(COSHH) CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH
The controls of Substances Hazardous to Health Regulations 1988 are widespread and encompass all manner of premises. Managers should carry out “suitable and sufficient” assessments of risks to health arising from substances used in connection with work.
Such assessments should be reviewed on annual bases, and updated wherever and whenever changes occur. This is to ensure that they remain a true reflection of current practices.
If part of the control measures involve the use of engineering controls such as processing/handling equipment, local exhaust ventilation or extraction plant, or any plant, processes or systems designed to control, contain or confine contamination whether under normal conditions or in the event of leakage or spillage, then weekly visual checks should be made and servicing and maintenance carried out as recommended by the manufacturers.
Finally, monitoring of exposure to hazards to health should be undertaken to ensue that the assessment, control measures, maintenance and examinations are effective.
The COSHH Regulations are the main piece of legislation covering control of risks from chemicals and toxic substances. This principles of control will be applied to all coshh substances (except lead, asbestos and radioactive substances where existing regulations continue to apply, these should be kept in a separate file).
In essence, the regulations require employers to make an assessment of the risk to health that may arise from the use of substances at the workplace, establish and maintain the necessary control measures, and, provide monitoring of exposure and health surveillance. The regulations are supported by Approved Codes of Practice (AcoPs) and other guidance dealing with the regulations themselves and specific substances or classes of substance.
The following explanation sets out the main features of COSHH and produces a step-by-step guide to what employers must do to comply with the regulations.
The COSHH Regulations apply to all substances classified as being very toxic, harmful, corrosive, or irritant.
Packaging & Labelling of Dangerous Substances Regulations 1989. State that all labels should have this information on them. They also apply to all other substances hazardous to health arising from work activities, including mixtures and compounds.
Certain existing prohibitions on very dangerous substances are continued (i.e. the Carcinogenic Substances Regulations) and there will be revisions in future in line with EC Directives.
The key provision of COSHH, from which other elements follow, is the requirement for the employer to carry out an assessment of likely risks to health to his employees arising from exposure to hazardous substances. The purpose of such an assessment is to enable a decision to be made about measures necessary to control substances hazardous to health arising from any work activity.
It allows the employer to show:
All the factors pertinent to the work have been considered; and informed and correct judgement has been reached about the risks and the steps which need to be taken to achieve and maintain adequate control;
Under the regulations and the general ACOP, the degree of detail involved in its preparation has to be commensurate with the nature and degree of risk arising from the work. Key issues here concern:
Once the employer has identified a potential risk to health, they must ensure that a risk assessment is completed. Staff should be made aware of potential dangers and what precaution have been put into place
The employer should ensure that thorough examinations and tests of engineering controls are carried out; in the case of local exhaust ventilation plan this should be done at least once every 12 months. Respiratory protective equipment has to be examined at suitable intervals, and, for all control measures a record (or summary) of the examinations has to be kept for 5 years.
Where it is necessary for the protection of the health of workers, the employer should ensure that they are under suitable health surveillance. Health surveillance should be treated as being appropriate where the worker is exposed to one of the substances where statutory medical examinations are required under existing legislation.
Health surveillance also has to be carried out where the exposure of the worker is such that an identifiable disease or adverse health effect may be related to the exposure, where there is a reasonable likelihood that the disease or effect may occur under the particular conditions of work and there are valid techniques for detecting signs of the disease or the effect. Any judgement as to the likelihood that a disease or adverse health effect may occur must be related to the nature and degree of exposure. If, following assessment, it can be shown that it is most unlikely that any disease or adverse health effect will result, then exposure can be deemed not to be significant and health surveillance is not required. Examples of health effects where health surveillance should be considered are given in the ACOP.
Workers exposed to substances hazardous to health must be given sufficient information, instruction and training to enable them to know about the risks involved and the precautions which should be taken. They are also entitled to know the results of environmental monitoring and the collective results of any health surveillance.
All persons having the authority to issue official purchase orders must request from the supplier, all data on health and safety of the product concerned. The product must be delivered to the Health and Safety Co-ordinator in order for an assessment to be carried out before the substances is used in the workplace.
Everyone has a duty to bring dangerous situations or things which could cause harm or damage to themselves or others (Hazards) to the employer’s attention. In normal circumstances, hazards which are likely to cause imminent danger should be dealt with immediately by reporting them to the Health and Safety Co-ordinator/Nursery Manager, so that remedial action may be taken, and a Risk Assessment undertaken.
Suggestions or
health and safety queries may also be raised.
Where personnel feel that action to remove or reduce hazardous
situations is not satisfactory, they should make formal representation to the
Health and Safety Co-ordinator/Nursery Manager by
using the Health and Safety hazard report form.
The issuing and receiving of hazard report forms must be monitored and
reviewed formally by the Health and Safety Co-ordinator on a regular basis. Where
the Health and Safety Co-ordinator receives a hazard report form a risk
assessment should be carried out to ascertain whether remedial action is
required.
© 2010