Control Of Substances Hazardous To Health Guidance

INTRODUCTION

The Control of Substances Hazardous to Health (COSHH) Regulations require that employees and others likely to be affected are protected against exposure to hazardous substances either used, or created, by work activities.

Exposure to biological agents, such as legionella, are also covered by the regulations.

MAIN HAZARDS

Hazardous substances may be defined as being very toxic, toxic, corrosive, harmful, sensitising, irritant, carcinogenic, mutagenic or toxic for reproduction. Hazardous substances in containers can usually be identified from the label (square orange background with black symbol) and any necessary supplementary wording. These are most commonly found on chemical containers such as those containing cleaning and maintenance substances.

Hazardous substances that are generated by work processes are not so easily identifiable as they do not come conveniently labelled. For example, people may be exposed to legionella bacteria from hot and cold water systems; various bacteria/viruses from bodily fluids; premises with covered or underground parking may expose people to vehicle exhaust fumes; some manufacturing and cleaning processes may give off dusts, vapours or fumes.

Exposure to hazardous substances may be via ingestion, inhalation, contact with eyes or skin and absorption through the skin.

Effects on health may be short-term or long-term and will generally vary according to levels and duration of exposure.

CONTROL MEASURES

Precautions

To comply with the requirements of the regulations, the following action should be taken.

An inventory of all substances used on the premises e.g. those used for cleaning and maintenance activities, and any processes where exposure to biological agents, fumes, dusts etc could arise.
All relevant product health and safety data sheets should be obtained from the manufacturer.
Copies of these data sheets should be made available to employees, preferably at the point of use or likely exposure.
Using the information provided by manufacturers, and knowledge of the way products are used, or exposures likely to occur, an assessment should be made of likely exposure and the consequential risks to health.
Where practical, exposure to hazardous substances should be avoided, preferably by eliminating use of the substance or by substituting with a safe or less harmful alternative.
For substances which cannot be eliminated or substituted, the assessment should identify suitable control measures for safe storage, transport, handling and use. Where exposure cannot be adequately controlled by other means, the assessment should identify the provision, use, cleaning and maintenance of appropriate personal protective equipment and clothing. The assessments should be recorded and regularly reviewed to ensure they remain valid.
Copies of the assessments should be provided to employees who could be exposed to the substances.
To accurately determine likely exposure and to check that control measures are effective, some form of monitoring may be required. This may be continuous or occasional, depending on the substances and the nature of the process. For some substances, limits are specified, above which people should not be exposed. These are known as MELs (maximum exposure limits) and OESs (occupational exposure standards). Details of these are published annually by the Health and Safety Executive in document EH40. For further information, you should contact the consultancy on 01455 984222.
Personal protective equipment should only be used as a last resort method of preventing or controlling exposure.
All employees using, or likely to be exposed to hazardous substances must be given information, instruction and training about hazards and control measures relating to those substances, and the use, cleaning and maintenance of any personal protective equipment required.
To ensure the control measures identified by the assessment are used/applied correctly, regular checks should be carried out by management and corrective action should be taken where incorrect use, or non-use is observed.
Where control measures involve the use of personal protective equipment, the use of this equipment must be monitored and regular checks for signs of wear or damage carried out. It should be replaced, as necessary.
Where engineering controls or non-disposable respiratory protective equipment are used to control exposure, they must be maintained. With certain exceptions, extraction systems should receive a thorough examination and test at least once in every 14 months by a competent person. Respirators should be examined monthly. Records should be kept of these checks.
Arrangements should be made to ensure that no new substance is used before a manufacturer's health and safety data sheet is obtained, an assessment is carried out and appropriate information, instruction and training is provided for employees who are to use the substance.
All employees must be informed that they are required to co-operate with management regarding the use of the required control measures and to report defects or loss of any personal protective equipment supplied.
Contractors should be required to keep effective control of the hazardous substances brought onto the premises and to secure these in a locked cupboard or container when they are not being used.
Contractors must provide adequate control measures to prevent harm occurring to other people on the premises.

INFORMATION, INSTRUCTION AND TRAINING

Managers and supervisors should be trained on the requirements of the COSHH Regulations so they are able to implement an effective strategy for managing exposure to hazardous substances.
Employees using hazardous substances should be provided with sufficient information, instruction and training to understand the assessments, make effective use of the control measures and, where appropriate, to know the action to take in an emergency such as a spillage or leak.
There is a requirement to train users of personal protective equipment (PPE) in the following:
- the use and wearing of PPE.
- the cleaning, maintenance and replacement of PPE.
- the reasons for wearing PPE.
- the consequences of not wearing PPE.

HEALTH SURVEILLANCE

Some work activities and the handling of some substances, for example, work with substances which could cause asthma or dermatitis, may require those exposed to be subject to a health surveillance programme. Health surveillance is appropriate when an identifiable disease or adverse health effect is associated with exposure to a hazardous substance, and this is reasonably likely to occur under the working conditions. Health records must be maintained and kept for 40 years. For further information, you should contact the consultancy on 01455 984222.