COSHH regulations
At Aegis we have had experience dealing with hazardous substances, which have provided a good grounding for understanding what a hazardous substance is and what harm they can do. Within the UK we have regulations which offer employers within the UK a framework to build a management system that will allow the health risks associated with using hazardous substances to be controlled and to monitor those controls to ensure that they remain effective. Compliance with the COSHH regulations could provide numerous benefits to an employer such as lower insurance costs, less lost working time and improved employee morale, plus the priceless feeling of knowing that you are compliant and more importantly that your people are safe at work.
So what do I need to do to comply with the COSHH Regulations?
When hazardous substances are used or are being considered for use at your place of work then the COSHH regulations impose a number of duties on an employer and also require employees to cooperate with the employer by following any safety procedures and complying with any information that allows the employer to comply with the regulations. So lets drill down and have a look at the specific requirements under the regulations.
- Risk Assessment – An employer must conduct a suitable and sufficient risk assessment of the risk to health to workers from exposure and using hazardous substances. This risk assessment must take into account hazardous substances that are created through work activity, length of exposure and the requirement for any health surveillance. Emergency procedures must also be in place to suitably control leaks and spills etc. Some hazardous substances have a workplace exposure limit (WEL) which should not be exceeded. The HSE provide a specified list of substances that attract a WEL to them. Here is some further information on WEL’s for you provided by the HSE. Employers must prevent and where this is not possible, adequately control exposure to hazardous substances. Employees must make use of any controls provided for them.
What is a substance hazardous to health under COSHH?
Substances or mixtures of substances classified as dangerous to health under the Classification, Labelling and Packaging (CLP) Regulations 2015. Please see the picture below which displays hazard warning symbols. These can be identified by their warning symbol and the supplier must provide a safety data sheet (SDS) for them. An SDS contains 16 sections, each section provides information on a number subjects such as transport, storage, first aid measures, toxicity and environmental impact.
Substances with workplace exposure limits listed within the HSE publication EH40/2005 which can be downloaded free of charge from the HSE website.
Biological agents- We discussed these in our Chemical and Biological information which is available on this blog here. Bacteria and other micro organisms, if they are directed connected to work, such as agriculture, sewage treatment or if the exposure is incidental to the work activity.
Any type of dust if the average concentration levels in the air exceed the safe levels specified in COSHH.
Any other substance which creates a risk to health, but due to technical reasons may not be specifically covered by the CLP Regulations such as asphyxiates – argon, helium which do not present a hazard on their own, they can endanger life through reducing the amount of oxygen available.
Not every hazardous substance is covered by the COSHH Regulations, some substances which are hazardous such as asbestos, Lead and radioactive substances are covered by their own regulations. A good guide is to look for a hazard warning symbol on the substance container. If there is no hazard warning symbol label or the substance is a biological agent which is not directly used in the workplace such as swine flu then no COSHH assessment is required.
COSHH Risk Assessment
Hazard warning symbols – CLP.
A COSHH assessment is similar to a risk assessment but is purely focused upon hazardous substance control and prevention. The HSE suggest using the 5 step to risk assessment system with two further sub sections. So lets explore them now.
- Step 1 – Identify hazards. We are looking to identify all hazardous substances present or reasonably foreseeable to be present. Identify the quantity of the substances used and identify the hazards associated with these substances from labels, safety data sheets, HSE guidance and any other credible information sources such as industry etc. Then we need to determine who can be harmed and how that harm will potentially occur, taking into account the possible routes of entry into the body, inhalation, ingestion, absorption and injection. Note that there is a requirement to look at the substance and the activities where persons could be exposed to hazardous substances.
- Step 2 – We then need to evaluate the risks to health including the duration and frequency of exposure such as the concentration of a substance such as gas, airborne dust. Workplace Exposure Limits (WEL) must be considered at this step.
- Step 3 – Decide on precautions, what needs to be done to control exposure. All existing control measures should be evaluated for their effectiveness using monitoring records if available if none are available to decide what are the requirements for monitoring. Decide on additional controls if required, and any maintenance and supervision are required. Emergency plans should be reviewed and revised as required. Decide if any health surveillance is required, and decide on what information, instruction and training are required.
- Step 4 – Record the findings of the assessment if you have 5 or more employees. Decide upon the format of the record, what risk assessment format will you use. Then decide upon the method of storage ensuring that the record is available for employees, safety reps and regulators.
- Step 5 – Review the assessment at regular intervals or as required when you have changed a process, change to persons exposed, after an accident/ incident or incident of ill-health relating to hazardous substances or following a significant near miss.
Competency
It is vital to the success and ensuring the safety of you and your employees that the COSHH assessment is conducted by a competent person or persons for larger complex operations. Aegis can provide a competent person to conduct your COSHH assessment, please click here to make an enquiry.
COSHH Top Tips
Below we have included some generalised good practice for the control of substances hazardous to health.
When designing or operating a process or activity, try to minimise any emissions, releases and spread of substances hazardous to health.
Consider the routes of entry into the body , Inhalation, Ingestion, Absorption and Injection.
You may have to provide RPE remembering that face fitting may be required to lower the risk of exposure from dusts and bio-aerosols.
Remember that we should always control a risk to health using proportionate controls compared to the health risk.
Regular monitoring of control measures must take place and record the monitoring.
Inform and train employees on the hazards associated with hazardous substances and the control measures that are in place to prevent harm.
COSHH posters and Signage for your workplace
Using posters is a great way of communicating COSHH information to your employees, here is one which we use:
To ensure that you store COSHH items safely and in compliance with current regulations we recommend that you install a COSHH locker / cupboard at your premises, here is what we recommend and they are available in different sizes to suit your requirement:
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