Control of Substances Hazardous to Health COSHH (Control of Substances Hazardous to Health Regulations 2002) COSHH requires employers to control exposure to health from hazardous substances to protect both employers and others who may be exposed from work activities. Employers must be aware of what hazardous substances are used in the workplace and the associated risks to health, precautions and controls must then be put in pace. Employers must ensure that employees are properly trained and/or supervised when dealing with hazardous substances. When does COSHH apply? 1. COSHH applies to virtually all substances hazardous to health, except: asbestos and lead, which have their own regulations substances which are hazardous only because they are: radioactive; asphyxiants; at high pressure; at extreme temperatures; or have explosive or flammable properties biological agents if they are not directly connected with the work, e.g. catching a cold from a work mate. For the vast majority of chemicals, the presence of a warning label will indicate whether COSHH applies or not. 2. Regulations cover requirements relating to substances which can cause ill-health. Such substances may be used directly in work, e.g. paints or cleaning materials arise from the work, e.g. dusts, fumes and waste products occur naturally, e.g. fungal spores in agriculture 3. For the purposes of COSHH, substances hazardous to health are substances identified as hazardous by their warning label, and supplied with a safety data sheet substances with occupational exposure limits (see safety data sheet) biological agents (bacteria and other micro-organisms), if they are directly connected with work or if exposure is incidental to it, e.g. farming, sewage work, healthcare any dust in concentrations that you feel may give rise to ill-health any other substance which has comparable hazards to health. IF IN DOUBT ASK YOUR LINE MANAGER OR SAFETY, HEALTH AND ENVIRONMENT ADVISER FOR ADVICE Useful Links: COSHH Risk Assessment Forms COSHH Regulations 2002 COSHH Amendment Regulations 2003 COSHH Amendment Regulations 2004 COSHH (HSE) SCOPE The Regulations cover requirements relating to substances which can cause ill-health. Such substances may:• be used directly in work, e.g. paints, cleaning materials; • arise from work activities, e.g. dusts, fumes, waste products; • occur naturally, e.g. fungal spores, in agriculture. These substances are usually supplied in packages carrying warning labels and should be accompanied by safety data sheets. By law, manufacturers/suppliers are required to provide such health and safety information. Substances hazardous to health consist of substances/mixtures:• identified as 'dangerous' and labelled accordingly; • considered to be biological agents, but only if directly connected with work or if exposure is incidental to work, i.e. health care; farming, etc. An employee catching a cold from a workmate would not fall within the scope of the COSHH Regulations. The following substances do not fall within the scope of the COSHH Regulations as more specific Regulations apply: • Asbestos and Lead; • Substances that present a risk due solely to one of the following hazardous properties: they are radioactive; an asphyxiant; at high pressure; at extreme temperatures; are explosive/flammable. REQUIREMENTS With regard to tasks that involve the use of substances covered by the COSHH Regulations, the Employer must:Assess the risk to the health and safety of those who may be affected. Decide what (if any) precautions are needed to minimise the risks and prevent or control exposure to the substance. Ensure control measures are used/maintained properly. Monitor exposure, and carry out appropriate health surveillance. Ensure employees are properly informed, trained, instructed and supervised. 1. Assess the Risk A procedure for undertaking and recording COSHH risk assessments is given in Annex 1. Unless the assessment is very simple, a record must be kept and a review date set. The Assessment must be reviewed at not less than 5 yearly intervals, and sooner where there is a significant change in circumstances, e.g. change in procedure or new information about the effects of the substances used becomes available. In general, the following must be considered: • Manufacturers advice (safety/hazard data sheets). • Those who might be affected and to what extent. • The likely routes of entry, e.g. can the substance be swallowed, inhaled, absorbed. • Risks posed by slippage's; leaks; accidental release. The control measures currently in place, compared to acceptable standards and 'Good Practice'. • Exposure to hazardous substances that may result from cleaning and maintenance work. • Employees who work away from your premise, as you must make similar considerations in respect to other workplaces, visited by your staff. 2. Precautions to Prevent or Control Exposure If it is 'Reasonably Practicable' you must aim to prevent exposure, for example, by changing the process/activity; replacing the substance with a safer alternative; or using the same substance but in a safer form. In deciding whether a measure is reasonably practicable a consideration of the cost, time and effort that may be incurred must be weighed up against risk. The 'cost' must be commensurate with the risks, i.e. more serious risks may necessitate greater investment than less serious risks. If prevention is not reasonably practicable then one or more of the following measures must be adopted, as appropriate: a) Total enclosure of the process/activity b) Partially enclose and extraction (e.g. local exhaust ventilation [LEV]; fume cupboard. c) General ventilation e.g. opening windows and doors, 'fresh air'. d) Safe systems of work e.g. adopting safe codes of practice e) Decreasing the number of employees exposed and the duration of exposure (only after having considered other options). f) As a last resort, where no other controls are appropriate or as a 'belt and braces' precaution, issue of Personal Protective Equipment [PPE]. 3. Ensure Control Measures are Used/Maintained Properly Employers must take reasonable steps to ensure that employees use the measures made available. Reasonable steps are considered to include: • Provision of training, instruction, supervision, information. • Carrying out simple checks at regular intervals. • Testing and examining controls, where appropriate, e.g. PPE, LEV and keeping simple records (for a 5 year period) to demonstrate that tests have been undertaken. • Employees must use the control measures properly. 4. Monitoring Exposure and Undertaking Health Surveillance In the following circumstances, the COSHH Regulations require exposure to be monitored and records to be kept: • Wherever there could be a serious risk to health, if controls deteriorated or failed. • Where reassurance is required, to demonstrate that exposure limits are not being exceeded. • To demonstrate that control measures are working properly In the following circumstances, the COSHH Regulations require Health Surveillance to be undertaken: • Where employees are exposed to substances linked to a disease or adverse health effect AND there is a likelihood of such a disease/effect occurring AND it is possible to detect signs or symptoms • For special processes contained in a Schedule to the Regulations. Health Surveillance can involve: • A doctor and trained nurse examining employees. Supervisors performing simple checks/asking relevant questions, e.g. checking skin; asking about breathing difficulties. • Records of Health Surveillance must be kept for up to 40 years. 5. Information, Training, Instruction and Supervision Employees must be given information, instruction and training to cover the: • Nature of substances used, and the risks they pose. • Precautions to be taken and their purpose, including PPE. • Results of exposure monitoring and health surveillance (having regard to confidentiality). • Emergency procedures.