No employer may carry on with work liable to expose employees to substances
hazardous to their health, unless a suitable and sufficient
assessment of the risks created by that work, and of
the steps needed to comply with COSHH has been made (Regulation 6 of The Control
of Substances Hazardous to Health Regulations 2002).
A suitable and sufficient assessment should include:
- an identification of the hazards and
assessment of the risk to health;
- consideration of the prevention of exposure to
the hazardous substances;
- the steps which need to be taken to achieve adequate control
of exposure where prevention is not reasonably practicable; and
identification of other action necessary to comply with the regulations
Assessments should be regularly reviewed and whenever there is any evidence
to suspect that it is no longer valid, or where there has been a significant
change in the work to which the assessment relates.
The COSHH assessment procedure follows a logical
series of steps, beginning with the identification of the hazards
associated with a particular substance. Suppliers are legally obliged to provide
safety data information (MSDS) for their products to customers which should contain a
list of any hazardous substances contained within the product, and any other
pertinent information such as emergency/first aid procedures and control
measures to implement when using the substance. Hazards can be chemical,
physical, biological or microbiological.
Once the hazard has been identified and prevention of
exposure is not considered to be reasonably practicable, an assessment can be made of the risks to health from
the substance when used with a particular process or operation. This assessment
may incorporate monitoring of an individual's exposure to the substance, for
example by sampling the air quality in the vicinity of the operation or by
biological monitoring, where blood/tissue samples are taken from the operative
and analysed for accumulation of the substance. The results of the monitoring
can be compared with relevant guideline concentrations published by the HSE in
order to aid in the assessment of the risk to health.
A number of different monitoring techniques exist, but in general they all
consist of drawing air from in the vicinity of breathing zone of the operative
through a collection mechanism e.g. a liquid or solid sorbent which collects the
substance(s) of concern. The sample can then be transported to a laboratory and
analysed to quantify the amount of substance present.
Once the concentration of the substance in air has been quantified, it can
be compared with any relevant published workplace exposure limits (WELs) to assist
in the assessment of risk to health. The Health and Safety Executive annually publish a list of WELs in the publication EH40.
Where a risk to health is likely, or a potential risks exists, and it is not
considered practicable to eliminate exposure to the substance, a number of
controls should be implemented to reduce the risk to an
acceptable level. These may include engineering controls such as the
introduction of local exhaust ventilation or management controls such as the
rotation of tasks between employees to reduce the exposure to any one employee.
The provision of personal protective equipment (PPE) should always be
looked upon as a last resort, and should never be the first line of defence to
minimise exposure to the hazard.
The eight principles of good practice for 'the control of
exposure to substances hazardous to health are set out in
Schedule 2A of The Control of Substances Hazardous to
Health Regulations 2002 (see below) If employers apply the principles correctly, exposure
should be below any relevant WEL. Control by personal
protective equipment should only be used when other
measures are not reasonably practicable. The list of WELs
applies to concentrations of hazardous substances breathed
in by the worker and are used to determine the adequacy of
control measures.
The principles are
- design and operate processes and activities to minimise
emission, release and spread of substances hazardous
to health;
- take into account all relevant routes of exposure -
inhalation, skin absorption and ingestion - when
developing control measures;
- control exposure by measures that are proportionate to
the health risk;
- choose the most effective and reliable control options
which minimise the escape and spread of substances
hazardous to health;
- where adequate control of exposure cannot be
achieved by other means, provide, in combination with
other control measures, suitable personal protective
equipment;
- check and review regularly all elements of control
measures for their continuing effectiveness;
- inform and train all employees on the hazards and risks
from the substances with which they work and the use
of control measures developed to minimise the risks;
- ensure that the introduction of control measures does
not increase the overall risk to health and safety.
NEMS is able to assist clients in compliance with their legal obligations
under COSHH in a number of ways, ranging from walk-through surveys to identify
processes and hazardous substances present, to a comprehensive air monitoring
service and subsequent recommendations for control measures designed to reduce
to an absolute minimum any potential risk to health. The completed assessment is
provided on a standard proforma which can be tailored to the specific needs of
your organisation.
In addition to monitoring and assessment, we provide testing of local exhaust ventilation (LEV) to meet the requirements of the 14-monthly inspection required under Regulation 9 of COSHH.
