Controlling and Working with Substances that are Hazardous to Health (COSHH)
Many people will be familiar with the Control of Substances Hazardous to Health Regulations 2002, or COSHH. This is because substances are regularly used in many businesses, and many can be harmful to health. Where this is the case, COSHH applies.
As a health and safety practitioner, your knowledge of COSHH will be extensive. Indeed, your role may involve conducting risk assessments and providing training on COSHH to employees who encounter harmful substances during the course of their work. You may also be heavily involved in the implementation of control measures to reduce risks.
What is COSHH?
The COSHH Regulations apply to the way in which people work with hazardous substances. The legislation is concerned with safe use and practice in relation to these substances.
Harmful substances cause health problems. Dermatitis may be suffered when skin comes into contact with substances such as certain fluids used in metalworking, or even flowers. Chemical burns can occur if wet cement gets on to someone’s skin. Lung problems could result from inhaling fumes or dust. Serious diseases can be suffered, too, such as leukaemia, as a result of exposure to benzene.
How do you know what risks are present?
By carrying out a COSHH assessment, you can identify risks. There are four steps in this process:
- Firstly, consider where people might be exposed to any hazardous substances. Look at the processes that workers carry out and identify any emissions or skin contact.
- Secondly, identify the way in which these substances are harmful. Consult safety data sheets for the information. If there is no safety data sheet available for something that may be a by‑product of a certain process, conduct research.
- Thirdly, consider which particular tasks may result in exposure, and whether there are any control measures in place.
- Fourthly, read the workplace accident book and look for any incidents that point to problems related to hazardous substances. Has anyone suffered chemical burns, for example?
You must record your risk assessment if your organisation has five or more employees, but it is good practice to do so anyway, even if there are fewer people in your workplace.
Exposure control measures: preventing health problems by managing risks
To reduce the potential for exposure to harmful substances, exposure control measures should be implemented. They address two areas: the equipment used, and the way in which a task is performed.
Implementation is achieved through instruction, training and supervision, and a health and safety practitioner’s input is vital in ensuring this happens.
The best form of control measure is elimination of the product and the use of something safer in its place. If this isn’t possible, a safer form of the product should be used.
If alternatives are not feasible, the process should be changed so that emissions are reduced. It could be enclosed so as to prevent the escape of any emissions, or the emissions could be extracted as close as possible to their source.
Keeping people away from harm is important, and if personal protective equipment (PPE) is required, it should be provided.
Whatever control measures are implemented, those who carry out the process must understand what the measure is and why it is required. They should also know how to use any PPE with which they have been supplied.
Equipment should come with a user guide, which you should read and understand but, if there is no guide, you should create one. It should contain information on what the control measure is, any checks that may need to be carried out (and at what intervals), and the scheduling of maintenance.
What particular control measures may be used in a workplace?
The specific control measures used will vary from industry to industry. However, the two most common methods are local exhaust ventilation, which ensures that people are not exposed to airborne contaminants, and PPE. These may be used in combination.
Consider what happens when, for example, a disc cutter is used to cut stone. The harmful substance is the dust produced. An enclosure to extract the air, and a vacuum cleaner, would constitute appropriate control equipment, and the way of working would be to use the disc cutter on stone within the enclosure and use the vacuum cleaner to collect the dust left behind. Testing and maintenance of the enclosure and vacuum cleaner would be required, too.
The appropriate PPE for this task would be a filtering facepiece (an FFP3 mask) or an orinasal respirator (covering the mouth and nose), which should be used both when cutting stone and vacuuming up afterwards. The masks should, of course, fit the disc cutter operator’s face properly.
What else can a health and safety practitioner do to ensure COSHH awareness and compliance?
When exposure control measures are needed, it is imperative that those involved in designing, installing, maintaining and testing them are properly qualified. As a health and safety practitioner, you will possess the necessary competence to oversee all aspects.
You should also ensure that workers are fully involved in the process. Consult them and find the answers to these questions: Are the measures being implemented suitable? Is there scope for improvement? What if something goes wrong?
Provide staff with the necessary training and information both to use the control measures and to check that they are working properly. Arrange drills so that staff can practice dealing with any problems such as spills.
Remember that the objective of COSHH is to ensure that workers’ health is not affected by harmful substances. To this end, it may be necessary to carry out monitoring, for example, through air sampling.
Health surveillance may also be necessary. If people are at risk of skin disease because of the work they do, for example, they will need to undergo assessments by a doctor. The results will show whether control measures are working properly, and inform any changes that need to be made.
Everyone in an organisation, from the chief executive to the new apprentice, needs to be COSHH-aware. As a health and safety practitioner, you are the right person to dispense the appropriate information to everyone. Make sure they exploit your expert knowledge.