COSHH stands for Control of Substances Hazardous to Health. Here's a guide to what comes under COSHH and what it means for your business.
1) What is a 'substance hazardous to health'?
While in some cases it may be obvious that something may be considered hazardous to health, this is not always the case. COSHH covers a wide range of substances, not just harmful chemicals.
Substances falling under COSHH regulations include:
- Substances or mixtures of substances classified as dangerous to health under the Chemicals (Hazard Information and Packaging for Supply) Regulations 2002 (CHIP). Their warning label can identify these and the supplier must provide a safety data sheet for them.
- Biological agents, bacteria and other microorganisms which are directly connected to the work undertaken (e.g. in farming, sewage treatment, research, healthcare) or are incidental to it (e.g. exposure to harmful bacteria due to improperly maintained water towers or air conditioning systems).
- Any kind of dust if average concentration in the air exceeds levels specified by COSHH.
- Harmful fumes, vapours, gases or asphyxiating gases.
- Products containing chemicals.
- Any other substance which poses a risk to health, but which for technical reasons may not be specifically covered by CHIP, including: pesticides, medicines, cosmetics or by-products of chemical processes.
COSHH does not cover lead, asbestos or radioactive substances, as these have their own specific regulations.
2) Assess the risks
The risk assessment must:
- Identify the hazardous substances present in your workplace.
- Consider the risks these substances present to people's health. Identify and consider who could be exposed to the substance and how often.
Whoever carries out the assessment needs to have access to and understand the COSHH regulations and relevant approved codes of practice.
3) Develop practises to control, mitigate and eliminate these risks
A. Prevent exposure: The COSHH regulations require you to prevent exposure to substances hazardous to health whenever reasonably practicable to do so. Furthermore, whenever it is possible and practicable to do so, you must substitute a hazardous substance for a less hazardous, or safe, substance, or use another process which doesn't create a hazardous form of that substance.
B. Adequately control exposure: If prevention is not reasonably practicable, you must adequately control exposure:
- Use work systems, engineering controls and personal protective equipment (PPE) to reduce exposure - e.g. air extraction systems, ventilation, hazmat suits, gloves, respirators, etc.
- Control exposure at source, reduce the number of exposed employees to a minimum and reduce the level and duration of their exposure.
For example: Silicosis is a potentially fatal occupational lung disease caused by exposure to crystalline silica dust. This dust is produced when cutting stone and is a common hazard in construction and mining. Although eliminating exposure to the dust completely is not possible, water spraying equipment or extractor fans are commonly used to suppress or reduce dust at the source while dust masks and respirators provide personal protection to the worker.
4) Implementing and maintaining control measures
COSHH requires employees to make proper use of the control measures designed for their work processes and to report any defects with them. This is why employees must be suitably trained, informed and supervised concerning the potential dangers to their health and safe methods of work.
Employees must know:
- Which PPE to wear, when to wear it and how to use it properly
- How to use any equipment for controlling risks
- The correct hygiene proceedures
- Who to warn if anything appears to be wrong
COSSH places specific duties on the need to ensure that exposure controls are consistently maintained to the required standard.
5) Monitoring exposure
Exposure means the uptake of a substance into the body. The exposure routies are:
- By breathing in a fume, dust, gas or mist
- Via contact with the skin
- Via injection into the skin
- By swallowing
Around 500 substances have defined Workplace Exposure Limits (WELs) detailed in the EH40 workplace exposure limits. These are the substances most likely to cause harm to health should efforts to prevent or control exposure be absent, insufficient or defective.
According to COSHH regulations, you must measure the concentration of substances in the air that workers breath whilst performing their task to ensure they are below the relevant WEL. This must be performed by a competent, trained person.
6) Carrying out health surveillance
COSHH requires health surveillance to be carried out in the following circumstances:
1. There is a disease associated with the substance in use (e.g. Asthma, cancer, silicosis)
2. It is possible to detect the disease or adverse changes and to reduce the risk of further harm
3. The conditions in the workplace make it likely the disease will appear
This surveillance must be regular and not on a one-off basis. It is not enough to simply carry out tests, medical examinations etc. Employers must interpret the results and act to eliminate or control exposure more vigorously. It may be necessary to redeploy affected workers to prevent further exposure and progression of illness.
7) Inform, instruct and train
COSHH requires the provision of suitable and sufficient information and training for all employees, including:
- The main findings of any risk assessment.
- The names of substances they work with or could be exposed to and the related risks.
- Access to any relevant data sheets for those substances.
- What precautions they need to take to protect their health and that of others.
- How to use any PPE and safety equipment provided.
- The results of any exposure monitoring and health surveillance.
- The emergency proceedures to be followed in case of an accident or emergency.
8) Prepare plans & procedures
COSHH requires employers to identify potential accidents or emergencies involving controlled substances and create a plan outlining the response required before an accident happens. For some employers this is particularly important, as some industrial sites can be very dangerous if a disaster strikes due to the nature and quantity of substances involved. Although rare, incidents like the Bhopal disaster illustrate just how serious accidents involving hazardous substances can be.
This planning must include:
1. Preparing procedures and setting up warning and communication systems to enable an appropriate response immediately if any incident occurs.
2. Ensuring that the information on the emergency arrangements is available to those who need to see it, including the emergency services.
3. Preparing steps to minimise the harmful effects of an accident or emergency and restore the situation to normal immediately.
4. Briefing all employees who may be affected regardless of their function, i.e. all employees on site if a site-wide disaster is possible.
5. An evacuation plan for all staff and members of the public. Only employees necessary to deal with an incident may remain in an affected area and they must be provided with the appropriate safety equipment and training to handle it.
6. Safety drills to be practised at regular intervals involving all relevant staff.
To read the HSE's guidance concerning COSHH, click here.