As part of our series on COSHH (Control of Substances Harmful to Health) regulations, we’ve already explored what COSHH is and why it’s important. In our next couple of articles, we’ll look in more detail at how to comply with COSHH regulations.
There are eight steps businesses need to take in order to be compliant. We’ll go through each one in turn, looking at the first two steps in this article.
How to comply with COSHH Regulations: Step 1
The first step every business must take is to determine which substances you use that are hazardous to health and where there are potential risks of exposure to your employees.
Undertaking this risk assessment is a critical step in complying with COSHH regulations.
Which substances are hazardous to health?
There could be a number of hazardous substances in your workplace and you need to identify each of them. Hazardous substances include:
- Those substances or mixtures of substances which are classified as dangerous to health under CHIP regulations (Chemicals (Hazard Information and Packaging for Supply) Regulations 2002). Any substance recognised under this act will have a warning label on their packaging and will have an accompanying material safety data sheet. You will also find commonly-used hazardous substances on the HSE publication Approved Supply List.
- Dust, if its average concentration surpasses the levels specified in COSHH regulations.
- Substances which have workplace exposure limitations in place. You can find these substances listed in the HSE’s EH40/2005 Workplace Exposure Limits document.
- Biological agents which are directly connected with the workplace, for example, farming, sewage treatment, and healthcare.
- Biological agents such as bacteria where exposure may be a side effect of being in the workplace. For example, exposure to bacteria from an old or poorly-maintained air conditioning system.
- Any substance which poses a health risk but may not be listed under CHIP regulations. Some of the substances which fall into that category include asphyxiants, pesticides, medicines, cosmetics, and by-products of chemical processes.
You will need to identify all the substances your employees could be exposed to. Consider substances which may have been supplied to you, are produced during any internal processes (and remember that fumes and vapours are also substances), and those that are simply present in your workplace.
Consider the risks these substances pose
Once you have identified every hazardous substance, you need to think about the risks that these substances could post to your employees’ health. Think about:
- How much of the substance there is
- How your employees could be exposed to it
- Who could be exposed
- How frequently they are exposed
- How long they could be exposed for
- If the substance can be ingested or absorbed through the skin
- Risks to employees working at locations outside your workplace, such as their homes
When you are considering your workplace, risks to personal health include anyone who may be on your premises even if they aren’t employees. This includes contractors, visitors, and members of the public.
Who should conduct your risk assessment?
Legal responsibility for conducting the risk assessment lies with the employer. Other employees can carry out some or most of the work as long as they have access to the COSHH Regulations and relevant Approved Codes of Practice and have the knowledge and experience needed to make correct decisions about any identified risks and the actions and outcomes necessary. If the risks are particularly complex, you should seek the help of professionals in that field.
Your employees should also be involved in risk assessments, for example through an employee safety committee. Employee involvement is useful as they have insights into and working knowledge of the substances they use. You must also inform your employees of the results of your risk assessment.
You can use the Health & Safety Executive’s (HSE) generic risk assessment guide for supplied substances. It includes information on potential hazards, amounts that should be used, and has definitions of dust and volatility.
There’s also more guidance in the COSHH essentials section of the HSE’s website. Not only will you find information on risk assessments, but also on deciding what precautions you need to take (see step 2) and controlling exposure (step 3 of the regulations).
How to comply with COSHH Regulations: Step 2
Decide on the precautions you need to take
After you have completed your risk assessment, you will need to decide what precautions you need to take to protect your employees and others from hazardous substances especially when there are significant risks. Any risk should be removed or reduced so that it is at an acceptable level.
If you already have a system in place to control exposure, undertake a check to see how robust this system is and whether any improvements could be made.
You can use the following guidance to assess how any risks should be managed:
- The HSE’s good practice guidelines for the work environment
- The COSHH regulations essentials for supplied substances, which provide advice on control measures for common industrial operations
- Good work practices and standards for your industry, such as trade associations and Health and Safety Commission (HSC) advisory committees
- The results of monitoring workers’ exposure with workplace exposure limits (WELs)
- Advice from your chemical supplier or manufacturer’s
- The substance’s relevant material safety data sheet
- If the substance can be absorbed through the skin, check the HSE’s guide to biological monitoring in the workplace
What happens next?
If you determine that you use substances which pose health risks, you must take steps to protect your employees (and others) if they are not already in place. You should do this by going through all the steps in the COSHH regulations – there are eight in total and along with the first two being examined here, we will look at them all in detail.
If you already have measures in place which completely control any risks, you should still check that you are complying with COSHH regulations by going through these steps to ensure your controls stay effective.
Recording your risk assessment
If your business has five employees or more, you must keep a record of the results of your risk assessment. This document should be completed as soon as possible after the risk assessment has taken place and should include your decisions and control measures as well as the actions your employees and others need to take.
It should be made available to all employees, safety representatives, and health and safety inspectors as necessary. It acts as a ‘living’ document that is updated with any changes, such as new substances being introduced into the workplace or anything which becomes invalid. Each risk assessment record should include the date of your next review.
- What is COSHH?
- Why is COSHH Important?
- How to Comply with COSHH Regulations (Steps 3-4 of 8)
- How to Comply with COSHH Regulations (Steps 5-6 of 8)
- How to Comply with COSHH Regulations (Steps 7-8 of 8)
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