What HSE expects

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What HSE expects

• Andrew Lake
• Manufacturing Sector, HSE

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Intend to cover

• HSE health agenda
• How nickel salts treated in past
• HS Implications of reclassification
• What standards Inspectors will expect

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Background

• Revitalising health and safety -20 reduction in
  work-related ill health. Particular emphasis on
• asthmagens
• carcinogens
• skin disease
• Fit for Work, Fit for Life, Fit for Tomorrow 3
  reduction in ill health caused by chemicals
  between 2004/5 and 2007/8.

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Why Electroplating?

• Historically poor standards
• Particularly hazardous chemicals
• Nickel sulphate nickel chloride
• human carcinogens
• asthmagens
• allergic irritant contact dermatitis

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1991
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1997
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1996
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Monitoring Info Sheet 1993/8
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Health Surveillance 1993/8
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Whats new?

• Nickel Sulphate Chloride classification (from
  Oct 2006?)
• R38 irritating to skin
• R42 - may cause sensitisation by inhalation
• R43 may cause sensitisation by skin contact
• R49 may cause cancer by inhalation
• R61 may cause harm to the unborn child

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• R49 May cause cancer by inhalation
• R42 May cause sensitisation by inhalation (ie
  may cause asthma)
• R43 May cause sensitisation by skin contact (ie
  dermatitis)
• R61 May cause harm to the unborn child
• R48/23 Toxicdanger of serious damage to health
  by prolonged exposure through inhalation
• R68 Possible risk of irreversible effects

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Déjà vu?

• April 2005 Chromic acid at National Motorcycle
  Museum
• 80 have an interest in both chromium and nickel.

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Requirements for soluble nickel salts similar to
hexavalent chromium

1. Carcinogens ACOP applies
2. Both asthmagens and skin sensitisers

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Requirements for soluble nickel salts different
to hexavalent chromium

1. Dont need fortnightly monitoring above bath
2. Nickel salts only carcinogenic if breathable (ie
   aerosol or dust)

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Four new chromium documents
Applicable to nickel?

1. Prevention or control of exposure to chromic
   acid mist
2. Monitoring for electrolytic hexavalent
   processes
3. Health Surveillance for hexavalent chromium
   compounds
4. Prevention or control of exposure to chromic
   acid

• But not surfactant

? But not fortnightly
? But not chrome ulcers
? Largely
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Prevention of nickel salt exposure

• Substitution by safer substances unlikely
• If no inhalation risk Carcinogens ACOP doesnt
  apply!
• Workplace Exposure Limit (WEL) 0.1mgm-3
• Legal requirement to reduce exposure below WEL as
  far a reasonably practicable.
• Cannot achieve 0.1mgm-3 above bath with air
  agitation and conventional LEV!

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Prevention of nickel salt exposure

• Replace air agitation with eductors

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Use of eductors
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Control of nickel salt exposure plating solution

• Available controls
• Local exhaust ventilation (LEV)freeboard
• Prevention is better than control ( nickel
  plating mist causes lung cancer) so eductors are
  best option

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LEV freeboard

• Lip extraction freeboard (distance from lip to
  electrolyte) are linked
• Reduced freeboard reduces ability to capture.
  Should aim for gt300mm
• Set-up mark measure maintain
• Consider visual indicators, alarms, automatic
  dosing

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LEV freeboard

• LEV should be installed by ventilation engineer
  (VE)
• Thorough examination test by VE at least once
  every 14 months
• Consider push/pull system necessary if air
  agitation is used but difficult to set up
  maintain.

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Setting up controls

• Must control under worst-case conditions eg
  largest surface area, highest current density,
  longest plating time
• Carry out air sampling
• Measure exhaust velocity, freeboard

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Checking controls LEV

• Measure using anemometer at set points along lip
  (check vs installed level)
• Measure initially daily before start of process
• Can extend period up to max once per week
• Log book kept. If level drops gt15 suspend
  operation and determine problem
• Smoke tests are probably best indicator of
  effectiveness

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Most effective way of checking extraction
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Smoke tests show recirculation of air in
downdraft booth
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Some sources of smoke/fog machines
Cybermarket Search for mini smoke machine
(Reference- 160.428) http//www.cybermarket.co.uk
/index.html
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Maplin Search for Smoke (Vivid V-1 fogger
Reference L55BJ) http//www.maplin.co.uk/
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Blue Aran Antari Search for Fog machine F80Z
700W http//www.bluearan.co.uk/
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Periods on inactivity

• No need to carry out checks if process not used.
  
• But if inactive period exceeds normal checking
  period then must carry out checks BEFORE
  restarting process

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Checking controls wetting agent

• Not really COSHH control measure more quality
  of plating (unlike PFOS for chromic acid).
• Surface tension must not be allowed to exceed
  level set by supplier
• Measure initially once every 4 hours till process
  characteristics understood
• Log book kept showing additions and surface
  tension plot

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Checking controls wetting agent

• Surface tension measured by surface tension meter
  (eg du Nouy ring)

Dont use stalagmometer
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Chroffles

• Not considered COSHH control measure but useful
  for reducing heat loss

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Control of nickel salt exposure other sources

• Need to consider cleaning maintenance

Consider spray rinsing or other methods to reduce
build-up
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Control of nickel salt exposure other sources
Need to minimize/eliminate dust aerosol Use of
appropriate respiratory protective equipment
during cleaning operations
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Control of nickel salt exposure other sources

• Pumping solutions ensure end of discharge pipe
  restrained and below surface of liquid
• Raw materials pellets or concentrated liquid
  rather than powder

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Control of nickel salts - Inspectors

• Check what control measures present if no
  eductors, why not?
• Check anemometer as appropriate
• Check freeboard set and maintained
• Ensure checks carried out appropriately
• Check thorough examination and test 14 monthly
• How are they control other sources of exposure
• Prohibition Notice if controls absent/not
  working. IN if inadequate or no proper
  assessment of exposure.

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Control of nickel salts - Inspectors

• Has operator considered cleaning pumping
  operations and put in appropriate controls?
• How are raw materials supplied made up
• L (or IN if other matters) if inadequate. PN if
  excessive exposure eg jetting/steam cleaning
  without PPE

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Monitoring

• Separate to checks on controls
• Required for the most harmful substances and
  processes
• Would be required for nickel plating unless can
  demonstrate adequate controls by another method
  of evaluation.

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Air sampling

• Should be to MDHS 42/2

Appropriate for initial assessment and periodic
checks More important to check control measures
are working
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Air Sampling Summary

• Hopefully you should find nothing because control
  measures so good
• Aiming for lt 0.1mgm-3 above bath

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Air Sampling - Inspectors

• Ask what method is used
• Ask to see person trained to carry out sampling
• Ask to see log book (if representative of
  personal exposure records kept 40yrs, otherwise
  5yrs)
• If inadequate/absent Improvement Notice (IN)

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Monitoring other options

• Air sampling fine if confident that other routes
  of exposure are controlled
• Most plating shops will not have facilities on
  site to do testing
• If other routes significant may be more useful
  (and cheaper _at_42 pp?) to carry out Biological
  Monitoring
• Better to demonstrate adequate controls by
  another method of evaluation eg LEV/freeboard
  smoke tests

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Health Surveillance- Inspectors

• Check evidence of
• appointment of responsible person
• pre-placement ongoing asthma checks
• examinations of hands forearms
• Check records are being kept (40 yrs)
• This is not a new requirement! So If
  inadequate/absent Improvement Notice (IN) and
  consider prosecution

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Storage handling

• Closed, clearly labelled containers
• Establish emergency procedures in event of
  spillage
• Consider secondary containment (environmental),
  drainage PPE
• BSTSAs Health and Safety Guide for Surface
  Treatment Tank Side Personnel

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Safe handling use

• ¼ all accidents (36 fatals) are contact with
  hazardous substances
• Unsafe transfer (eg buckets),
• Splashing while making additions
• Unsafe systems for dis/connecting pumps

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Carcinogens ACOP

1. Totally enclose process/handling systems unless
   not rp
2. Prohibit eating, drinking, smoking in areas that
   may be contaminated
3. Clean floors, walls, other surfaces at regular
   intervals and whenever necessary

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Carcinogens ACOP

• Designate areas and installations that may be
  contaminated by inhalable nickel salts. Exclude
  non-essential personnel. Display warning
  signs.

5. Store, handle, dispose of safely, use
closed clearly labelled containers.
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Contamination

• Note may be contaminated
• How do you know? Visual splashing? Is mess room
  uncontaminated?
• Nickel swab check may be an answer (gross
  contamination easy to spot!).

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PPE min standards

• Washable overalls (or disposables of a suitably
  chemical resistant material that provide a
  similar level of protection)
• safety boots or Wellingtons as appropriate
• additionally for manual line
• impervious apron
• suitable gloves/gauntlets and
• a full-face visor.

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PPE

• Is useless if wearing is not enforced
• Overalls laundered once/wk changed immediately
  if contaminated
• Lockable locker for each worker
• PPE used as a last resort It is difficult to
  justify manual un/loading of jigs into baths
  hoists are likely to be obligatory

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Emergency procedures

• Guidance lays out standards for drench showers,
  eye wash stations etc. will be necessary if
  chromium plating probably nickel-strike
  (acidity)
• Employees should be instructed in use

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Nickel salts - Inspectors

• How are nickel salts stored and transferred
  closed labelled?
• Check demarcation signage. Do they know where
  contamination is likely?
• Is manual loading of tanks taking place? What
  justification?
• Are surfaces cleaned regularly when necessary

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Nickel salts - Inspectors

• Suitable messroom, toilets, washing facilities.
• Provision of overalls, changing lockers and
  laundering arrangements
• Provision of emergency showers
• Lack of any of the above justifies IN. Consider
  prosecution for serious omissions.

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Nickel plating conclusions

• Reclassification will happen and will affect the
  way you work
• There is no ban on use
• Inspectors will enforce the law on safe use
• Nickel solutions not perceived to be as hazardous
  as chromic acid may lead to false sense of
  security
• For chromium platers most of the precautions
  should be familiar.

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Nickel plating - conclusions

• Looking to establish industry best practice
• Chromium guidance agreed by industry HSE much
  applicable to nickel
• Sets out standards you will be judged by
• There should be no surprises when you are visited
  by an Inspector

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Biggest cause of allergic contact dermatitis is
nickel

• Much of this results from body piercing using
  cheap jewellery!

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Any Questions?