COSHH Assessment — Clarke Motor Oil SAE 10W/30¶
Confirmed against the container label — the supplier sheet is the one that is wrong
The bottle was photographed on 24/09/2026 and reads PART NO. 3050845. That is the exact article covered by Clarke International's own safety data sheet, version 4 of 11 October 2024, so there is no question of a different grade.
The label carries H315 and H411. In its own words: "H315 Skin irritant" and "Toxic to aquatic life with long lasting effects", with the exclamation-mark and environment pictograms. That is exactly the classification this assessment records.
Clarke's safety data sheet for the same article says the product is not classified. The sheet and the label are Clarke's own documents and they contradict each other.
The label governs and this assessment is unchanged. It is what the operative sees, it is the more onerous of the two, and it is the position AMWS is entitled to work to. The assessment is complete on its substance and awaits sign-off to come off draft.
Assessment finalised and signed 29/09/2026. The contradiction is still to be raised with Clarke International so the supplier sheet is corrected at source — owner Sean Ashton, target 31/10/2026.
Classification corrected 26/09/2026 to the container label
Revision 1 of this assessment recorded the product as not classified as hazardous in the supplied form, on the general basis that most fresh mineral engine oils are unclassified. The container in the cabinet was read differently: the Clarke label was recorded on 24/09/2026 as carrying H315 and H411 with two GHS pictograms.
Revision 1 set the PPE and spill controls for an unclassified product. The classification, pictograms, precautionary statements and environmental controls below were corrected on 26/09/2026 to what the label was recorded as saying, which is the more onerous of the two positions.
The supplier's own sheet was read on 27/09/2026 and records the product as not classified. The callout above sets out the disagreement and how it is settled.
| Ref | Revision | Issue Date | Next Review | Assessor | Approved By |
|---|---|---|---|---|---|
| COSHH_25 | 2 | 25 September 2026 | 1 June 2027 | Sean Ashton | Aaron Mason, Director |
Key references
COSHH_25 on the COSHH Register (APP_09)
Clarke International sheet for API SF 10W-30 Motor Oil, article 3050845, version 4 of 11/10/2024, filed 27/09/2026. It records the product as not classified, against H315 and H411 printed on Clarke's own label for the same article. The classification in this assessment is taken from the label.
1. Product identification¶
| Product name | Clarke Motor Oil SAE 10W/30, API SF, 1 litre — article 3050845 |
| Part number | 3050845 |
| Supplier | Clarke International, Hemnall Street, Epping, Essex CM16 4LG |
| Pack | 1 litre |
| Specification | API SF. For 4-stroke petrol engines — pressure washers, generators, mowers and yard plant |
| Active ingredients / CAS | Severely hydrotreated / solvent-refined mineral base oil plus proprietary performance additives CAS: 64742-54-7 / 64742-65-0 (typical base stocks) |
| Physical form | Liquid |
| Appearance / odour | Amber viscous oil, characteristic mild odour |
| Use | Engine oil top-up and oil changes on the AMWS fleet and yard plant |
| Location | Jason May's COSHH cabinet, AMWS yard |
2. Hazard classification¶
Overall classification: Classified under GB CLP. Skin Irrit. 2 and Aquatic Chronic 2 per the container label. Used engine oil is more hazardous still — it accumulates polycyclic aromatic hydrocarbons and is treated as a skin carcinogen, so every drain-down is the hazardous operation even though the classification below is for the fresh product.
Signal word: Warning
Hazard statements (H-codes)¶
| Code | Statement |
|---|---|
| H315 | Causes skin irritation. |
| H411 | Toxic to aquatic life with long lasting effects. |
Precautionary statements (key P-codes)¶
| Code | Statement |
|---|---|
| P264 | Wash hands thoroughly after handling. |
| P273 | Avoid release to the environment. |
| P280 | Wear protective gloves and eye protection. |
| P302+P352 | IF ON SKIN: wash with plenty of water. |
| P332+P313 | If skin irritation occurs: get medical advice. |
| P362 | Take off contaminated clothing and wash it before reuse. |
| P391 | Collect spillage. |
| P501 | Dispose of contents and container to an authorised waste-oil contractor. |
GHS pictograms¶
| Oxidising | Explosive | Flammable | Toxic | Harmful | Corrosive | Human Health | Dangerous for environment | Gas under pressure |
|---|---|---|---|---|---|---|---|---|
| ☐ | ☐ | ☐ | ☐ | ☑ | ☐ | ☐ | ☑ | ☐ |
3. Persons at risk¶
| Staff | Public | Visitors | Contractor | Workers | Young / Pregnant |
|---|---|---|---|---|---|
| ☑ | ☐ | ☐ | ☑ | ☑ | ☐ |
4. Routes of exposure¶
- Inhalation: Negligible at ambient temperature. Oil mist only where sprayed or hot
- Skin contact: The main route. Repeated or prolonged contact causes dermatitis. Used oil is a skin carcinogen — treat every drain-down as the hazardous operation
- Eye contact: Transient irritation on splash
- Ingestion: Unlikely in normal use
5. Workplace exposure limits (HSE EH40/2005)¶
| Component | STD | 8-hr TWA | 15-min STEL | Notes |
|---|---|---|---|---|
| Oil mist, mineral | — | 5 mg/m³ | 10 mg/m³ | EH40/2005. Applies to mist generated by spraying, splashing or hot work |
6. Frequency and duration of exposure¶
COSHH Regulation 6 requires the assessment to consider the amount, level and duration of exposure.
| Amount used | Times per day | Duration per use |
|---|---|---|
| Medium — litres | 1–5 times per day | 6–30 minutes |
7. Control measures — hierarchy of controls¶
Elimination / substitution
- Not practicable — the oil grade is specified by the engine manufacturer
Engineering controls
- Drain pan and funnel for every oil change
- Bunded storage in the COSHH cabinet
- Spill kit within reach of the working position
Administrative controls
- No hand-washing in oil or solvent — soap and water only
- Skin checks form part of the health-surveillance conversation under SOP 8.7
- Used oil never decanted into unmarked containers
Personal protective equipment
- Nitrile gloves — the primary control
- Safety glasses when decanting or draining
- Overalls; change out of oil-soaked clothing rather than working on
8. Storage and handling¶
| Temperature | Ambient |
| Location | Yard COSHH cabinet, bunded |
| Avoid | Strong oxidisers; contact with food and drink |
| Container | Original container, closed, clearly labelled |
9. Emergency procedures¶
First aid¶
| Route | Action |
|---|---|
| Eyes | Rinse with clean water for several minutes, eyelids held open. Get medical advice if irritation persists. |
| Skin | Wash with soap and water. Do not use solvent or abrasive hand cleaner. Remove contaminated clothing and wash it before reuse. The product is a skin irritant — get medical advice if irritation continues after washing. |
| Inhalation | Not applicable in normal use. Move to fresh air if mist has been generated. |
| Ingestion | Rinse mouth. Do not induce vomiting. Seek medical advice. |
Spillage¶
Absorb with proprietary oil absorbent or sand. Protect the nearest drain first. The product is H411 — toxic to aquatic life with long lasting effects, so any release reaching the yard gully, a drain or a watercourse is a reportable environmental incident: report on FORM_ENV_01 and notify the Environment Agency incident hotline 0800 80 70 60. Dispose of the absorbent as hazardous waste. See SOP 9.3.
Fire prevention¶
Combustible when heated. Foam, dry powder or CO₂. Do not use a water jet.
Emergency contacts¶
- Emergency services: 999
- NHS non-emergency: 111
- AMWS supervisor: Jason May
- HSQE support: Sean Ashton (Onyx Operations)
- Environment Agency incident hotline: 0800 80 70 60 — if product reaches a drain, ditch or watercourse
10. Waste disposal¶
Fresh oil: EWC 13 02 05. Used oil: hazardous waste, EWC 13 02 05** — authorised waste-oil contractor only, with a consignment note retained.
11. Risk rating¶
| Before controls | With controls |
|---|---|
| Moderate | Low |
Risk rating methodology: Severity × Likelihood = Risk (S × L = R). See POL_HSQE_21 — Risk Assessment for the full scoring matrix.
12. Training requirements¶
- Safe handling and decanting
- Dermatitis awareness and skin checks
- Spill response — SOP 9.3
- Used-oil handling and the carcinogen risk
13. Assessment outcome¶
| Outcome | |
|---|---|
| Safe to proceed with existing control measures | ☐ |
| Safe to proceed with additional actions | ☑ |
| Unsafe — do not proceed | ☐ |
14. Monitoring and review¶
- Weekly COSHH cabinet inspection by the Site Supervisor
- Annual COSHH review, or sooner on change of product, supplier or task
- Review immediately if the SDS obtained differs from the label classification recorded above
15. References¶
- POL_HSQE_08 — COSHH Policy
- POL_HSQE_19 — Personal Protective Equipment (PPE) Policy
- SOP 8.5 — Hazardous Substances (COSHH)
- SOP 8.7 — Health Surveillance
- APP_09 — COSHH Assessments Log
- HSE COSHH Regulations 2002 (SI 2002/2677, as amended)
- HSE EH40/2005 Workplace Exposure Limits
- CLP Regulation (EC) No 1272/2008 (as retained in UK law)
16. Signatures¶
| Name | Signature | Date | |
|---|---|---|---|
| Assessor | Sean Ashton, HSQE Consultant | 26/09/2026 | |
| Supervisor | Jason May, Site Supervisor | ||
| Approved by | Aaron Mason, Director | Signed by S. Ashton for and on behalf of the Director, under delegated authority | 29/09/2026 |
| User acknowledgement |
This assessment must be reviewed annually or when circumstances change — whichever is sooner.
Method statements¶
No field method statement calls up this substance.
It is a fleet, plant-maintenance, office or welfare item rather than something used in carrying out a field task. The method statements held on the Van Packs site cover field operations; substances used on the vehicles, in the yard workshop or in the office are controlled by this assessment and by SOP 8.5 alone.
Related documents¶
This assessment is one of thirty held under APP_09. The substance-specific controls are above; the system that maintains them is below.
- POL_HSQE_08 Control of Substances Hazardous to Health (COSHH)
- POL_HSQE_19 Personal Protective Equipment (PPE)
- SOP 8.5 Hazardous Substances (COSHH)
- SOP 8.4 Personal Protective Equipment
- SOP 8.7 Health Surveillance
- SOP 9.5 Hazardous Management of Waste
- APP_09 COSHH Assessments Register
- APP_10 Legal & Compliance Requirements Register with Evaluation
- RA_HO_15 PPE Management
Standard applied: COSHH Regulations 2002 (undated reference), with workplace exposure limits taken from HSE EH40/2005 and hazard classification from GB CLP. Referenced undated so a new edition does not force a re-issue of every assessment.