Your writing should be that of a practitioner communicating with a non-practitioner client. John McGill has a bathtub refinishing business called NUTUB Ltd on the banks of the Shannon. He employs...

Your writing should be that of a practitioner communicating with a non-practitioner client.
John McGill has a bathtub refinishing business called NUTUB Ltd on the banks of the Shannon. He employs three people. He uses several chemical products in the stripping and re-enamelling of bathtubs. Sometimes he carries out “on-site” refinishing if a client is not removing the bath from the domestic bathroom, but just wants a refurbishment.
He was recently inspected by the HSA and given a Prohibition Notice due of the use of methylene chloride as a stripping agent on his premises and in the domestic environment. He has 20 working days to respond to the HSA with a reasonable OSH management system.

John has employed you to instruct him and write the necessary documents regarding the following issues:
a)    Instruct John about the conditions of a prohibition notice and why he did not receive an improvement notice from the HSA.
b)    Carry out a “Chemical Hazards” risk assessment for methylene chloride used at NUTUB Ltd, at both the premises and domestic settings (if admissible).

c)    Write a Safe Working Procedure for work carried out using methylene chloride for both factory and domestic procedures.
d)    Advise John about the regulatory Health Surveillance issues specific to the use of methylene chloride, including monitoring tests, record keeping and communications.
e)    Does John have duties under REACH? Inform him of any duties with external bodies.
f)    Describe how John should design the company tank farm to protect the nearby river.
g)    Instruct John about his hazardous waste management requirements.
Refer to the HSA website for guidance documents on statutory notices, risk assessments, health surveillance and preventative methods. (UK HSE and US NIOSH may also be helpful, but regulations not Irish)