National Industrial Chemicals Notification and Assessment Scheme

14.2Emergency procedures

Written procedures for workers for handling spills and other emergencies during formulation and use of trichloroethylene is good practice. Procedures to be followed during clean up of spills and first aid procedures should be recorded on the MSDS.

Trichloroethylene is listed in the Australian Code for the Transport and Handling of Dangerous Goods (ADG Code) which provides guidelines for handling emergencies during transport (Federal Office of Road Safety, 1998).

14.3Hazard communication

14.3.1Assessment of Material Safety Data Sheets

MSDS are the primary sources of information for the safe handling of chemical substances. Under the National Model Regulations for the Control of Workplace Hazardous Substances (the National Model Regs.) (National Occupational Health and Safety Commission (NOHSC), 1994) and corresponding State and Territory legislation, suppliers are required to provide MSDS to their customers for all hazardous substances. Employers must ensure that MSDS for any hazardous substance used in the workplace is readily accessible to employees with potential for exposure to the substance.

Trichloroethylene is currently on the List of Designated Hazardous Substances (National Occupational Health and Safety Commission (NOHSC), 1994) as a hazardous substance in concentrations at or above 1%. During assessment of MSDS in this report comparisons are made with the current listing and classifications. Seven MSDS for trichloroethylene (>99%) and 46 MSDS for trichloroethylene-containing products were submitted and assessed for compliance with the National Code of Practice for the Preparation of Material Safety Data Sheets (the MSDS Code) (National Occupational Health and Safety Commission (NOHSC), 1994). The 46 products contain >1% trichloroethylene (range 10% - >90%) and are therefore considered hazardous substances. Most products contain high concentrations of trichloroethylene, with almost one half (20) containing >60% trichloroethylene (see table 3 in chapter 7 for more information on concentration of trichloroethylene in products). An MSDS for one other product, a paint stripper, was also submitted but not included in the assessment as it contained 0.05% trichloroethylene.

The MSDS were divided into two groups, ie MSDS for trichloroethylene (>99%) and products containing trichloroethylene, for assessment. The assessment focussed on the adequacy of the information provided in relation to the following core elements of an MSDS: product identification; health hazard information; precautions for use; safe handling information; and contact point. Information considered most important in each of these sections was identified and checked for inclusion. The presence of an emergency telephone number and a statement of hazardous nature as required under the MSDS Code were also checked. The statement of hazardous nature required to be on MSDS for all hazardous substances is: ‘Hazardous according to criteria of Worksafe Australia’. The findings of the MSDS assessment are given in Table 33.

A sample MSDS for trichloroethylene, prepared in accordance with the MSDS Code, is provided in this report as Appendix 2. The sample MSDS, prepared from information obtained for the assessment of trichloroethylene is for guidance purposes only. Under the National Model Regulations, manufacturers and importers have the responsibility to compile their own MSDS and ensure that the information is up-to-date and accurate.

Table 33 - Findings of MSDS Assessment

N/A not applicable

* First Aid Statements as recommended by SUSDP for substances containing trichloroethylene.
Discussion of findings

Amongst both groups of MSDS, the Safe Handling Information section provided adequate information. Information considered important for this section was reference to appropriate conditions of storage, storage/transport incompatibilities, spills/disposal instructions, mention that fumes could evolve, and recommendations for fire fighters (see sample MSDS for details). However, deficiencies were noted in other sections, including:

omission of a Statement of Hazardous Nature

in the case of one MSDS for trichloroethylene, omission of several elements in the product identification section - major uses, UN Number, ADG Code, Hazchem Code and Poison Schedule.

omission of information on use of products.

in the acute health effects section, omission of information on skin absorption and cardiac effects; also nausea, headache, irritation to the upper respiratory tract, CNS symptoms, including unconsciousness, and skin defatting

in the MSDS for products, omission of information on chronic health effects

inappropriate first aid instruction to induce vomiting if ingested

inappropriate first aid instruction to give milk if ingested

omission of first aid instructions to avoid giving oils, milk or alcohol

omission of Australian exposure standard for trichloroethylene or citing of the ACGIH or other overseas exposure standards instead of the Australian exposure standard.

Of the points listed above, the omission on one trichloroethylene MSDS of most product identification information is of concern. The UN Number, ADG class, Hazchem code and Poisons Schedule classifications contain information relating to hazard identification and emergency response and are important for safe handling.

In the health hazard section, inclusion of the fact that trichloroethylene is absorbed through the skin is especially important, as it highlights the need to avoid skin contact, such as through engineering controls, safe work practices or personal protective equipment. Cardiac effects was another significant health effect omitted on many of the MSDS, and is the reason that a statement on avoidance of sympathomimetic drugs is recommended for inclusion in the advice to doctor section. Many MSDS contained neither a reference to cardiac effects or a recommendation to avoid sympathomimetic drugs (17 did not have an ‘advice to doctor’ section at all).

With regard to first aid instructions, it was noted that instructions contrary to the recommended SUSDP instruction (c), that is, do NOT induce vomiting, were given on three MSDS for trichloroethylene and eight MSDS for mixtures. Vomiting creates a risk of aspiration of trichloroethylene into the lungs and while the presence of other poisons in mixtures may justify an instruction to induce vomiting, where the dangers of aspiration of trichloroethylene have been weighed against the dangers of ingestion of another poison, this was not the case in the cases examined in this survey.

Another significant omission in many MSDS was the Australian exposure standard for trichloroethylene, which should be listed in MSDS for mixtures as well as trichloroethylene. Listing of overseas exposure standards is allowed under the MSDS Code only where an Australian standard does not exist. A number of MSDS listed the ACGIH standard, which happens to be the same value as the Australian standard, or no standard at all.

Some information on carcinogenicity was provided in six of the seven MSDS for trichloroethylene and 20 of the MSDS for products. The variation in the information provided reflects the current uncertainty regarding its carcinogenic classification.

The need for adequate ventilation and local exhaust ventilation were mentioned in most MSDS, however none of the MSDS for trichloroethylene contained recommendations on engineering controls specific to the use of trichloroethylene in vapour degreasers, such as a reference to the Australian Standard 2661:Vapour degreasing plant - design, installation and operation - safety requirements (Standards Association of Australia, 1983). Under the MSDS Code, recommendations for engineering controls in the ‘precautions for use’ section should reflect the intended uses and common applications of the chemical. Vapour degreasing is a major use of trichloroethylene, reflected in the fact that four of the six MSDS for trichloroethylene specifically mention vapour degreasing in the ‘use’ subsection, while the two others that contained a ‘use’ subsection referred to metal degreasing.

The MSDS Code requires that if special requirements for gloves exist to prevent skin exposure, they should be clearly stated. For instance, ‘protective gloves’ may not be sufficient in some cases. The assessment of MSDS for trichloroethylene and trichloroethylene-containing products indicated wide variation in the type of glove recommended for use. Types recommended included: nitrile or fluorocarbon (1); PVC (5); PVC or rubber (2); neoprene or viton (4); neoprene, nitrile or rubber (6); natural rubber (1); PVA, PE, or viton (3); PVA, PVC or viton (1); viton (2); PVA (10). Some MSDS (14) recommended the use of gloves but did not specify a type of glove that should be used, while three MSDS did not mention the use of gloves at all.

14.3.2Assessment of labels

Introduction

Labels for trichloroethylene and trichloroethylene-containing products were assessed for compliance with the requirements of the National Code of Practice for the Labelling of Workplace Substances (the Labelling Code) (National Occupational Health and Safety Commission (NOHSC), 1994) and the Standard for the Uniform Scheduling of Drugs and Poisons (the SUSDP) (Australian Health Ministers' Advisory Council, 1997).

Trichloroethylene is listed in schedule 6 of SUSDP, except when used therapeutically in which case it is listed in schedule 4. Labelling of domestic end-use products should comply with the SUSDP labelling requirements.

Substances which are covered by the SUSDP but which are packed and sold solely for industrial use should comply only with the Labelling Code. Products used industrially and domestically need to comply with both codes, ie the SUSDP along with additional labelling information in accordance with the Labelling Code.

A total of 44 labels were assessed, comprising of 8 for (>95%) trichloroethylene and 36 for trichloroethylene-containing products. Forty one labels, including the eight for trichloroethylene, were for industrial products. They were screened solely for compliance with the Labelling Code. One label was for a consumer product available to the general public and was screened only for compliance with the SUSDP. Two other products were available to the public but could be expected to be used in the workplace, so they were screened for compliance with both the SUSDP and the Labelling Code.

1) Industrial products - compliance with the Labelling Code

Hazardous substances used in the workplace should be labelled in accordance with the Labelling Code. According to the current List of Designated Hazardous Substances (National Occupational Health and Safety Commission (NOHSC), 1994) industrial substances containing 1% of trichloroethylene are hazardous. Current risk and safety phrases are:

R40 Possible risk of irreversible effects

R36 Irritating to eyes

R38 Irritating to skin

Current safety phrases are:

S23 Do not breathe gas/fumes/vapour spray

S36/37 Wear suitable protective clothing and gloves

Other requirements are: the presence of the signal word POISON; product name; details of the amount of trichloroethylene present (exact amounts or ranges); instructions on the control of leaks, spills or fires; the name and address in Australia of the supplier and a telephone number where advice can be obtained; a reference to the MSDS and first aid instructions. The ADG dangerous goods class label (6.1) and UN Number (1710) for trichloroethylene are also required under the Labelling Code. Until recently, trichloroethylene was classed as 6.1(b) and the class label was ‘Harmful - Stow Away From Foods’. In December 1994, the UN Committee of Experts on Dangerous Goods decided to eliminate this class label and replace it with the skull and cross bones diamond, with the word ‘Toxic’. The most recent edition of the ADG (Federal Office of Road Safety, 1998) has picked up these changes. Either were considered acceptable for the purposes of this assessment.

The products intended solely for industrial use all contained >1% trichloroethylene and the labels (33) were examined for compliance with the requirements listed above. The results are presented in table 34. Compliance with some other requirements of the Labelling Code, such as directions for use were not examined in this assessment.

Table 34 - Compliance with the Labelling Code

Requirement prior to this assessment	Trichloroethylene (8)	Products (33)
R40	2/8	13/33
R36	0/8	7/33
R38	0/8	7/33
S23*	8/8	28/33
S36/37	3/8	12/33
- S37 only	3/8	3/33
POISON	7/8	12/33
product name	8/8	33/33
disclosure of ingredient (trichloroethylene)	8/8	29/33
statement of strength (of trichloroethylene)	5/8	10/33
emergency instructions	2/8	7/33
supplier details	8/8	16/33
telephone number	5/8	14/33
reference to MSDS	2/8	9/33
ADG Code (6.1 or 6.1b)	5/8	n/a
UN Number (1710)	8/8	n/a
First aid statements (or equivalent phrases)
a. If poisoning occurs, contact a doctor or Poisons Information Centre.	6/8	32/33
c. If swallowed, do NOT induce vomiting. Give a glass of water.	6/8	12/33
d. Avoid giving milk or oils.	5/8	9/33
e. Avoid giving alcohol.	5/8	9/33
f. If skin contact occurs, remove contaminated clothing and wash skin thoroughly.	6/8	18/33
g. Remove from contaminated area. Apply artificial respiration if not breathing.	6/8	17/33
s. If in eyes, hold eyes open, flood with water for at least 15 minutes and see a doctor.	6/8	20/33

*equivalent phrases such as the SUSDP safety phrase ‘Avoid breathing dust (or)
vapour (or) spray mist’ were considered adequate.

n/a=not applicable

Directory: data -> assets -> word doc -> 0017
word doc -> Rail safety news issue 6 – October 2011
word doc -> Review of Multiple Chemical Sensitivity: Identifying
word doc -> Board Endorsed October 2009 amended 13-09-11 with extra units
0017 -> Rail Safety News Edition 8, December 2012
0017 ->  Commonwealth of Australia 2010
0017 -> Real-Time License Plate Localisation on fpga
0017 -> Careers network bulletin issue 6 July 16 2012
0017 -> Wiser science: Finding References inspec for Physics and Engineering
0017 -> Part A: Depth Study: The globalising world Popular culture and public policy

Download 1.35 Mb.

Share with your friends: