is a reasonably well-defined relationship between biological

monitoring and systemic effect; or

• systemic toxicity is related to long-term tissue accumulation of a

chemical and not airborne measurements taken at a particular time

(eg PCB5).

39 It involves measuring the chemical agent (or break-down products) in

a sample of breath, urine or blood and comparing that measurement

against a reference value called a biological monitoring guidance value (BMGV). HSE uses two types of BMGV — one is health-based

and is called a Health Guidance Value (HGV) and the other is a

hygiene-based value called a Benchmark Guidance Value (BMV) and

is set at a level which can be achieved at workplaces employing

good occupational hygiene practices. BMGV5 established for

particular chemical agents are listed in Table 3 of EH4O.5

'3

Modelling 40 Measured data are preferable to data derived from modelling.

However very few data on skin exposure are available. The EASE

(Estimation and Assessment of Substance Exposure) model is in

widespread use throughout the European Union for the occupational

___________ exposure assessment of new and existing substances. It is used to estimate inhalation exposure to airborne contaminants, or exposure of the skin. Exposure ranges are estimates based on data from

several sources, principally the United States Environmental

Protection Agency (EPA), HSE and published literature. Skin

exposure assessment does not include any form of uptake such as absorption through the skin

Manaqing hsks (COSHH reguaUon 7)

Preventing or controlling exposure 41 Once a skin contamination problem has been identified prevention

or control of exposure will be necessary. The first consideration

should be to prevent exposure either through • elimination of chemical agents with the potential to cause either

temporary or permanent health effects following skin exposure; or, • substitution of the chemical agent with a less hazardous substance.

42 If this is not reasonably practicable, adequate control will need to be

achieved. In practice, skin exposure often occurs via a combination

of exposure pathways. But, it should be possible to prevent or

control exposure by applying good occupational hygiene practice,

through one or more of the following options (in order of priority): • enclosing or mod)5jing the process to isolate the hazard source; • installing local exhaust ventilation close to the hazard source, to remove the chemical agent from the workplace; • mod jfijing working methods if appropriate, eg to exclude or

restrict workers' access to areas where there is a risk of exposure; • providing workers with PPE to protect them from the hazard.

43 Skin care products can also play a role in an overall skin care

programme, and are discussed in more detail in paragraphs 57-59.

Elimination and substitution 44 Eliminating the use of a hazardous substance is most feasible at the

process design stage. In the case of existing systems, elimination of a

hazardous substance usually means a change of process. For

example, mechanical methods (eg brushes, scrapers, grinders) can be used instead of solvents for paint stripping and surface cleaning. This

may, however, introduce other risks such as noise, dust or ergonomic problems, and exposure to these risks must be controlled too.

1iMINATION

A gardener at a large estate developed skin irritation on

his lower legs during the winter months only. This was

diagnosed as arising from exposure to an irritant chemical

released by a species of caterpillar which nested in the

gardens. The problem with the gardener's skin stopped once

the caterpillar nests had been eliminated using a single

application of an appropriate pesticide.

45 It elimination is not possible, the next preferred option is to substitute

or replace the substance with something less harmful. For example, chemicals used in cleaning are often too aggressive and can be

replaced by less hazardous or less concentrated products. Solvent-

based materials can often be replaced by water-based products and

surfactant degreasers can be replaced by milder non-ionic products.

SUBSTITUTION

Employees at a metalworking company started to suffer from skin rashes, thought to be caused by exposure to metal-

working fluids. The company took specialist advice, installed an automatic fluid mixer and substituted a higher quality metalworking fluid.

The problem of skin rashes disappeared. Improved manage- ment of the metalworking fluid resulted in significant savings

through lower consumption of metalworking fluid and less

machine downtime, while the metalworking fluid was changed.

46 A change in physical form may also reduce the potential for skin

exposure. Contact with powders can be reduced by using granulated or liquid formulations, eg substituting powdered formulations with less dusty pellets. This will reduce the amount of material released into the air and therefore reduce contamination of

surrounding surtaces. In some cases, it may be possible to use pre-

packaged forms of the chemical to eliminate handling operations such as scooping or weighing.

Engineering controls 47 If prevention of exposure is not possible, the next option is to

consider containment of the source, using closed handling systems or partial enclosure with some form of local exhaust ventilation

(LEV). Closed handling systems (eg the use of fully enclosed

automated chemical additive systems) can be very effective in

controlling skin exposure. Such systems essentially remove the risk, as there is no potential for skin exposure to the chemicals during normal operation, provided the plant is properly maintained.

However, there will be a potential for skin exposure during maintenance and repair operations and, therefore, separate and

clearly defined control measures will be needed for these

operations. Much can also be achieved by the use of simple

engineering controls, such as partial enclosure and LEV.

_____________________ -

PARTIAL ENCLOSURE WITH LOCAL EXHAUST

VENTILATION (LEV)

A number of workers employed to bag thy cement powder

complained of skin irritation on their hands and faces. The

company knew that skin exposure to wet cement could cause

allergic contact dermatitis, but did not realise that skin

exposure to thy cement powder could lead to a mild irritant

dermatitis. They had not thought that they needed to provide

any means of controlling worker's skin exposure and had only

provided their workers with respirators to protect against inhalation of dusts. The situation was improved by installing a partial enclosure with local exhaust ventilation (LEV) at the

bagging station to control the dust as far as possible and also by providing suitable gloves, overalls and respirators.

Process modification 48 Having contained the hazardous chemical as far as possible, the

next option is to modify the process to minimise manual handling

operations. This can be done by using automated systems. For

example the electronics industry can apply methacrylate based

glues onto circuit boards by remote and fully contained methods

rPROCESS MODIFICATION

The offshore industiy add glutaraldehyde, a recognised skin

sensitiser, as a biocide to well injection sea water This inhibits

the growth of sulphate-reducing bacteria and so prevents

production of hydrogen sulphide which can cause corrosion

damage to metal pipework The glutaraldehyde is added on a

measured 'shot' basis to the injection water, by an automatic

pumping system. This avoids the need for manual decanting and measuring operations which can lead to skin exposure.

Working methods 49 Working methods can be modified to control skin exposure. One

very effective way of achieving control is to prevent or minimise the

need for access to areas where there is a risk of skin exposure.

(ODIFIED WORKING METHODSk

An office worker in an electrical components manufacturing company developed a skin rash, especially on her face. Part

of her job was to issue worksheets directly to employees in

workshops where soldering took place. The office worker's job was changed so she no longer needed to go into the

workshops. Her skin condition immediately improved when

she was removed from exposure to soldering fume.

50 If contamination of surfaces cannot be prevented, it can be reduced

by providing impermeable, easy-to-clean worksurfaces. These should be cleaned on a regular basis. Another way of reducing contamination of worksurfaces is to use disposable absorbent paper

lining which can be replaced on a regular basis.

51 Simple procedural controls, such as barriers between contaminated

and clean work areas, can be very effective in preventing the spread of contamination. Spillage controls, eg using drip trays, will also

prevent the spread of contamination and spillages can then be cleaned up without generating dust or increasing the likelihood of skin exposure.

52 Risks from exposure to many chemical agents can be reduced or controlled by regular washing. A very high standard of personal

hygiene is important and this should be encouraged by providing clean washing facilities as near as possible to the area of work.

Exposed skin areas should be washed thoroughly at breaks and

after work using the least aggressive cleaner possible and avoiding the use of solvents or abrasives. The skin should be rinsed in warm

water and carefully dried using clean towels. Pre-work creams can

be applied before starting work or on returning to work after a break. An after-work moisturising cream can also be useful as this will help

to replace the natural oils the skin can lose when it is washed or

comes into contact with detergents. Pre-work and after-work creams

are discussed in more detail in paragraphs 57-59.

Personal Protective Equipment (PPE) 53 PPE for control of skin exposure should be used only as a last

resort, when other methods of control are not reasonably practicable. In situations where exposure is unavoidable and will cause health

effects, the use of PPE is required but it is important to remember

that PPE has a number of limitations:

• it can only protect the wearer; • it has to be selected carefully; • it has to be put on, worn and taken off properly; • it may limit the wearer's mobility or ability to communicate; • its continued effectiveness will depend on proper cleaning, maintenance, training and adherence to good working practices.

54 PPE is available in a wide range of natural and synthetic materials.

Typical examples of PPE provided to withstand exposure to chemical

agents include gloves, aprons and overalls. When selecting PPE,

take care to ensure that the quality, construction and maintenance

provides the level of protection needed. PPE should be adequate but not over-elaborate for the job, as this can discourage its use.

/9

N

55 If PPE is worn or selected incorrectly, this will increase risk of

exposure as contaminant can become trapped inside ill-fitting PPE,

against unprotected skin. Employers should provide PPE that is 'CE

marked',6 compatible with the wearer, compatible with the work to be done and compatible with any other PPE to be worn (eg ear

defenders, safety goggles or respirator).

56 Employers should also provide employees with information, instruction, training and adequate facilities for issue, use, cleaning, storage and maintenance of PPE. Employees should wear PPE

properly, look after it and report any loss, defects or other problems.

JSING PPE

There are many situations where the use of PPE must form an essential part of the overall control strategy, because

other means of control may be impractical or may not achieve adequate control by themselves.

Examples of such situations are the cleaning and maintenance of process plant and the repair of breakdowns.

Also, routine tasks of short duration such as taking samples

from chemical processes and longer term tasks such as

spraying pesticides rely heavily on PPE as a form of control.

Skin care products 57 A wide variety of skin care products are available for occupational

use and generally fall into one of two categories: pre-work or after- work creams. Pre-work creams (usually referred to as 'barrier'

creams) are designed to provide a protective layer between the skin and the substance. They are generally formulated to repel either oil,

grease, solvents etc (called 'dry uses') or water-based substances, such as weak acids and alkalis. Manufacturers claim that some

creams give protection against both. After-work creams are general

purpose 'moisturisers' designed to replace the natural skin oils

removed by washing and the solvent action of substances on the

skin. Skin care products are defined as cosmetics and as such are

covered by the Cosmetics Products (Safety) Regulations.9 Under

these regulations, manufacturers are required to assess the safety of their products but currently these Regulations have no mandatory

requirement for an efficacy test.

58 Pre-work creams cannot be relied on for primary protection of the

skin as there is no information on the rate of penetration of chemicals through creams. Also, people habitually miss areas of their exposed skin when applying creams and so complete skin

cover cannot be guaranteed. It is not always obvious if the barrier

has been removed, damaged or thinned. Because of this, pre-work creams should not be regarded as PPE. They cannot give the same level of protection as gloves and should not be used as an

alternative to properly selected PPE.

59 Skin care products can however play a role in an overall skin care

programme For example the use of a pre work cream can assist

the removal of dirt when washing thereby making it less likely that

powerful solvent or abrasive cleaners are used. After-work creams

are particularly beneficial, as they assist in restoring the natural

moisture content of the skin's surface layer and should be used

regularly after washing.

USING AFTER-WORK CREAMS

When air-impermeable gloves are worn for extended periods, a hot and humid atmosphere is established inside the glove. This condition will act as a skin irritant and may promote the growth of bacteria. When the hands are removed from gloves they need to be washed and dried thoroughly. An

after-work moisturising cream can then be applied to help restore the skin's natural oils.

Heafth surveillance (COSHH reguation 11) 60 Health surveillance will help to identify the early symptoms of

dermatitis or other health effects caused by skin exposure. The earlier that health effects are recognised and treated, the more

likely it is that the sufferer will make a full recovery.

61 Health surveillance, like biological monitoring, can also show whether an adequate standard of control is being maintained.

It may give an early indication of lapses in control and the need

for a reassessment of the control strategy.

62 Wherever there is a potential for skin exposure to a substance

known to be associated with a risk of health effects, arrangements should already be in place to identify such cases. Workplace health

surveillance can be as simple as administering a brief employee

questionnaire and conducting regular inspection of the potentially

exposed skin areas of workers to find out if they are experiencing

any skin symptoms. If a questionnaire is used, seek advice on its

suitability from an occupational health nurse or doctor. A suitably trained responsible person, however, can administer the

questionnaire and carry out skin inspections. An example of an

appropriate questionnaire may be found in Health surveillance

programmes for employees exposed to metalworking fluids.1°

63 The training of a responsible person should include instruction on the characteristic signs of the particular health effects. Employees should be encouraged to look for these signs by self-inspection and

report them. Confidentiality must be safeguarded if such reporting is

to be effective.

HEALTH SURVEILLANCE

The surface layer of the skin must contain at least 10% of its

weight in water to function properly. Portable monitoring equipment has been developed to measure the electrical

conductivity of the skin, which can indicate the skin moisture content. Using such equipment to measure the skin moisture content before and after work will help to assess moisture lost

from employees' skin during work and could be a useful tool in

identifying the risk of developing occupational dermatitis from this cause. It will also monitor the effectiveness of any after- work creams used.

N

nformafion, nstructon and tranng (COSHH reguaton 12) 64 Human factors are critical in determining the effectiveness of control

measures. Studies have shown that skin exposure is often increased

by poor work practices. Engineering controls and PPE programmes are unlikely to be fully effective unless they are supported by appropriate levels of management. Employers must therefore

regularly inform, instruct and train employees about:

• the risks to health from skin exposure; and • the precautions needed to prevent or control skin exposure.

I1NF0RMATl0N, INSTRUCTION AND TRAINING

Hafr preparations are cosmetic products. Generally, hairdressers

took this to mean that exposure to hair preparations would not cause health effects. Experience has shown, however, that hafrdressers are at high risk of developing either irritant or

allergic contact dermatitis from frequent multiple exposures

over long periods to hairdressing products such as shampoos, dyes, bleaches, soaps and detergents. If hafrdressers'

employers provide suitable information, instruction and

training, health risks could be managed more effectively.

Concusons 65 If workers are made aware of the potential sources of skin exposure,

how to use control measures properly and instructed in work methods which prevent or minimise skin exposure, then health

effects due to skin exposure can be eliminated from the workplace.

Appendix 1

Reevant egsaUon The Health and Safety at Work etc Act 1974 (the HSW Act) and

several sets of regulations are relevant to the control of risks to health which arise from skin exposure to chemical agents at work.

These regulations are: • the Control of Substances Hazardous to Health Regulations 1999

(COSHH); • the Management of Health and Safety at Work Regulations 1992; • the Chemical (Hazard Information and Packaging for Supply)

Regulations 1994 (CHIP); • the Personal Protective Equipment at Work Regulations 1992.

2 The HSW Act is an umbrella Act which is concerned with securing the health, safety and welfare of people at work, and with protecting those who are not at work from the risks to their health and safety from work activities.

3 COSHH provides a legal framework to protect people against health

risks from hazardous substances used at work. It applies wherever

there is a risk at work of health effects from skin exposure to

chemical agents. COSHH requires employers to:

• assess the risk, ie identify where chemical agents are used at

work and evaluate whether that use causes a health effect; and

• either prevent or adequately control the risk by putting control

measures in place.

COSHH requires employers to monitor the effectiveness of their controls,

in some situations to carry out air monitoring and health surveillance and

in all cases, inform, instruct and train the workforce about: • the risks to health caused by exposures to substances hazardous

to health; and, • the precautions which should be taken.

4 CHIP requires suppliers to identify the hazards of the chemicals they

supply, to give the hazard information to their customers and to

package their chemicals appropriately.

5 The Personal Protective Equipment at Work Regulations deal

with the design, construction, testing and certification of protective

clothing and other types of ppe. They require PPE to be cleaned,

maintained, used and stored properly.

6 The Management of Health and Safety at Work Regulations require all employers and self-employed people to assess the health and safety risks to workers and any others who may be affected by their undertakings. Following the risk assessment it may be

necessary to take action to control the risks from the hazard.

O2

References and further readng References

1 The Health and Safety at Work etc Act 1974

HMSO 1974 ISBN 0 105437743

2 General COSHH ACOP and Carcinogens ACOP and Biological

agents ACOP. Control of Substances Hazardous to Health

Regulations 1999. Approved Codes of Practice L5

1999 HSE Books ISBN 0 7176 1670 3

3 Medical aspects of occupational skin disease

1998 HSE Books ISBN 07176 15456

4 Cherry NM. Recent advances Occupational disease BMJ99 1397-9

5 EH4O/2000 Occupational exposure limits 2000 HSE Books ISBN 0 7176 1730 0

6 CHIP2 for eveiyone HSG126 1995 HSE Books ISBN 0717608573

7 Approved supply list — CHIP2. Information approved for the

classification and labelling of substances and preparations

dangerous for supply L61 1995 HSE Books ISBN 071760858 1

8 Personal protective equipment, guidance notes on UK regulations January 1996 Department of Trade and Industry URN 96/528

9 The Cosmetics Products (Safety) Regulations 1996 SI 1996/2925 ISBN 011 0633229

10 Health surveillance programmes for employees exposed to metal-

working fluids: Guidance for the responsible person INDG1 65

1994 HSE Books Free leaflet

Further reading • Agricultural pesticides AS27 (rev) 1995 HSE Books Free leaflet

• Interpreting biocide health and safety data sheets IACL47

1989 HSE Books Free leaflet

• Personal protective equipment: A ceramics industy booklet IACL56

1996 HSE Books Free leaflet

• Glutaraldehyde and you IACL64(rev 1) 1998 HS Books Free leaflet

• Dermatitis in printing ACL1O1 1996 HSE Books Free leaflet

• Arsenic and you MSA8 1991 HSE Books Free leaflet

• Benzene and you MSA13(rev 1) 1997 HSE Books Free leaflet

• Nickel and you MSA1 4(rev 1) 1997 HSE Books Free leaflet

• Chromium and you MSA1 6 1992 HSE Books Free leaflet

• Cobalt and you MSA17 1995 HSE Books Free leaflet

• Beiyllium and you INDG311 1995 HSE Books Free leaflet

• PCBs and you MSA19 1995 HSE Books Free leaflet

• IVIbOCA and you MSA21 1996 HSE Books Free leaflet

• Health risks from metalworking fluids: Aspects of good machine

design INDG1 67 1994 HSE Books Free leaflet

• Metalworking fluids and you INDG1 69 1994 HSE Books Free leaflet

• A guide to risk assessment requirements INDG21 8 1996 HSE Books Free leaflet

• Preventing dermatitis at work 1NDG233

1996 uSE Books Free leaflet

• Biological monitoring in the workplace INDG245

1997 HSE Books Free leaflet

• Health risks management: A guide to working with so/vents HSG188 1999 HSE Books ISBN 0717616649

• Working safely with solvents 1N0G273 1998 HSE Books Free leaflet

• Skin cancer caused by pitch and tar MSB4 HSE Books Free leaflet

• Skin cancer caused by oil MSB5 HSE Books Free leaflet

• Reactive dyes: Safe handling in textile finishing TIS5 1997 HSE Books Free information sheet

• Skin creams and skin protection in the engineering sector EIS1 4 1994 HSE Books Free information sheet

• Chemical cleaners CIS24(revl) 1998 HSE Books Free Information sheet

• Cement C1S26(rev) 1996 HSE Books Free information sheet

• Solvents CIS27(revl) 1998 HSE Books Free information sheet

• Occupational dermatitis in the catering and food industries FIS1 7

1997 HSE Books Free information sheet

• Rash decisions UK4350 HSE video on work-related dermatitis

• Dermal exposure to non-agricultural pesticides EH74/3 1999 HSE Books ISBN 07176 1718 1

• Choice of skin care products fbi- the workplace: Guidance for employers and health and safety specialists HSG2O7

2001 HSE Books ISBN 0 7176 1825 0

• Latex and you INDG32O 2000 HSE Books Free leaflet

• Selecting protective gloves for work with chemicals INDG33O

2000 HSE Books Free leaflet

• Cost and effectiveness of chemical protective gloves HSG2O6

2001 uSE Books ISBN 0 7176 1828 5

While every effort has been made to ensure the accuracy of the references listed in this

publication, their future availability cannot be guaranteed.

Printed and published by the Health and Safety Executive C70 01 /01 OQ

HSE BOOKS

MAIL ORDER HSE priced and free

publications are available from:

HSE Books P0 Box 1999

Sudbury Suffolk COlO 2WA Tel: 01787 881165 Fax: 01787 313995

Website: www.hsebooks.co.uk

RETAIL HSE priced publications

are available from good booksellers

HEALTH AND SAFETY ENQUIRIES HSE InfoLine

Tel: 08701 545500 or write to:

HSE Information Centre Broad Lane

Sheffield S3 7H0 Website: www.hse.gov.uk

A1 lNl ANI.) MANA(.lN( FK Al )Vl)llF< I)l)M SKIN EXPOSURE 1)1111 MICAI. A(l NI

£8.00

HSG2O5

ISBN 0-7176-1826-9

9 j,i,618262