Assessing and managing risks at work_froj

kn

OXpOSULO
(to chemica agents)

Health &Safety Executive

HSE

(GuidanceD for employers and health and safety specialists

Assessing and managing risks at work

aExpu
to chemical agents

frD

HSEBOOKS

Guidance for employers and health and safety specialists

 Crown copyright 2001

Application for reproduction should be made in writing to: CopyrightUnit, Her Majesty's Stationeiy Office, St Clements House, 2-16 Colegate, Noiwich NR3 BQ

First published 2001

ISBN 07176 18269

All rights reserved. No part of this publicationmay be reproduced, stored in a retrieval system, or transmitted in any form or by any means(electronic, mechanical, photocopying, recording or otherwise) withoutthe prior written permission of the copyright owner. This guidance is issued by the Health and Safety Executive. Following the guidanceis not compulsoryand you are free to take otheraction. But if you do follow the guidanceyou will normallybe doing enough to comply with the law. Health and safety inspectorsseekto securecompliancewith the law and may refer to this guidanceas illustrating good practice.

II

Contents
1...
Introduction

2... The law 2... Skin and chemical agents 4...

Health effects 4... Effects at the site ofexposure 6... Effects elsewhere in the body Prevention or cure? Recognising

7...

8...

a hazard

11... Assessing health risks 11... Exposure pathways 12... Measuring skin exposure 14... Managing risks 14... Preventing or controlling exposure 15... Eliminationand 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 furtherreading

ill

ntroducfion
This guidance provides practicaladvice to employers and the selfemployed on how to control skin exposure to chemical agents in the workplace,to protectthe 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 be

explanation of how temporary or permanent health effects can caused by skin exposure to chemical agents; examples of chemical agents which are knownto cause either

temporaryor permanenthealth effects afterskin exposure; practical adviceon how to assess and manage risk of skin

exposure to chemical agents.

The aw
2
The law requires that employers makea suitableand sufficient assessment of the health risks from skin exposureto chemical agentsat work. Thisis covered by the Health and Safety at Work etc Act 1974 (the HSWAct)1 and the Control of Substances Hazardous

to Health Regulations 1999 (COSHH).2Having completedthe assessment, there is a furtherduty to take the stepsneededto preventor adequatelycontrol exposure to the hazard, and to use and maintain the relevant controls. 3 Manyemployersare unaware they havelegal dutiesunder COSHH to make sure that employees' exposureto chemical agents by absorptionthroughthe skin or contactwith the surface of the skin is
either prevented or, wherethis is not reasonably practicable, adequately controlled. This guidance has been preparedto help

employerscomply with their legal duties.

SeeAppendix 1 for other legislation(in additionto the HSWAct and COSHH) relevant to the control of health risks from skin exposureto chemical agentsat work.

Skn and chemca agents

5 Skin acts as a barrierto limitthe loss of water and otheressential compoundsout of the body and the permeation of substancesinto the body. It is madeup of many thin layers of cells and is rich in proteins and fats. The thickness of the skinvaries acrossthe body and is thickest on the palms of the handsand soles of the feet. The
skin needswaterto functionproperly. Low humiditycan adversely affectthe skin by causingit to dry out and crack. Damage to the skin from cracks, cuts, burns or abrasions orfrom diseases such as eczemaand psoriasis impairs the skin's barrierpropertiesand allowssubstancesto penetrate more easily.

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

from biological agents (such as micro organisms) and physical agents (such as noise, vibrationand friction).

____________

7 Many chemical agents have the potential to cause serious health effects afterskin exposure (often referred to as dermal exposure). Yet, skin exposure to chemical agents happens everyday for many workers. If a chemical agent comes into contactwith the skin, it may cause health effects, eitherby provokinga reaction at the site of exposure or by enteringthe bloodstream, which could cause or contribute to a toxic effect somewhere else in the body.

8 Chemical agentscapableof provokinga reactionat the site of

exposure can be divided into threegroups: substanceswhich cause irritation at the site of exposureand may

HeaLth effects Effects at the site ofexposure

cause irritant contactdermatitisif the skin is exposed enoughtime and in sufficient concentration;

to them for

substanceswhich the skin to substanceswhichcauseother skin

sensitise dermatitis;

cause allergiccontact

diseases, eg contact urticaria,

loss of normal skin pigmentation, skin canceretc.

Irritant contactdermatitis
9 Substances which causeirritantcontactdermatitisincludeacids,
alkalis, soaps, detergents and some, but not all, solvents. Irritation at the site of exposurecan vary from inflammation (redness and swelling) of the skinwhich can developafter regular contactwith mild irritants such as weak acids (pH between 4 and 7) or alkalis (pH between 7 and 9), to more severe tissuedamage,eg a chemical

burn from brief skin exposure to a corrosive substance. Defatting of the skin (ie the removal of naturaloils) can also occur if the skin is exposed to substancessuch as detergentsand (some) solvents. This damagesthe barrier function ofthe skin by breaking up the structure of the surface layers of the skin, leaving dry, crackedand scalyskin.

10 Localised inflammation is a normal response by the skin to skin damage. Usually, inflammation subsidesonce the damageto the skin has healed. However ifthe irritation is particularly severe or a chemical burn has occurredand destructionof skin tissuehas taken place, the skin will scar instead of healing. Ifthe skin is repeatedly exposed to irritants, a conditionknown as hyper-irritability may
develop. This means that the skin will become inflamed more readily whenit is exposed to irritant substances than would happen to someonewith normal skin.

Allergic contact dermatitis

11 Allergiccontactdermatitis (or skin sensitisation) is an immunological response to a chemical agent. The effects are difficultto distinguish from irritant contactdermatitis. However, once sensitisation has been induced, allergic contactdermatitismay be triggered by very small amounts of the substance. Sensitisation builds up with time and it may be weeks or even monthsbefore the conditionis apparent. By this time the employee will have become sensitised and there is no remedy otherthan to preventfurther exposure. This means that, once sensitised, a person can never be exposedto the chemical agentagain without suffering an allergic reaction.

Otheroccupationalskin diseases
12 There are also otheroccupational skin diseases, eg contact urticaria, loss of normal skin pigmentation, skin cancer etc, which can be caused by skinexposure to chemical agents. Together theyconstitute a substantial minority of the total numberof cases of occupational skin
disease and are dealt with in more detail in Health suiveillance of

occupationalskin

disease.3

Incidence of work-related dermatitis

1

3 Thereis no obvious visual distinction between irritant and allergic

contact dermatitis; theycan look the same in spite of the differences in underlying mechanism. Early symptomsare redness and irritation, which can progress to swelling, scaling,blistering crackingand bleeding. Once the surface ofthe skinis broken, infection can develop, making the condition worse. The skin mayalso developa hardness as a natural defence to frequentexposure to certain chemical agents. The handsare most often affected, but ifthe agents

are in the form of aerosols, dusts, or fumes, the face and neck can also be affected. Skin exposure via contactwith contaminated clothing or hand transfer of chemical agents can result in otherparts of the body being affected, eg the chest, arms, legs andface.

14 HSE estimated that in 1995 about 66 000 people in GreatBritain were suffering from a skin disease caused by their work. About 95% of thesecaseswerefrom exposure ofthe skin to chemical agents.

This caused around half a million lost working days. HSE has estimatedthat the cost to employers of skin disease caused by work was between 24 millionand 59 million in Great Britain in 1995/96. The EPIDERM/OPRAskin surveillance scheme4 funded by HSE, reportsthe percentage breakdownof casesof work-related skin
disease caused

15

by exposure to chemical agentsas: 15.8% of cases caused by chemicalsand materials used in the

of rubberproducts; 14.3% of casescaused by soaps and cleaners; 9.9% of casescaused by wet working;and, 8.7% of cases caused by an allergic reactionto component materials in personal protective equipment (PPE)worn atwork. For example, manyworkers have been foundto suffer a contact allergic reaction to
manufacture

the proteins contained in gloves madefrom natural rubber.

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

Catering and food processing Engineering Agriculture

Hairdressing Cleaning Printing Health care

Construction Rubber

S Offshore

EXAMPLES OF EXPOSURE
Hairdressers are at high risk ofdeveloping either irritant or

allergic contact dermatitisfromfrequent multiple exposures over long periodsto hairdressing productssuch as shampoos, dyes, bleaches, soaps and detergents.
Construction workers are at high risk ofdevelopingallergic

contact dermatitisfrom exposures to wet cement.

Engineering workers are at high risk ofdeveloping irritant

contactdermatitis fromfrequent exposures to metalworking fluids.

Effects elsewhere in the body

16 Many substances don't have an effectat the site of exposure but may be absorbed throughthe skin and enterthe bloodstream. Once

in the bloodstream, they are carried around the body and maythen cause or contributeto a toxic effect elsewhere in the body. This is referred to as systemic toxicity.
1

7 Substances which pass readily through the skin includemany low

molecularweightsubstances and many organicsolvents. For any chemical absorbed into the body, the resultant health effects will be different for differentsubstances and although some effects may becomeapparentwithin a few hoursor daysof exposure, other effects can take monthsor years to appear. EXAMPLES OF SYSTEMIC EFFECT
known as methylene bis (ortho-chloroaniline), is used in the manufacture ofpolyurethane articles. The prime health concern with MbOCA is bladder cancer. MbOCA readily
14bOCA, also

the skin and this will lead to an increased risk of bladdercancer

crosses

Dermal exposure to organophosphate pesticides during sheep dipping has produced damageto the nervous system in workersfailing to wear appropriatepersonal 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 presenceof health and safety hazards in their workplace, evaluate the risk of harm occurring and developmeasures to adequatelycontrol the risk. This will prevent health effects, includingthose caused by exposureof the skin to chemical agents.
1

9 Occupational hygienists and other health and safety professionals

can play an important role in the recognition of workplacehazards. Theycan evaluate the risks posedto employees' health when workingwith chemical agents and can advise on the most practicable means of eitherpreventingor controllingsuch risks.

Recoqnsng a hazard (COSHH reguaton 6)

20 The first step in carrying out an assessment of risk of skin exposure
is to identifychemical agentseither used or generated in the workplace. The second step is to decidewhich have the potential to
cause health effectsfollowingskin exposure.

21 Although many chemical agents are assignedlimitsfor exposure throughinhalation (as publishedin the HSE publicationEH4O, Occupational exposure limits)5 thereare no such limitsfor skin exposure. You should therefore make a judgementabout the potentialfor chemical agentsto cause health effects based on information from various sources.

22 Many chemical agentsare knownto cause health effects following

skin exposure. Some commonexamples of occupationalcontact irritantsand sensitisers are listed in Health surveillanceof occupational skin disease.3 Chemical agents which are known to be capableof being absorbed throughthe skin and which may contributeto systemictoxicity are assigned a 'skin notation' (symbol Sk) in EH4O.5 The criteriafor assigninga skin notation are that exposure to the substancevia the skin may: make a substantial contributionto body burden (when compared to the contribution attributableto inhalation exposureat the occupational exposurelimit); and cause systemiceffects so that conclusionsabout exposureand health effects based solely on airborneconcentration limits may

be invalid.

23

Paragraph 39 ofthe General COSHH ACOP,2 on the needto consider exposure by routes otherthan inhalation states that skin exposure:

'shouldbe controlled to a standardsuch that nearly all the population could be exposed repeatedlywithout any adverse health effect As there are no publishedexposurestandardsavailable for skin exposure,the most practicablemeansof ensuringadequatecontrol is to preventor minimiseskin exposureto chemicalagents.

24

Where dermal absorptionof a chemical mayadd significantly to the total dose received by a worker during their normal working day, considerbiological monitoringas a means of assessing the effectiveness of control.Biological monitoringis discussedin more detail in paragraphs 38-39.

25 The CHIP Regulations6 require chemical suppliersto identify the hazards (or dangers) of the chemicalsthey supply. This is called classification. Theymust give this information to the peoplethey
supply the chemicalsto. The followingrisk phrases in the Approved guide to the classification and labelling ofsubstancesand for preparations dangerous supply,7 are applied to classify chemicalswhich cause effectsfollowingskin exposure:

R34, causes burns; R35, causes severe burns; R38, irritating

to the skin;

R43, may cause sensitisation

by skin contact;

R66, repeated exposure may cause skin drynessor cracking.

These risk phrases applyto chemicalshaving an effectaway from

the site of exposure: R21, harmful in contactwith the skin; R24, toxic in contact withthe skin; R27, verytoxic in contactwith the skin;
R48/21, harmful, serious exposure;

R39/27, danger the skin.

dangerof damageto prolongeddermal toxic, dangerof seriousdamageto by of very effects contactwith

health by R48/24, dermal exposure; health prolonged serious irreversible in

26

HSE publications can be a good sourceof information, eg Health surveillanceof occupational skin disease.3This adviseshealth professionals on suitable and necessary health surveillance for workersat risk from skin exposureto irritants, sensitisers and other non-infective skin damagingagents. Trade associations and trade journalscan be anothergood sourceof information, as experience within the industrymay suggesta health risk from a particular substance or process.

Assessng heafth hsks

(COSHH reguaUon 6)
27 The COSHH assessment should firstly identifywherever chemical
agentswhich have the potential to cause healtheffectsare used at work.The nextstep is to assess the potential for skin exposure to those chemical agents and therefore the risk Considerpatterns of use of the chemical agentand workeractivities. The aim is to identify how, how often, and for how long peopleare exposed and which partsof the body are exposed

23

For somejobs it may be quite straightforward to assess the potential for skin exposure and visual observations may be enough to confirmthis In othercasesskin exposurewill be less predictable

or less obviousand exposuremeasurements maybe requiredto identifysourcesand exposurepathways.

Exposure pathways 29 The link between a hazardsource and a workeris called an 'exposure pathway'. Skin exposurenormallyoccurs by one of three pathways: immersion, depositionor surfacecontact. 30
Immersion occurswhen the skin comes into direct contactwith a

liquid or solid. A common example of this pathway is the poor practiceof handsbeing put into a solvent during the manual
cleaning or degreasing

of mechanical components

31 Deposition occurswhendroplets dusts fumesor aerosols impactor settle onto the skin Aerosols may be generated as part of a work activity (eg spraypainting) or theymay be incidental to it (eg emissions from a nearby process). Common examples of this pathway include: splashing during the handling of liquids, dustgeneration from powder handling, and exposure to aerosols during paint spraying.

32

Surface contact occurswhenthe skin touchesa contaminated surface. This can be a majorsourceofskin exposureduring cleaning and maintenance operations, such as exposure to oils/greases during repair and maintenance of machinery.

/1

33 Transferring contamination by hand to otherparts of the body is an importantsourceof skin exposure. Chemical residues on hands are
frequentlytransferred to the eyes, nose and mouth and may also contaminate food and tobaccoproducts.Contaminated clothing can also be a sourceof skin exposure, particularlyto the hands, when
removing contaminated PPE.

Measuringskin exposure
34
Measuring skin exposurecan be useful in judging the effectiveness of control measures, such as any PPE that may be worn. Routine exposuremeasurements can also be useful in identifying any trends in workplaceexposure. Methods for assessing skin exposure fall into

five categories: surrogate skin methods;

35

removal techniques;

use of fluorescenttracers; biologicalmonitoring;

modelling.

Surrogate skin methods

Surrogate skin methodsinvolve workerswearingchemical collection pads.After a specific task has been completed,the pad is removed

and analysedfor chemical content. Two general approacheshave been used: patch samplers covering small skin surface areas and garmentsamplers coveringwholeanatomical regions, eg gloves, coveralls. The validityof these methods rests on the ability of the samplingmedium to captureand retain chemicals in a manner similarto skin. Although none of the garmentsamplers in common use has been systematically testedfor retention efficiency, surrogate skin samplinghas proved to be useful as a simpleand cost-effective method for measuringskin exposure.

Removal techniques

36

Removal techniquesincludeskin washing and wiping. These measure only what can be removedfrom the skin at the time of

sampling,ratherthan the actual skin loading. Water-alcohol wash solutions are generally used to assess hand exposure, while

/2

wiping techniques can be appliedto work surfaces. Sampling of work surfaces can be useful as it provides an estimate of dermal exposure potential and can be an effective way ofshowing that a cleaning or segregation policy is working. Handwash sampling procedures can normallybe standardised to ensurethat they are operator-independent. Skin-wiping procedures are inherently operator-dependent however, so they are much morevariable.

Use offluorescent tracers

37 Skin exposurecan also be quantified directlyand non-invasively by

materials which are then viewed measuring depositionof fluorescent under ultra-violet light. Imaging usingfluorescentdyes has been

used to quantifyskin exposure and has provedvery useful for workereducation. Thistechniquehas a majorlimitation, as the use of a fluorescenttracer usually requires introducinga foreign substanceinto the productionsystem, although some contaminants are naturally fluorescent.

Biological monitoring

33

Biological monitoringcan be used to indicate how much of a chemical has entered the body. It is especially useful when: thereis the likelihood of significantabsorptionthroughthe skin;

controlof exposurerelies (wholly or partly) on PPE; thereis a reasonably well-defined relationship between biological monitoringand systemiceffect; or systemictoxicity is related to long-term tissue accumulation of a chemical and not airborne measurements taken at a particulartime (eg PCB5).

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

a sample of breath, urineor blood andcomparingthat measurement against a reference value called a biologicalmonitoringguidance value (BMGV). HSE uses two typesof BMGV one is health-based and is calleda Health Guidance Value (HGV) and the otheris a hygiene-based value called a Benchmark Guidance Value (BMV) and is set at a level which can be achieved atworkplaces 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 derivedfrom modelling. However veryfew data on skin exposure are available. The EASE (Estimation and Assessment of Substance Exposure) model is in widespread use throughoutthe European Unionfor the occupational

___________

exposureassessment of new and existing substances. It is used to estimate inhalation exposureto airbornecontaminants, or exposure of the skin. Exposure rangesare estimates based on data from several sources, principallythe United States Environmental Protection Agency (EPA), HSE and published literature. Skin exposureassessment does not include any form of uptake such as absorptionthroughthe skin

Manaqing hsks (COSHH reguaUon 7)

Preventing or controllingexposure
41 Once a skin contamination problemhas been identified prevention or controlof exposure will be necessary. The first consideration should be to prevent exposure eitherthrough eliminationof chemical agents with the potentialto cause either healtheffectsfollowingskin exposure; or, temporary or permanent substitution of the chemical agentwith a lesshazardous substance.

42 If this is not reasonablypracticable,

adequate control will need to be achieved. In practice, skin exposure often occurs via a combination of exposurepathways. But, it should be possibleto prevent or

control exposure by applying good occupational hygienepractice, throughone or more of the followingoptions (in order of priority): enclosingor mod)5jingthe process to isolate the hazard source; installing local exhaust ventilationcloseto the hazard source, to remove the chemicalagent from the workplace; mod jfijing working methods if appropriate, eg to excludeor restrictworkers'access to areas wherethereis a risk of exposure; providing workers with PPE to protectthem from the hazard.

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

programme, and are discussedin more detail in paragraphs57-59.

Elimination and substitution

44
Eliminatingthe use of a hazardous substance is most feasible at the process design stage. In the case of existing systems, elimination ofa hazardous substance usually means achangeof 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 otherrisks such as noise, dustor ergonomic problems, and exposure to these risks must be controlled too.

1iMINATION
A gardenerat a large estate developed skin irritationon his lower legs during the winter monthsonly. This was diagnosed as arisingfrom exposure to an irritant chemical released by a species of caterpillar which nested in the
gardens. The problem with the gardener's skin stoppedonce the caterpillar nests had been eliminated using a single

applicationofan appropriatepesticide.

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

or replacethe substance withsomething lessharmful. For example,
chemicalsused in cleaning are often too aggressive and can be replaced by less hazardous or lessconcentrated products. Solventbased materials can often be replaced by water-based products and surfactant degreasers can be replaced by milder non-ionic products. SUBSTITUTION
Employees at a metalworkingcompany started to sufferfrom skin rashes, thought to be caused by exposure to metal-

working fluids. The company tookspecialistadvice, installed an automaticfluid mixer and substituted a higher quality metalworking fluid.
The problem ofskin rashes disappeared.Improved manage-

ment ofthe metalworking fluid resulted in significantsavings throughlowerconsumption ofmetalworking fluid and less machine downtime, while the metalworking fluid was changed.

46 A change in physicalform may also reducethe potential for skin

exposure. Contactwith powderscan be reducedby using granulated or liquid formulations, substituting powdered eg formulations with less dusty pellets. Thiswill reduce the amountof material released into the air and thereforereducecontamination of surroundingsurtaces. In some cases, it may be possibleto use pre-

packagedformsof the chemical to eliminatehandlingoperations such as scoopingor weighing.

Engineeringcontrols
47 If prevention of exposure is not possible, the next option is to
considercontainment of the source,usingclosed handlingsystems or partialenclosurewith some form of local exhaustventilation (LEV). Closed handling systems (eg the use of fully enclosed
automated chemical additive systems) can be very effective in controllingskin exposure. Such systems essentially remove the risk,

as thereis no potential for skin exposureto the chemicalsduring normal operation, providedthe plant is properlymaintained. However, there will be a potentialfor skin exposure during maintenance and repair operationsand, therefore, separate and

clearly definedcontrol measures will be needed for these operations. Muchcan also be achieved by the use of simple engineering controls, such as partial enclosureand LEV.

_____________________ PARTIAL ENCLOSURE WITH LOCAL EXHAUST

VENTILATION (LEV)

A numberofworkers employed to bagthy cementpowder complained ofskin irritation on their hands and faces. The company knew that skin exposure to wet cementcouldcause allergiccontact dermatitis, but did not realise that skin exposure to thy cementpowdercouldlead to a mild irritant dermatitis. They had not thought that they needed to provide
any means ofcontrolling worker'sskin exposure and had only providedtheir workers with respirators to protect against inhalation ofdusts. The situation was improved by installing a partialenclosure with local exhaustventilation (LEV) at the baggingstation to control the dust asfar as possible and also by providingsuitable gloves, overalls and respirators.

Process modification

48

Having contained the hazardous chemical as far as possible, the next option is to modify the processto minimise manualhandling operations. This can be done by using automated systems. For example the electronics industrycan apply methacrylate based glues onto circuit boards by remote and fully containedmethods

rPROCESSMODIFICATION
The offshore industiy add glutaraldehyde, a recognisedskin sensitiser, as a biocide to well injection sea water This inhibits

the growth ofsulphate-reducing bacteria and so prevents productionofhydrogen 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 for pumpingsystem. This avoids the need manualdecanting which can lead to skin exposure. and measuring operations

Working methods
49
Working methodscan be modifiedto controlskin exposure. One very effective way of achieving controlis to prevent or minimise the

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

(ODIFIED

WORKING

METHODSk

An office workerin an electrical components manufacturing companydeveloped a skin rash, especially on herface. Part of herjob was to issue worksheets directly to employees in
workshops where solderingtookplace. The office worker'sjob was changed so she no longerneeded to go into the workshops. Herskin condition immediatelyimprovedwhen she was removedfrom exposure to solderingfume.

50 If contamination of surfacescannot be prevented, it can be reduced

by providing impermeable, easy-to-clean worksurfaces. These should be cleanedon a regularbasis.Anotherway of reducing contamination of worksurfaces is to use disposableabsorbentpaper 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. Spillagecontrols,eg using drip trays, will also preventthe spread of contamination and spillagescan then be cleanedup without generatingdust or increasing the likelihood of
skin exposure.

52

Risks from exposureto many chemical agentscan be reducedor

controlledby regularwashing. A very high standard of personal hygieneis importantand this should be encouraged by providing clean washingfacilities as near as possibleto the area of work. Exposed skin areas should be washedthoroughly at breaks and afterwork using the least aggressive cleanerpossibleand avoiding the use of solvents or abrasives. The skinshould be rinsed in warm water and carefully dried using cleantowels. Pre-work creamscan be applied before startingwork or on returning to work after a break. An after-work moisturising creamcan also be useful as this will help

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

comes into contactwith detergents. Pre-work and after-work creams are discussedin more detail in paragraphs 57-59.

53

of skin exposure should be used only as a last whenother methods of control are not reasonably practicable. resort, 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 numberof limitations: it can only protectthe wearer; it has to be selected carefully; it has to be put on, wornand taken off properly; it maylimit the wearer's mobilityor ability to communicate; its continuedeffectiveness will depend on proper cleaning, maintenance, trainingand adherence to good working practices.
PPE for control

Personal Protective Equipment (PPE)

54

PPE is available in a wide range of natural and synthetic materials. Typical examples of PPE provided

to withstandexposureto chemical

agents include gloves, aprons and overalls. When selecting PPE, take care to ensurethat the quality, constructionand maintenance

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

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

exposureas contaminant can becometrapped insideill-fittingPPE, againstunprotectedskin. Employers should providePPE that is 'CE marked',6 compatiblewith the wearer, compatiblewith the work to be done and compatiblewith any other PPE to be worn (eg ear
defenders, safety gogglesor respirator).

56

Employers should also provideemployees with information, instruction, trainingand 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.

PPE

JSING There are

many situations where the use of PPE must form an essential part ofthe overall control strategy, because other means ofcontrol may be impracticalor may not achieve adequate control by themselves.
Examples ofsuch situations are the cleaningand maintenanceofprocess plant and the repair ofbreakdowns. Also, routine tasks ofshort duration such as taking samples

from chemical processes and longerterm tasks such as sprayingpesticidesrely heavilyon PPE as aform ofcontrol.

57 A wide variety of skin care productsare available for occupational

use and generally fall into one of two categories:pre-work or afterwork creams. Pre-work creams(usually referred to as 'barrier' creams) are designed to providea protective layer between the skin and the substance. Theyare generally formulated to repel eitheroil,
grease, solvents etc (called 'dry uses') or water-based substances, such as weak acids and alkalis. Manufacturers claim that some

Skin care products

creamsgive protection against both. After-work creamsare general purpose'moisturisers' designed to replacethe natural skinoils removed by washing and the solventaction of substances on the skin. Skin care productsare definedas cosmetics and as such are covered by the CosmeticsProducts (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 efficacytest.

58

Pre-work creamscannot 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 applyingcreamsand so completeskin covercannot be guaranteed. It is not alwaysobvious if the barrier has been removed, damagedor thinned. Because of this, pre-work creams should not be regarded as PPE. They cannotgive the same level of protection as glovesand should not be used as an
alternative to properlyselected PPE. 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

59

the removal of dirt when washing thereby making it less likelythat powerfulsolvent or abrasive cleaners are used. After-work creams are particularly beneficial, as theyassist in restoring the natural moisture contentof the skin's surface layer and should be used regularly afterwashing.

USING AFTER-WORK CREAMS

When

air-impermeable gloves are worn for extended periods,

a hotand humid atmosphere is establishedinside the glove. This condition will act as a skin irritant and may promote the growth ofbacteria. When the hands are removedfrom gloves theyneed to be washed and dried thoroughly. An
after-workmoisturisingcream can then be applied to help restore the skin's natural oils.

Heafth surveillance (COSHH reguation 11)

60
Health surveillance will help to identifythe early symptomsof dermatitis or otherhealtheffectscaused 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 whetheran adequate standard of control is being maintained. It may give an earlyindicationof 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 healtheffects, arrangements
should alreadybe in placeto identifysuch cases. Workplace health surveillance can be as simpleas administeringa brief employee questionnaire and conductingregular inspection of the potentially exposed skin areas ofworkersto findout if they are experiencing any skin symptoms. If a questionnaire is used,seek adviceon its suitabilityfrom an occupationalhealth nurseor doctor. A suitably trained responsible person, however, can administerthe questionnaire and carry out skin inspections. An example of an appropriate questionnaire may be found in Health surveillance programmes employeesexposed to metalworkingfluids.1 for

63 The trainingof a responsible

person should include instructionon the characteristic signs of the particular health effects. Employees

should be encouragedto look for these signs by self-inspection and reportthem. Confidentiality must be safeguarded if such reporting is to be effective. HEALTH SURVEILLANCE
The surface layer

ofthe skin must containat least 10% ofits

in water tofunction properly. Portable monitoring equipmenthas been developed to measure the electrical
weight

conductivityofthe skin, which can indicatethe skin moisture content. Using such equipmentto measure the skin moisture contentbefore and afterwork will help to assess moisture lost from employees' skin during workand could be a usefultool in dermatitis identifying the risk ofdeveloping occupational from this cause. will also monitor the effectiveness ofany afterworkcreams used.

It

nformafion, nstructon and

tranng (COSHH reguaton

64

12)

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 controlsand PPE programmes are unlikely to be fully effective unless they are supportedby appropriatelevels of management. Employers must therefore
regularly inform, instructand train employees about: the risks to healthfrom skin exposure; and

the

precautions needed

to prevent or control skin exposure.

I1NF0RMATl0N,

INSTRUCTION AND TRAINING

Hafrpreparations are cosmetic products. Generally, hairdressers tookthis to mean that exposure to hairpreparations would not cause health effects. Experiencehas shown,however, that hafrdressersare at high risk ofdeveloping either irritantor allergiccontact dermatitis fromfrequent multiple exposures over longperiodsto hairdressing products such as shampoos, dyes, bleaches, soaps and detergents. hafrdressers' employers providesuitable information, instructionand training, health risks could be managed more effectively.

If

Concusons
65 If workersare made aware of the potential sourcesof skin exposure,
how to use control measures properlyand instructedin work methods which preventor minimise skin exposure, then health effects due to skin exposurecan be eliminated from the workplace.

Appendix 1

Reevant egsaUon
The Health and Safety at Work etc Act 1974 (the HSWAct) 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 Safetyat Work Regulations 1992; the Chemical (Hazard Information and Packaging for Supply)

Regulations 1994 (CHIP); the Personal Protective Equipmentat Work Regulations 1992.

2 The HSWAct is an umbrella Act which is concernedwith 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 legalframeworkto 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 requiresemployers to: assess the risk, ie identifywherechemical agents are used at work and evaluate whetherthat use causes a health effect; and

either

controlthe risk by putting control prevent or adequately measures in place.

COSHH requires employers to monitor the effectivenessof their controls,

in somesituationsto carry out air monitoring and health surveillanceand 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 CHIPrequires suppliers to identifythe hazards of the chemicalsthey supply,to give the hazard information to their customers and to
package their chemicalsappropriately.

5 The Personal Protective Equipment at Work Regulationsdeal

with the design, construction, testing and certification of protective clothing and othertypes of ppe. They require PPE to be cleaned, maintained, used and stored properly.

The Management Health and Safety at Work Regulations of require all employers and self-employed peopleto assess the health and safety risks to workersand any otherswho may be affected by

their undertakings. Followingthe risk assessment it may be necessary to take action to controlthe risks from the hazard.

O2

References and further readng

References
1

The Health and Safety at Work etc Act 1974

HMSO1974 ISBN 0 105437743

General COSHH ACOP and CarcinogensACOP and Biological

Control ofSubstances Hazardousto Health Regulations1999. ApprovedCodes of Practice L5

agents ACOP. 1999HSE Books ISBN 0 7176 16703

3 4 5 6 7

Medical aspects ofoccupational skin disease

1998 HSE Books ISBN 0717615456

Cherry NM. Recent advances Occupationaldisease BMJ99 1397-9 EH4O/2000Occupational exposure limits 2000 HSE Books ISBN 07176 17300 CHIP2for eveiyoneHSG126 1995 HSE Books ISBN 0717608573

CHIP2. Information approved for the classificationandlabelling ofsubstances and preparations

Approved supply
list

dangerous for supply L61

1995HSE Books ISBN0717608581

8 9
10

Personal protective equipment, guidance notes on UK regulations

January 1996 Department of Trade
SI 1996/2925 ISBN 011 0633229

and IndustryURN 96/528

The Cosmetics Products (Safety) Regulations1996

Health surveillanceprogrammes employees exposed to metalfor Guidance for the responsible person INDG165 workingfluids:
1994HSE Books Free leaflet

Further reading
Agricultural pesticides AS27 (rev) 1995 HSE Books Free leaflet Interpretingbiocide health and safety data sheets IACL47
1989 HSE Books Free leaflet

Personal protective equipment:A ceramics industy booklet IACL56

1996 HSE Books Free leaflet

Glutaraldehydeandyou IACL64(rev 1) 1998 HS Books Free leaflet Dermatitis in printing ACL1O1 1996HSE Books Free leaflet Arsenic andyou MSA8 1991 HSE Books Free leaflet
Benzene

andyou MSA13(rev 1) 1997HSE Books Free leaflet Nickel and you MSA1 4(rev1) 1997HSE Books Free leaflet Chromium and you MSA1 6 1992HSE Books Free leaflet Cobalt and you MSA17 1995HSE Books Free leaflet Beiyllium and you INDG311 1995HSE Books Free leaflet

PCBs and you MSA19

IVIbOCA and you MSA21

1995HSE Books Free leaflet 1996HSE Books Free leaflet

Health risksfrom metalworkingfluids: Aspects of good machine design INDG167 1994 HSE Books Free leaflet Metalworkingfluids and you INDG169 1994 HSE Books A guide to risk assessment requirements INDG218
1996HSE Books Free leaflet Free leaflet

Preventingdermatitis

at work 1NDG233

1996uSE Books Free leaflet

Biological monitoringin the workplace INDG245

1997HSE Books Free leaflet

Health risks management: A guide

HSG188
1999 HSE Books

to working with so/vents

ISBN 0717616649

Workingsafely with solvents 1N0G273 1998 HSE Books Free leaflet Skin cancercaused by pitch and tar MSB4 HSE Books Free leaflet Skin cancercaused by oil MSB5 HSE Books Free leaflet
Reactive dyes: Safe handling

in textilefinishing TIS5 in the engineering sector

EIS1 4

1997HSE Books Free information sheet

Skin creamsand skin protection

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 Occupationaldermatitis in the catering andfood industries
1997HSE Books Free information sheet

FIS17

Rash decisionsUK4350 HSE video on work-related dermatitis Dermalexposureto non-agricultural pesticides EH74/3
1999 HSE Books ISBN 071761718 1

Choice ofskin care products fbi- the workplace:Guidance for

employersand health and safetyspecialists

2001 HSE Books ISBN 0 7176 18250

HSG2O7

Latex andyou

INDG32O

2000HSE Books Free leaflet

Selectingprotective gloves for work with chemicals INDG33O

2000 HSE Books Free leaflet

Cost and effectivenessofchemical protective gloves

2001 uSE Books ISBN 0 7176 18285

HSG2O6

While everyefforthas been made to ensuretheaccuracyof the references listed in this their futureavailabilitycannotbeguaranteed. publication,

Printedand published by the Health and Safety Executive

C70

01 /01

OQ

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A1 lNl ANI.)MANA(.lN( FK Al )Vl)llF< I)l)M SKIN EXPOSURE

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