COSHH

What is COSHH?

COSHH is the law that requires employers to control substances that are hazardous to health. You can prevent or reduce workers’ exposure to hazardous substances by:

• finding out what the health hazards are;
• deciding how to prevent harm to health (risk assessment);
• providing control measures to reduce harm to health;
• making sure they are used;
• keeping all control measures in good working order;
• providing information, instruction and training for employees and others;
• providing monitoring and health surveillance in appropriate cases;
• planning for emergencies.

Most businesses use substances, or products that are mixtures of substances. Some processes create substances. These could cause harm to employees, contractors and other people.

Sometimes substances are easily recognised as harmful. Common substances such as paint, bleach or dust from natural materials may also be harmful.

What is a ‘substance hazardous to health’?

COSHH covers chemicals, products containing chemicals, fumes, dusts, vapours, mists and gases, and biological agents (germs). If the packaging has any of the hazard symbols then it is classed as a hazardous substance.

COSHH also covers asphyxiating gases.

COSHH covers germs that cause diseases such as leptospirosis or legionnaires’ disease: and germs used in laboratories.

COSHH doesn’t cover lead, asbestos or radioactive substances because these have their own specific regulations.

I’m self-employed.  Does COSHH apply to me?

Yes.

If you have employees (you control their work), every part of COSHH applies.

If you have no employees (but you take hazardous substances to other people’s premises), all parts of COSHH regulations apply except those about monitoring and health surveillance.

What you need to do

Think about

• What do you do that involves hazardous substances?
• How can these cause harm?
• How can you reduce the risk of harm occurring?

Always try to prevent exposure at source. For example:

• Can you avoid using a hazardous substance or use a safer process – preventing exposure, eg using water-based rather than solvent-based products, applying by brush rather than spraying?
• Can you substitute it for something safer – eg swap an irritant cleaning product for something milder, or using a vacuum cleaner rather than a brush?
• Can you use a safer form, e.g. can you use a solid rather than liquid to avoid splashes or a waxy solid instead of a dry powder to avoid dust?

Check your trade press and talk to employees. At trade meetings, ask others in your industry for ideas.

If you can’t prevent exposure, you need to control it ‘adequately’ by applying the principles of good control practice.

Control is adequate when the risk of harm is ‘as low as is reasonably practicable’.

This means:

• All control measures are in good working order.
• Exposures are below the Workplace Exposure Limit, where one exists.
• Exposure to substances that cause cancer, asthma or genetic damage is reduced to as low a level as possible.

COSHH assessment: Identifying hazard and assessing risk

You are probably already aware of many risks in your trade or industry. A COSHH assessment concentrates on the hazards and risks from substances in your workplace.

Remember that hazards and risks are not limited to substances labelled as ‘hazardous’.

Steps to making a COSHH assessment:

• Walk around your workplace. Where is there potential for exposure to substances that might be hazardous to health?

Examples include processes that emit dust, fume, vapour, mist or gas; and skin contact with liquids, pastes and dusts. Substances with workplace exposure limits (WELs) are hazardous to health.

• In what way are the substances harmful to health?

Get safety data sheets, and read your trade magazines. Some substances arise from processes and have no safety data sheet. Examples include fume from welding or soldering, mist from metalworking, dust from quarrying, gases from silage. Look at the HSE web pages for your trade or industry – Your Industry.

• What jobs or tasks lead to exposure?

Note these down. Note down what control measures you already use. For these jobs, how likely is any harm to workers’ health?

• Are there any areas of concern, e.g. from the Accident Book?

Examples include burns from splashes, nausea or lightheadedness from solvents, etc

HSE has produced general guidance called 5 steps to risk assessment. You can apply this to substances hazardous to health. More detailed guidance is in the free booklet on working with substances hazardous to health.

Safety data sheets provide information on substances that are ‘dangerous for supply’. Other substances should have instructions for safe use.

By law, your supplier must give you an up to date safety data sheet for a substance that is ‘dangerous for supply’. Safety Data Sheets are often hard to understand, though this explanation might help.

Keeping a copy of the safety data sheet is not a COSHH assessment.

Substance substitution

You can prevent exposure to a hazardous substance by:

• substituting it with another substance which presents less, or no risk;
• using another process which doesn’t create a hazardous form of that substance.

For example

• substituting a powder for a liquid;
• removing the need to weigh out powders by buying it pre-packed.

There are seven steps to practical, well thought out decisions about substitution.

1. Decide whether the substance or process is a hazard. Is there a significant risk involved in storing, using or disposing of a substance?
2. Identify the alternatives.
3. Think about what could happen if you use the alternatives.
4. Compare the alternatives with each other and with the substance or process you are using at the moment.
5. Decide whether to substitute.
6. Introduce the substitute.
7. Assess how it is working.

You can speak to trade associations, others carrying out similar work, customers and suppliers for information if you are considering substitution.

Workplace exposure limits

What is exposure?

Exposure to a substance is uptake into the body. The exposure routes are:

• By breathing fume, dust, gas or mist.
• By skin contact.
• By injection into the skin.
• By swallowing.

Many thousands of substances are used at work but only about 500 substances have Workplace Exposure Limits (WELs) listed in ’EH40 workplace exposure limits’ [111KB]

How do I know if exposures are below the WEL?

You can only do this by monitoring. This means measuring the substance in the air that the worker breathes while the task is underway.

What if a hazardous substance has no exposure limit, or it is mixed in a product?

You can check whether you are using the right control measures. If you are, exposures are likely to be below the WEL. See COSHH essentials

Chemical safety data sheets

Safety data sheets provide information on chemical products that help users of those chemicals to make a risk assessment. They describe the hazards the chemical presents, and give information on handling, storage and emergency measures in case of accident.

Safety data sheet information may lead to guidance appropriate for your task.

Caution

A safety data sheet is not a risk assessment. You should use the information it contains to help make your own assessment.

As well as receiving chemicals you may supply them to others. If you do, you must pass on information (as safety data sheets) to those whom you supply.

Control measures to prevent or limit exposure to hazardous substances

What is COSHH for?

The objective of COSHH is to prevent, or to adequately control, exposure to substances hazardous to health, so as to prevent ill health.

You can do this by:

• using control equipment, eg total enclosure, partial enclosure, LEV;
• controlling procedures, eg ways of working, supervision and training to reduce exposure, maintenance, examination and testing of control measures;
• worker behaviour, making sure employees follow the control measures.

Changing how often a task is undertaken, or when, or reducing the number of employees nearby, can make an improvement to exposure control.

Control equipment

Control equipment can be general ventilation, extraction systems such as local exhaust ventilation, enclosure, or where the air cannot be cleaned, refuges and respiratory protective equipment (RPE).

Other control equipment includes spillage capture, decontamination, clean-up procedures and personal protective equipment (PPE).

Ways of working

Control through ways of working includes operating procedures, supervision and training.

It includes emergency procedures, decontamination and ‘permits to work’ for tasks such as maintenance.

It also means testing all control measures regularly – equipment, ways of working and behaviour, to make sure that they work properly.

You should keep records of examinations, tests and repairs to equipment for at least five years. This helps to identify any trends or variations in equipment deterioration.

Worker behaviour

Where control measures are in place it is important to use them properly.

This includes:

• wearing any PPE necessary;
• using control equipment;
• following hygiene procedures;
• warning supervisors if anything appears to be wrong.

Permits to work

Where proposed work is identified as having a high risk, strict controls are required. The work must be carried out against previously agreed safety procedures, a ‘permit-to-work’ system.

The permit-to-work is a documented procedure that authorises certain people to carry out specific work within a specified time frame. It sets out the precautions required to complete the work safely, based on a risk assessment. It describes what work will be done and how it will be done; the latter can be detailed in a method statement’.

The permit-to-work requires declarations from the people authorising the work and carrying out the work. Where necessary it requires a declaration from those involved in shift handover procedures or extensions to the work. Finally, before equipment or machinery is put back into service, it will require a declaration from the permit originator that it is ready for normal use.

Personal protective equipment (PPE)

Employers are responsible for providing, replacing and paying for personal protective equipment.

PPE should be used when all other measures are inadequate to control exposure. It protects only the wearer, while being worn.

If it fails, PPE offers no protection at all.

Types of PPE

• Respirators
• Protective gloves
• Protective clothing
• Protective footwear
• Eye protection

When deciding about PPE ask the supplier, your trade association or the manufacturer.

• Is it suitable for the conditions of the job?
• Does it offer the right level of protection?
• What sort of training or maintenance is required?
• How do I know when it needs replacing?

It is important that employees know why they need PPE and are trained to use it correctly. Otherwise it is unlikely to protect as required.

• Does it fit correctly?
• How does the wearer feel? Is it comfortable?
• Are all items of PPE compatible?
• Does PPE interfere with the job being done?
• Does PPE introduce another health risk, eg overheating, entanglement with machinery?
• If PPE needs maintenance or cleaning, how is it done?

When employees find PPE comfortable they are far more likely to wear it.

Monitoring the control of exposure to hazardous substances

Monitoring means measuring to show that control is adequate. It has nothing to do with the state of a worker’s health.

When do you need to monitor?

Monitoring is appropriate:

• when you need to show compliance with a WEL (Workplace Exposure Limit) or BMGV ( Biological Monitoring Guidance Value)
• when you need to show that control equipment or personal protective equipment is working well enough

Monitoring can also indicate the spread of contamination, eg surface wipes.

Screening, eg colorimetric detector tubes, meters, provides indicators of worker exposure only.

Personal air monitoring measures how much of a substance the worker inhales.

Biological monitoring measures how much of a substance has entered the body.

Further information has details of organisations that can help with monitoring.

COSHH health surveillance

What is health surveillance?

Health surveillance is any activity which involves obtaining information about employees’ health and which helps protect employees from health risks at work.

The objectives for health surveillance are:

• Protecting the health of employees by early detection of adverse changes or disease;
• Collecting data for detecting or evaluating health hazards;
• Evaluating control measures.

It should not be confused with general health screening or health promotion.

Health surveillance is necessary when:

• there is a disease associated with the substance in use (eg Asthma, Dermatitis, Cancers);
• it is possible to detect the disease or adverse change and reduce the risk of further harm;
• the conditions in the workplace make it likely that the disease will appear.

Health surveillance is a process; it may be a regular planned assessment of one or more aspects of a worker’s health, for example: lung function or skin condition.

However, it is not enough to simply carry out suitable tests, questionnaires or examinations. Employers must then have the results interpreted and take action to eliminate or further control exposure. It may be necessary to redeploy affected workers if necessary.

Health surveillance may need to be completed by an occupational health service physician (doctor or nurse). If a GP offers the service, you need to be sure that they are competent in occupational medicine.

The clinical outcomes from health surveillance are personal. The service provider must interpret the results of health surveillance for each individual. The service provider must supply general information for you to keep up-to-date health records. They may also be able to anonymise and group the information to highlight trends.

HSE produces a priced publication called Health surveillance at workwhich provides guidance on how employers can fulfil their legal duty to provide health surveillance.

Employers’ checklist- 4 stage approach

1. Do I have a health risk problem, or a need for occupational health input, in my workplace?
2. What/who do I need to control/provide it (a doctor or nurse or a ’responsible person’)?
3. Take that action.
4. Is it working (check on what’s been done)?

Training for employees working with substances hazardous to health

Provide information, training and instruction for employees who work with substances hazardous to health. This includes cleaning and maintenance staff.

Employees need to understand the outcome of your risk assessment and what this means for them. Tell them:

• what the hazards and risks are;
• about any workplace exposure limit;
• the results of any monitoring of exposure;
• the general results of health surveillance;
• what to do if there is an accident (eg spillage) or emergency.

Employees should have access to safety data sheets.

Keep employees informed about planned future changes in processes or substances used.

When a contractor comes on site, they need to know what the risks are and how you are controlling them. And you need to know if they are bringing hazardous substances onto your premises, and how they will prevent harm to your employees.

Keep basic training records.

Training providers

• Local Colleges
• Trade Associations
• Suppliers of LEV and PPE
• HSL
• Consultants

Emergencies – be prepared

You need to plan and practice to cope with foreseeable accidents, incidents or emergencies. This means:

• The right equipment to deal with the emergency (eg a spill), including protective equipment and decontamination products;
• The right procedures to deal with a casualty;
• The right people trained to take action;
• The right arrangements to deal with the waste created.

Think about how you would make such information available to the emergency services.

Everybody needs to know your emergency plans. Involve safety representatives and employees.