The Control of Substances Hazardous to Health Regulations (COSHH) are undoubtedly the most important legal requirements for occupational hygienists working in Great Britain. They’ve been around for a long time now – the first version being enacted in 1988 – yet, in my experience, there are still many organisations that haven’t completely got to grips with them. One of the main problems is that many employers do not fully understand the Regulations and what they require and often misinterpret them.
In essence, COSHH is relatively straightforward. It simply sets out a framework for the management of risks created by using hazardous substances at work. I’ve often used the following diagram to summarise the main requirements of the Regulations
Employers whose operations involve the use of hazardous substances have to undertake a risk assessment in order to decide on what controls are appropriate. The other measures are then about they need to do to ensure that the controls remain effective (they’re the management controls that I’ve discussed in a previous post).
1. COSHH is about CONTROL
The first mistake employers often make is to forget the real objective of COSHH – i.e. controlling the risks. They put a lot of work into the assessment, often generating a lot of paperwork, but don’t follow through to implement effective control regimes. The assessment is important – it is needed to establish priorities by deciding on which are the most significant risks, but it is primarily meant to be a tool to allow the employer to develop an action plan. It’s a means to an end not an end in itself.
2. Assess the RISK not the HAZARD
The second common problem is that many employers do not understand how to undertake the assessment. It is quite common to focus on the substances used taking information from the safety data sheets provided by the suppliers and transferring it to a standard form , in effect, producing a summarised data sheet. This often involves a lot of time and resources, and although such summarised data sheets can be a useful information tool they are not a risk assessment.
To see why this is the wrong approach it’s useful to take a look at the wording of COSHH regulation 6 which sets out the requirements for the assessment.
‘An employer shall not carry out work which is liable to expose any employees to any substance hazardous to health unless he has
a}made a suitable and sufficient assessment of the risks created by that work to the health of those employees and of the steps that need to be taken to meet the requirements of these Regulations
b) `implemented the steps referred to in sub-paragraph a.”
The key words that I’ve highlighted are “the risks created by the work”. The substances present hazards but, as the Regulations clearly state, the risks are associated with the use of the substances.
I’ve heard many people state that they have carried out the assessments for all their substances. This normally indicates that they haven’t got it right. It’s not the substances that need to be assessed, but the work involving their use. For example, take a simple case where solvent is used for cleaning purposes. The risks, and the necessary controls, associated with using a few millilitres applied with a cotton bud are clearly quite different than using several litres of hot solvent in a vapour degreasing bath. It is inappropriate to carry out a risk assessment of the substance – two assessments of two quite different processes are needed.
So the assessment should focus on the process. It should also concentrate on the risk not just the hazard. Risk is often defined as “the probability of harm occurring in practice”. For occupational hygienists it is best summed up by the following equation:
So the hazardous properties are important, but they are only half the story. The key to effective risk assessment, which s often neglected, is understanding the exposure of employees (and anyone else who could be affected by the work).
3. Identify ALL hazardous substances
Most COSHH assessments I’ve seen concentrate only on the substances that are bought in by the company. Yet there can be other substances present which need to be considered such as fumes, dusts and other airborne contaminants generated by the process or reaction products and intermediates in chemical manufacturing. In many cases it is these process generated substances that present the most significant risks, but they are often neglected.
4. Consider ALL routes of exposure
Many people carrying out assessments only focus on substances that can be inhaled. But there are other routes by which substances can come into contact with the body and be absorbed. All of these need to be considered.
Skin exposure is a common problem in industry leading to direct effects on the skin such as irritation, chemical burns and dermatitis and some substances can be absorbed through intact skin (this is something I’ve addressed in a previous post). Ingestion of hazardous substances can sometimes occur – normally due to contamination of foodstuffs, often following skin exposure. Penetration through the skin can occur by injection where workers are handling needles (e.g. healthcare workers) or where the skin has been abraded or otherwise damaged.
5. Identify controls and other management measures
The other common mistake is that employers often do not properly consider the measures needed to control the risks. They forget that controlling risk is the objective of COSHH and that the Regulations specifically require that the assessment must set out “the steps that need to be taken to meet the requirements of …. (the)…Regulations””. This means that they need to decide on what controls are needed and what other measures might be needed (i.e. on the use, maintenance and testing of controls, air monitoring, health surveillance and information, instruction and training)
The first step in solving a problem is to recognise that it exists, but we then need to decide how to resolve it. I’ve set out some of the common problems with COSHH that I come across; I’ll consider how to avoid them when carrying out a COSHH assessment in my next post.