An image showing chemicals on a shelf - COSHH regulations

COSHH

Comply with COSHH Regulations

Understanding and complying with the law around COSHH is important in any business that comes into contact with chemicals. In this month’s article we take a look at COSHH regulations and how an employer can adhere to these regulations.

What does COSHH Stand for?

 COSHH is an acronym for Control of Substances Hazardous to Health.

What is COSHH?

COSHH is a set of regulations introduced originally in 1988, and have gone through several revisions in:

  • 1994,
  • 1999, and
  • 2002, with an amendment in 2004, but the 2002 regulations are the most update!

The regulations were put into place to protect workers when working with specific materials and substances. It is important to note that failing to comply with these regulations is a crime and is punishable by an unlimited fine.

These regulations were brought into law to control the exposure of employees to hazardous substances and should be taken seriously by the employer and employees.

What does COSHH cover?

In order to answer this question effectively we need to break COSHH down into 2 parts:

  • Substances, and
  • Hazardous.

Substances

Let’s take a look at substances first, this includes any form of hazardous material which includes, but not limited to:

  • Beauty products.
  • Benzene in crude oil,
  • Detergents,
  • Dusty or fume-laden air,
  • Flowers, bulbs, fruit, and vegetables,
  • Glue,
  • Ink,
  • Lubricant,
  • Metalworking fluids,
  • Paint,
  • Prolonged contact with wet cement in construction, and
  • Wet working, e.g., catering and cleaning.

In summary substances can be all around in the working environment but does depend on what work is being carried out. COSHH substances take the form of:

  • Biological agents such as bacteria and viruses.
  • Dust,
  • Fibres,
  • Fumes,
  • Gases,
  • Liquids,
  • Mists,
  • Nano-particles,
  • Solids, and
  • Vapours.

Hazardous

When we look at hazardous, we are looking at any potential damage to:

  • Central nervous system,
  • Eyes,
  • Genes,
  • Internal organs,
  • Lungs,
  • Mouth,
  • Nose, or
  • Skin.

The hazardous part of the regulations also applies to the risk of injury due to combustion or explosion, from the substances being used.

What does COSHH not cover?

The COSHH regulations have a few areas that they do not cover as these have specific regulations of their own, these are:

  • Asbestos,
  • Lead, and
  • Radioactive substances.

How to identify a Hazardous Substance

A hazardous substance can be identified by reading its label or Safety Data Sheet (SDS). Having an awareness of The Globally Harmonised System (GHS) of classification and labelling of chemicals is important.

What is The Globally Harmonised System (GHS)?

 The Globally Harmonised System (GHS) is an international standard for identification of labelling chemicals, replacing the Chemicals (Hazard Information and Packaging for Supply) Regulations (CHIP) in 2015.

Here we compare the old CHIP signs with the GHS current system:

COSHH Statistics

Of course, the human cost is the first thing that we think of, we will explore statistics around the human cost shortly, there is a business cost to the misuse of COSHH as well.

In 2021/22 36.8 million working days were lost due to Health and Safety, including COSHH. It came with a cost of £18.8 billion in 2019/20.

In the UK there are millions of workers who work in environments that bring them into close proximity of hazardous materials. Sadly, the mismanagement, poor safety and accidents in the workplace can be fatal:

  • 135 people were fatally injured at work in 2021/22,
  • Exposure to harmful working conditions can also result in fatal diseases,
    • Asbestosis = Over 5,000 deaths (2021/22),
    • Hazardous chemicals = 541,000 workplace injuries (2017/8), and
    • Ill health = 1.4 million workers,
    • Non-stress or musculoskeletal disorders = 56% of those.

As you can see, controlling the risk of hazardous substances and complying with COSHH is vitally important and can save lives.

What do I need to do?

The Health and Safety Executive (HSE) states that employers 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 workers and others,
  • Providing monitoring and health surveillance in appropriate cases, and
  • Planning for emergencies.

A COSHH Risk Assessment

The Standardised Risk assessment format should be followed when assessing the risks of COSHH, but it is important that it has been amended to reflect the COSHH regulations.

The 5-step Risk Assessment process is:

Step 1: Identify the hazards.

Step 2: Decide who might be harmed and how.

Step 3: Evaluate the risks and decide on precautions.

Step 4: Record findings and implement them.

Step 5: Review the assessment and amend as necessary.

Step 1: Identify the hazards

 Identify which substances are harmful by reading:

  • The product labels, and/or
  • Safety data sheets (SDS).
  • If in doubt, contact your supplier.

You will need to carefully consider if your processes can cause damage to health through dusts etc.

Step 2: Decide who might be harmed and how

You will need to consider who might be harmed, and how, as well as whether they have any specific circumstances that need to be taken into account for example:

  • Work experience students,
  • Pregnant women, or
  • Disability.

Decide who might be harmed and how. It is important to consider:

  • How will there be exposure,
  • Effects of exposure by each route of exposure, (Inhalation, ingestion, absorption etc.)
  • Length of exposure, and how often someone is exposed to the substance,
  • Anyone else who could be exposed – not just employees, but visitors to the site,
  • What are your existing control measures?
  • What else can be done to control risks?
  • Who needs to take action, and by when?

 Step 3: Evaluate the risks and decide on precautions

 As with all Risk assessments, now that the hazards have been identified, who can be harmed and the severity of harm, it is time to think carefully about how to control the risk. In order to do this the hierarchy of Control for COSHH should be used:

  1. Eliminate

Does this substance have to be used? Is there a safer alternative?

  1. Change the process

Can the process be changed to eliminate the use or production of the substance?

  1. Containment

Can the process or activity be enclosed to minimise the escape or release of the substance?

  1. Cleaning

Think about how the cleaning process will take place, to ensure that exposure to harmful substances is minimised.

  1. Personal protective equipment

PPE is a LAST resort. If the exposure cannot be controlled by any other means PPE as well as other protective measures should be used. DO NOT rely on it and DO NOT automatically opt for this, it can often not be as effective as other measures.

Step 4: Record findings and implement them

 A business that has 5 or more employees must record their assessment but, even if they have fewer than 5, it makes sense to write down what steps they have taken to identify the risks. Make a list of the actions taken to control the risks to workers’ health.

One of the ways to ensure that measures are enacted are to provide staff with appropriate training. Ensure that they have been given all the necessary information about the hazards and risks, as well as how they are to protect themselves in line with the Risk Assessment of the business.

Step 5: Review the assessment and amend as necessary

A Risk Assessment is a live document, that should be reviewed regularly to ensure that it is up-to-date and takes into account any changes in the workplace. It is important that any measures introduced are reviewed to ensure that they are actually working!

A Risk Assessment must also be reviewed when there are the following changes:

  • To the workplace,
  • To staff,
  • A process, or
  • To the substances or equipment used,

A risk assessment must also be reviewed when staff have reported problems, concerns, accidents or near misses.

It is vital that the risk assessment record is updated with any changes made.

We hope that we have given you an insight into
the World of COSHH, and how you can comply with these important regulations.

For more information on COSHH and Risk Assessments,
Why not get in touch and book a course:

The Training Fox Health and Safety Course Den

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