Posted by Robert Atkinson 2 on 12/06/2021 10:10:17:
I blme tth laweres and insurance companies
The same thing has happened with material safety data sheets. Intended to gve practical advice, most just give worst case scenearos with over the top preautions.
Yers ago I designed lab equipment and a customer asked if we could adapt a machine to use a more viscous liquid than normal and sent a sample bottle full. The "safety officer" looked at the MSDS … and said we could not test with it. I said "can I use baby oil?" and they said "of course, why not?" I didn't tell them it's the same thing in case they changed their mind!
Robert G8RPI.
I blame the idiots who cause accidents!
Quite right though, "Safety Officers" can be a problem, as is anyone who doesn't do his job properly.
MSDS, and most other H&S stuff is Guidance. Mostly all the law requires is reasonable precautions. A Competent Person is supposed to do a Risk Assessment and establish what, if any, mitigations are needed.
"Safety Officers" have to supervise a wide variety of different activities and specialisms and can't be "Competent Persons" in all of them. They're not supposed to be evaluating individual MSDSs, rather they're supposed to confirm the Competent Person has done his job, which includes reading MSDS and formally deciding what to do about their advice. Plus evaluating any other risks.
Unfortunately evidence is often paperwork, and everybody hates bureaucracy! It's common for CPs to bodge the paper evidence, often because they already know the answer, but also for less creditable reasons. Not good enough! Safety Officers should reject CPs who can't produce evidence.
Waving an MSDS under the SO's nose, claiming the answer is 'common sense', or appealing to ones 50 years experience aren't evidence risk has been considered. It's impossible for the SO to tell the difference between someone whose 'common-sense' is based on solid experience and best-practice, and an overconfident lazy ignorant jackass who doesn't really know what he's doing. Inexperienced well-qualified brainiacs straight from University can be Jackasses, and so can the guy who's done the same job for 40 years, has bad-habits galore, and is completely out-of-date. And normally Competent Persons often become temporary Jackasses due to illness, over-work, or a multitude of other life distractions.
So "Safety Officers" should look for written statements from 'Competent Persons' listing all the risks identified, and what the 'Competent Person' has done to assess and mitigate them. A CP would identify all relevant MSDS, and explain how to manage the risks presented within the context of the job in hand. That varies: Baby Oil in small quantities is different from Baby Oil in large quantities, and Nitroglycerin is something else again! Managing risk ranges from 'Do Nothing', to 'Build protected Installation in open country, wear chemical protective suits, refill tanks with fire brigade in attendance, daily health checks, and agree local-area evacuation plan with the authorities'.
Sadly "Safety Officers" have human faults too. They also can be Jackasses! A few imagine they know more about the job than the CP, don't understand or exceed their remit, and I've met one who was drunk with power, I thought mentally ill! I've seen good Safety Cases on a single sheet of A4 and one than filled a 6×4' cupboard. The worst I've seen was a few hundred pages copied from a completely different project altered crudely with Find and Replace. Not good to find a project has been asserted 'safe' when the evidence lists inappropriate test equipment, inapplicable procedures, irrelevant checks, and non-existent personnel! Almost good enough to fool the Safety Officer, but not another 'Competent Person'. He had suspected enough to ask for expert help though!
We live in an imperfect world…
Dave
Edited By SillyOldDuffer on 12/06/2021 12:08:45