In brief
The control banding approach estimates chemical risk without measurement results using four pieces of information: the hazard statements in the safety data sheet, the quantity used, volatility or dustiness, and the method of use. The result is a control approach ranging from general ventilation to specialist advice. The method does not replace measurement; it makes it easier to decide which chemical to measure first and which measure to take immediately.
What is taken into account in a chemical risk assessment?
In a business doing plastics, paint, rubber or metal plating, dozens of chemicals are used, and having workplace measurements made for all of them at once is neither practical nor necessary. A chemical risk assessment starts by finding which of these chemicals really pose a risk.
Art. 6 of the Regulation on Health and Safety Measures in Work with Chemical Substances requires the following in particular to be taken into account in the risk assessment:
- The health and safety hazards of the chemical,
- The Turkish-language safety data sheet (SDS) obtained from the supplier,
- The type, level and duration of exposure as determined by an authorised laboratory,
- The quantity of the chemical, the conditions of use and the frequency of use,
- Occupational exposure limit values and biological limit values,
- The effect of measures taken or to be taken,
- The results of previous health surveillance, if any,
- Where there is more than one chemical, their interactions,
- Non-routine work such as maintenance, repair, installation and commissioning.
The fourth item on the list is the basis of the control banding approach that is the subject of this article: when hazard, quantity and method of use are assessed together, a reasonable estimate of the magnitude of exposure can be made even before measurement. For the Regulation's general obligations and documentation, see our article on the chemical substances regulation.
What is the control banding method?
Control banding is a qualitative method that sorts chemicals and conditions of use into broad classes and assigns a control approach to each combination. The HSE's COSHH Essentials tool in the UK, the ILO's International Chemical Control Toolkit and BAuA's EMKG approach in Germany work on this logic. The common structure is based on four inputs:
| Input | Where does it come from? | Classes |
|---|---|---|
| Hazard group | H statements in SDS Section 2 | A (lowest) – E (highest) |
| Quantity | Quantity used at one time or per day | Small (grams, millilitres), medium (kilograms, litres), large (tonnes, cubic metres) |
| Tendency to become airborne | Boiling point for liquids, dustiness for solids | Low, medium, high |
| Method of use | Observation on site | Closed system, partly open, open or spraying |
The result is one of four control approaches:
- General ventilation and good working practice,
- Engineering control: extraction at source (local exhaust ventilation),
- Containment: closed system, booth, glovebox,
- Specialist advice: measurement, detailed assessment and special measures.
Step 1: Determine the hazard group from the SDS
The H statements in Section 2 of the SDS determine the chemical's hazard group. The table below is a simplified example illustrating the approach; use the full mapping table of the tool you are using.
| Group | Example H statements | Meaning |
|---|---|---|
| A | H315, H319 | Skin and eye irritation |
| B | H302, H332 | Harmful if swallowed or inhaled |
| C | H314, H317, H331, H335 | Corrosive, skin sensitiser, toxic if inhaled, respiratory tract irritation |
| D | H330, H351, H361 | Fatal if inhaled, suspected of causing cancer or damaging fertility |
| E | H334, H340, H350 | Respiratory sensitiser, mutagen, carcinogen |
We explained how to read an SDS in our article on how to read a safety data sheet. For mixtures, the classification in the mixture's SDS is used; the H statement in the highest group is decisive.
Step 2: Estimating chemical exposure
Exposure potential is estimated by reading quantity and tendency to become airborne together; the method of use moves this estimate up or down by one level.
- Volatility of liquids: For liquids used at room temperature, a boiling point above 150 °C is considered low, between 50 and 150 °C medium, and below 50 °C high. If the liquid is used heated, volatility increases.
- Dustiness of solids: Solids that do not release dust, such as pellets and flakes, are considered low, granular powders that settle quickly medium, and fine powders that stay suspended in the air high.
- Method of use: Spraying, mixing in an open container and wiping with a cloth increase exposure; closed transfer and dosing reduce it.
- Duration and frequency: Short jobs of a few minutes a day and jobs lasting the whole shift are not assessed in the same way.
An example simplified matrix (for illustrating the approach only; the tables of published tools are more detailed):
| Hazard group | Low potential | Medium potential | High potential |
|---|---|---|---|
| A | 1 | 1 | 2 |
| B | 1 | 2 | 2 |
| C | 2 | 3 | 3 |
| D | 3 | 3 | 4 |
| E | 4 | 4 | 4 |
Chemicals in group E require specialist assessment and measurement, whatever the quantity and method of use.
Chemical risk analysis example: a plastics processing plant
The result of the approach for four uses at a plastics processing plant:
| Use | Hazard | Quantity and release | Method of use | Control approach |
|---|---|---|---|---|
| Wiping the mould surface with an acetone-soaked cloth | H319, H336 → A | 1–2 litres per day (medium); boiling point 56 °C (medium volatility) | Open, short duration | 1: General ventilation, closed containers, used cloths collected in a lidded bin; flammability assessed separately |
| Feeding calcium carbonate filler on the compounding line | Not classified → A | Tonnes per day (large); fine powder (high dustiness) | Open emptying from bags | 2: Local exhaust ventilation at the feed opening, bag emptying station |
| Thinner containing toluene in the printing section | H361d, H373 → D | A few litres per day (medium); boiling point 111 °C (medium) | Mixing in an open container | 3: Closed mixing and dosing, substitution where possible; measurement plan |
| Isocyanate (MDI) in polyurethane foam | H334, H317, H351 → E | Medium | Mixing and pouring into the mould | 4: Specialist advice, closed system, measurement, health surveillance for respiratory sensitisation |
In this example, the real gain is the prioritisation: the measurement and investment budget goes first to isocyanate and thinner use; simple measures that can be applied immediately are identified for acetone and filler. This work cannot start without listing the chemicals; for the inventory, see our article on preparing a chemical inventory.
Is chemical measurement needed?
Control banding does not replace measurement. Article 7(h) of the Regulation requires the employer to ensure regular measurement and analysis of chemical substances that may pose a risk to workers' health, to repeat measurement when conditions that may affect exposure change, and to compare the results with occupational exposure limit values. Control banding supports this obligation as follows:
- Measurement priority: Chemicals falling into approaches 3 and 4, and chemicals with limit values, are moved up the measurement plan.
- Measurement point: The estimate shows at which station and during which operation measurement should be made.
- Verifying the measure: A measurement made after local exhaust ventilation has been installed shows whether the measure is effective.
- Reasoned record: For low-hazard chemicals falling into approach 1 and having no limit value, the reason for not measuring is written into the risk assessment.
Measurements are carried out by laboratories authorised under the Regulation on Occupational Hygiene Measurements, Tests and Analyses, to which the Regulation refers. We plan measurements with authorised laboratories and health institutions and enter the results into the risk assessment. We explained in which workplaces measurement comes to the fore in our article on workplaces requiring workplace measurements.
Common mistakes
- Looking only at the SDS and not at the method of use: The same product poses a low risk in closed dosing and a high risk when sprayed.
- Skipping non-routine work: Tank cleaning, filter changes and breakdown response can create much higher exposure than normal production.
- Reducing a mixture to a single component: The classification and the component list in the mixture's SDS should be read together.
- Not turning the result into measures: If the band result is written down without setting a measure, owner and date, the assessment stays on paper.
- Forgetting the skin route: For chemicals carrying statements such as H311, H314 and H317, glove selection and skin contact must be assessed separately.
We address chemical risks, incorporated into your business's general risk assessment, in our risk assessment service. For sector-specific risks, also see our chemicals and plastics page.
Frequently Asked Questions
Is the control banding method legally accepted?
The Regulation on Risk Assessment does not mandate a specific method; it allows methods chosen according to national or international standards and requires the method to be stated in the document. Within this framework, control banding can be used for chemical risks; however, it does not remove the measurement obligation in the Chemical Substances Regulation.
If the control banding result is low, do we not need to measure?
For low-hazard chemicals used in small quantities and in closed systems, the measurement priority is low; however, this decision and its rationale must be written into the risk assessment. For chemicals that have a limit value and may pose a risk, measurement is planned.
What information is needed to estimate chemical exposure?
The H statements in the SDS, the quantity used, the boiling point for liquids or dustiness for solids, and the method and duration of use. This information is collected through the inventory and site observation.
When is the chemical risk assessment renewed?
At the renewal interval set by the hazard class, and when the substance, equipment or production method used changes, when measurement and health surveillance results require it, or when the limit value legislation changes.
A risk assessment that identifies and scores hazards on site, links each measure to an owner and a date, and has a clear renewal schedule.
Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.