The Risk Assessment
end-point of chemical supply legislation, taking into account hazard data, manufacturing techniques, use patterns, handling
and finally disposal. The Safety Data Sheet (SDS) is effectively a crude Risk Assessment in that the author
must take into account all relevant factors and conclude with recommendations for use, handling an disposal that minimise
risk.
For the supply of new and existing substances under Directive 67/548/EEC (as amended)
and under proposals for REACH, a formal risk assessment is a key part of the regulatory process.
Training work undertaken
by Denehurst takes a single approach to Risk Assessment whether for regulatory work or for SDS preparation; that it is necessary:
·
to understand the relevance and relationship between types of hazard
·
to consider exposure scenarios during the life cycle of the substance
·
to understand the principles of risk reduction
During training programme,
this basic level of risk assessment can either take the form of an hour or so pre-amble to set the scene for SDS writing or
for consumer safety, or it can be extended to cover detail expected for those preparing Risk Assessments for regulatory submission.
Either way, the approach is to stress the importance of looking at the ‘big picture’ of all data and exposure
sources.
In addition to the theoretical
concepts of Risk Assessment, the use of models such as EUSES and EASE need to be considered. These should
not be used without an understanding of the theories of risk assessment as they can give misleading conclusions in the hands
of the un-skilled risk Assessor. If used correctly, EUSES can prove to be a powerful tool in not only identifying
areas of highest risk, but also in modelling where effort can be focussed to reduced exposure in key areas to made a big difference
in the final assessment.
A full-day programme for Risk Assessment training has been developed that can be adapted to suit to those with existing
skills or those starting at a basic level. An example of such a programme is given below:
Outline Training Course - Risk Assessment for Chemical Supply
Welcome, introductions (10 mins)
What do we want out of this course?
Establishment of knowledge base (30 mins)
Recap of basic principles:
Legislative framework
Environmental and health effects
Considering risk (and not hazard)
Atmospheric, aquatic and terrestrial compartments
Workplace and general public exposure
Risk assessment – basics
(30 mins)
Basic
risk assessment and understanding risk
Background to EU methods / Technical Guidance Document
PEC and PNEC
Gathering data for risk assessment (expected use patterns etc)
How to prepare a simple risk assessment (default parameters)
Exposure assessments (30 mins)
Environmental exposure
Work exposure
Exposure to general public
Interpretation of data – environmental and health effects (40 mins)
Quality of supplier safety data sheets
What to look for in test reports
Looking for anomalies in data
Difficult materials and non-standard tests
Computer
models, read across and educated guessing (SAR)
EUSES introduction
(2 hours)
Practical
demonstration
Exercises using
increasing levels of sophistication in changing parameters
‘Advanced’
testing; further testing options (30 mins)
Why do more testing?
Environmental fate and the effects on treatment plants
Persistence and bioconcentration
Long-term health effects
Secondary and tertiary exposure