As per COSHH regulation 6, it is a responsibility of an employer that they make sure to not carry out any

work, if any of their employees are being exposed to any hazardous substance which poses risk to health
of employees.

Employer must assure suitable and sufficient risk assessment for the employees exposed to substances
hazardous to health, identify the steps to control those hazards as per regulation and implement these
steps to assure safety of employees.

Main objective of the risk assessment is to help employers to make decisions in terms of control
measures needed to prevent workers to be exposed from substance hazardous to their health which is
arising from their work

A suitable and sufficient risk assessment must consider all the hazardous properties of the substance,
health effect information provided by the supplier, information in the SDS, consider the level, types and
duration of exposure, amount of the substance , activities like cleaning and maintenance, any WEL
provided for the substances, etc. various factors must be considered for the adequate risk assessment.

The information provided in the section 2 of supporting document 1 may provide some valuable
information to carry out a suitable and sufficient assessment of risk for the workers who are being
exposed for vitamin C processing in the production department of Nutripex.

Properties of substance:

The information provided in section 2 of supporting document 1 regarding personal exposure

monitoring result of two individual workers. The sampling has been done for an hour and the result is 12
mg/m3 and 10 mg /m3 for worker 1 and 2 during that period. The value is not for 8 hour- TWA, which
can be converted in 8-hours TWA for further description. Vitamin C dust particle and % weight
mentioned in table 2 of section 2 which can be helpful in assessing the risk and categorizing the dust size
as per COSHH 2002 regulation

Inhalable dust: As per COSHH definition of hazardous substance which pose risk to health includes
‘’dusts’’ of any type if it is present at a concentration in air is 10 mg /m3 or greater than that for 8-hours
TWA for inhalable dust then it will be considered as substance hazardous to health as per COSHH
regulation.

Respirable Dust: As per COSHH definition any dust with concentration in air equal to or above 4 mg/m3
is considered as respirable dust and will be considered as substance hazardous to health as per COSHH.

To know the 8- hours TWA of this substance we convert the above value of table 1 of section 2 in 8-
hour- TWA then the formula will be used mentioned below,

The 8-hour TWA = C1XT1+C2XT2+CnxTn/8

Hence,
8 - hour TWA for worker1 = 12x1+0x7/8 = 1.5 mg/m3. If the same level of exposure is continued for 8
hours.

8 - hour TWA for worker 2 = 10x1+0x7/8 = 1.25 mg/m3. if the same exposure continue for 8 hours.

The value shows that the exposure is within the range and not exceeding the concentration given as per
COSHH 2002, accordingly the risk control can be considered

Risk assessment should also consider the physical, chemical, and biological properties of the substance
as in this case it is vitamin C. As PM checked the SDS of vitamin C and found that it is non-hazardous
substance. But he did not check about the air bone dust concentration if it reaches above the level
mentioned in COSHH, it should be considered as hazardous substances. Hence, all the different
properties of vitamin C and other raw material should be considered in the risk assessment.

Health effect of the substances:

Risk assessment must consider the effect of the substances on the worker’s health, which can depend
on its particle size, concentration in the atmosphere, any contamination, if there is a mixture of
substance then assessment should be based on concentration of each component present in the air for
which workers are exposed. Assessment should also include all the mixture poured in the mixing
machine and mixture of dust particle and its health effect. Health effect can also vary as per type of
exposure.

As per table -2 of section 2 of supporting document 1, the sizes of vitamin C powder mentioned with *
mark is less than 5*, 5-7* and 7-10* which indicates these size of dust can be respirable and can reach
to lungs and can cause infection.

Similarly, these dust can cause irritation, sensation to skin, eyes and also in respiratory track irritation or
infection.

Level of Exposure:

Level of exposure is an important consideration for assessment of risk for exposure. As mentioned in
supporting document 1 of section 2, the sampling is done for personal exposure for 1 hour duration

The 8-hour TWA = C1XT1+C2XT2+CnxTn/8

Hence,

8 - hour TWA for worker1 = 12x1+0x7/8 = 1.5 mg/m3. If the same level of exposure is continued for 8
hours.

8 - hour TWA for worker 2 = 10x1+0x7/8 = 1.25 mg/m3. If the exposure level is same for 8 hour,

Hence, from above calculation the concentration level of exposure is under the specified limit
mentioned in COSHH for dust to be considered as hazardous.
Type of exposure/ route of entry:

Type of exposure should also be considered for assessing the risk, type of exposure may include
inhalation, ingestion, absorption and contact with the skin. As per section 2 of supporting document 1,
most of the exposure is through inhalation as the personal monitoring is done for exposure by
inhalation. Most of the hazardous substance inters into the body through inhalation and all the
exposure limit given in the guideline is based on inhalation exposure only. There are few substances
which can penetrate intact into the skin and can be absorbed by the body and contribute to systematic
toxicity for the worker.

Duration of Exposure:

As per section 2 of supporting document 1, the duration of exposure is not mentioned but the sampling
duration is mentioned and we have converted this for 8- hour time weighted average for 1 shift. This
means the actual length of time a worker is exposed to vitamin C powder. Prolonged exposure can have
cumulative effect on the workers body.

As mentioned in the scenario, dust is easily visible throughout the production area, so worker present in
this area is exposed to the dust throughout the working hours. Furthermore, if a worker is working near
the charging point and pouring 25 kg sacks into the mixing machine for 1 hour that should also be
considered in the risk assessment.

As per the information in section 2 of supporting document 1, measurement has been taken for an hour
and the value is not in 8- hour TWA but the value as per the COSHH 2002, dust of any type if it is present
at a concentration in air is 10 mg /m3 or greater than that for 8-hours TWA for inhalable dust then it will
be considered as substance hazardous to health.

Similarly, As per COSHH definition any dust with concentration in air equal to or above 4 mg/m3 is
considered as respirable dust and will be considered as substance hazardous to health as per COSHH.

Hence, duration of exposure need to be considered to assess the risk of exposure to hazardous
substances.

Frequency of exposure:

For the assessment of risk of exposure to hazardous substances the frequency of exposure should also
be considered, it means how frequently a worker comes in contact with the hazardous substances
within a certain time period, e.g. daily, weekly, or occasionally etc.

The risk assessor must check that a worker hoe often being exposed to the hazard, as mentioned in the
scenario, in two different days 2 different workers has been used for sampling in different shifts, so
there might be shift rotation to manage the exposure, e.g. if a worker doing work at charging point for
pouring sacks into the mixing machine then he might not be assigned the same job in the next day to
control the exposure. Hence, while assessing the risk for exposure to hazards substances frequency of
exposure should also be considered.
Amount and type of the substance used:

As mentioned in the scenario, for every batch 30 sacks of 25 kg is being poured into the mixing machine
and some other raw materials are also added, this can give an idea about the quantity of substance is
being used.

The capturing efficiency of the LEV hood can provide the data how much dusts are being captured by
the LEV and fixed point measurement can provide data how much dust are present in the atmosphere,
all these data can help in preparing suitable and sufficient risk assessment.

Activities performed by the workers:

Activity performed by the worker is also an important consideration as some activity may have more
exposure level and other may have less exposure. As mentioned in the supporting document 1, section 2
table 1 that the personal exposure dust measurement for workers at mixing vessel E charging point, that
means worker performing task near the charging point and may have indulge in pouring of sacks activity,
hence, the concentration of dust at this location may be high and exposure level will be more. Similarly,
if a person doing maintenance and cleaning then for that activity exposure level can be more. So this
factor should also be considered.

Hazards arising from the activities:

There are some activities which increase the hazard level or exposure level, as mentioned in previous
point. Based on the scenario, there are some activities such as manually pouring of 25 kg sacks into the
mixing machines, flattening and stacking the empty sacks create more dusts and cleaning as well as
maintenance, etc. all such activity arising the hazard and risk of exposure. These activities creates more
dust powder therefore, level of exposure also increases.

Workplace exposure limit of the substance:

Workplace exposure limit is an important criteria to be considered for assessing the risk of exposure. As
mentioned in the scenario, the PM checked in SDS there is no exposure limit mentioned in the SDS. But
there is recommended limit as per COSHH regulation 2002 for inhalable and respirable dusts.

As per information given in the section 2 of table-2 where particle size distribution data for vitamin C is
given, this can help in establishing the workplace exposure limit as per size the dust can be considered
as respirable or inhalable, then as per COSHH 2002, concentration of 10 mg/m3 for 8-hour TWA or
above for inhalable dust can be considered as hazardous, and concentration of 4 mg/m3 for 8- hour
TWA or above for respirable dust can be considered as hazardous substance. As per this information
maximum allowable limit can be set for Nutripex with respect to recommended exposure limit in
COSHH.
Compare measured value with WEL:

During the risk assessment the measured value can be compared with the recommended value in
COSHH. In supporting document personal exposure value for 1 hour is given 12 mg/m3 and 10 mg/m3
respectively, after converting it into 8-hour TWA the value is coming 1.4 mg/m3 and 1.25 mg/m3 for
both the workers, these value can be compared with the recommended value given in the COSHH for
dust to be considered as hazardous.

Any specific characteristic of the hazardous substance:

Here in supporting document 1 section 2 table 2, the size of vitamin C powder mentioned is less than
5 ,microns, 5-7 microns and 7-10 microns with * mark, which indicates these size dusts are respirable
and can reach to the lungs.

As per the size and exposure there are few characteristics of vitamin C powder should be considered in
the risk assessment.

Vitamin C powder can acts as irritant – if the Vitamin C is in pure form it can cause irritation to the skin,
eyes as well as in respiratory system, direct contact with vitamin C powder can cause irritation
particularly an individual with sensitive skin. Some people may develop an allergic sensation when
exposed to vitamin C powder.

Ascorbic acid powder when exposed to air it can act as oxidizing agent when exposed to moisture or
metal. These characteristic of vitamin powder should be considered during the risk assessment of
exposure to hazardous substance.

Number of workers exposed:

As per the supporting document 1, table – 1 of section 2, there are 2 people selected from
measurement. Risk assessment must include all the people who are being exposed to the hazardous
substances. Some people may have less exposure and some may be exposed to higher level.

As per the scenario, sample taken near the charging point of vessel E, there might be the level of dust
concentration more due to sacks pouring and flattening process. Similarly, workers involved in the
cleaning and maintenance activity can higher exposure level.

Two different workers have been selected for sampling in different timings in two different days which
can provide real-time exposure. Two different workers selected to check the accuracy of the
measurement result.

Supplier Information and Safety data sheet:

As mentioned in the last line * supplier information about the particle size and indication that the
particle size less than 5 micron are respirable dust, therefore, supplier information and safety data sheet
is an important document to refer for the assessment of risk. As in this supporting document fine dust
particle size are marked with * which indicates, consideration should be given to that information.
Similarly, safety data sheet provide various important information about the vitamin C powder. So while
assessing the risk supplier information and recommendation as well as SDS should be referred to
provide best control measures for the hazards substance exposure to workers at Nutripex.

Health surveillance record and plan:

If there is any health surveillance program exist the data and results can help during the risk assessment
or if there is no health surveillance program then it should be considered to process. Health surveillance
of employees exposed to dust can provide valuable information for the assessment of risk.

Evaluate the existing control measures:

The information provided in the section 2 of supporting document 1 can be helpful in evaluating the
existing control measures such as LEV system, PPE or RPEs, etc. This information can help in determining
the effectiveness of current engineering control measures like ventilation system used in production
department, PPE used by the workers, hence, it helps in ensuring that the control measures are as per
regulatory compliances and working effectively.

Exposure monitoring system:

During the risk assessment for exposure to hazards substances the monitoring procedure or system
should be considered. As in section 2 of supporting document 1 indicates that the personal sampling
system has been used to monitor the dust level and exposure level.

Fixed point monitoring system can also be considered as per requirement in the risk assessment by
considering various other factors. Hence, exposure monitoring devices and system should also be
considered while assessing the risk.

Frequency of dust monitoring, location prone to dust, worker who is more exposed, all such factors
should be considered while deciding the monitoring of exposure level.

Consulting employees and the representatives:

For a suitable and sufficient risk assessment employee and his representative consultation is an
important factor to know about the risk arising from their activities, any idea or proposal to manage
these risk, taking ideas for making best provision for information and training. As in this case supporting
document 1 section 2, two workers participated in the sampling and monitoring of dust process, they
may have provided their idea and suggestion to mitigate the risk

Suitable PPE and RPEs:

Risk assessment should also consider the most suitable PPEs or RPEs as per requirement of the work
place and type of hazards and exposure.