Guidance on COSHH Regulations for Hazardous
Substances.
Introduction
The Control of Hazardous Substances to Health Regulations are aimed at
eliminating or controlling the risks at work from a wide range of substances.
While this guidance will introduce you to the main requirements of these
regulations and how to comply with them, staff who have a line management
or supervisory capacity for work which involves potentially hazardous
substances are strongly recommended to read the HSE Approved Code of
Practice , Control of Substances Hazardous to Health [5th Edition], which can
be ordered from HSE books at www.hse.gov.uk. In addition, School,
Departmental and Divisional safety officers or coordinators have been issued
with copies by OSHEU.
Which substances are covered by COSHH?
These include:
[1] Chemicals which are classified under the Chemicals (Hazard Information
and Packaging for Supply) Regulations [CHIP] as on or more of the following:
Very toxic
Toxic
Harmful
Corrosive
Irritant
Sensitising
Carcinogenic
Mutagenic
Toxic to reproduction
[2] Substances which have been assigned a Workplace Exposure Limit
[WEL] because of the potential risk from their inhalation. These limits are
published in EH40/2005 Workplace Exposure Limits which can be ordered
from HSE books at www.hse.gov.uk. In addition, School, Departmental and
Divisional Safety Officers or Coordinators have been issued with copies by
OSHEU]
[3] Dusts of any kind whose average concentration in air exceed the levels
specified in the COSHH regulations.
[4] Asphyxiant gases, which act by reducing the oxygen content of the
atmosphere. These include inert gases, such as nitrogen and argon, but also
certain flammable gases.
[5] Biological agents which can cause harm to human health. This harm
may be through infection, allergy, toxicity, or some other mechanism.
Biological agents include microoorganisms, such as bacteria and viruses,
fungi and prions; parasites and their infectious forms. Further advice on
working with biological agents is also given in the Biological Safety section of
this website.
[6] Carcinogens and mutagens
Because of the particular risks posed by these agents, COSHH provides
specific advice. You must read the information provided later in this guidance
if you are considering using either carcinogens or mutagens in your work.
[7] Any other substance hazardous to health not specifically covered by
CHIP [e.g. medicines, pesticides, cosmetics]
Which Substances are not covered by COSHH?
These include:
[1] Substances which are only hazardous because they are:
Radioactive
Have explosive or flammable properties
At high pressure
At extreme temperatures
[You should note that the use of radioactive substances is separately covered
by the Ionising Radiation Regulations (IRR) and use of explosive or highly
flammable substances is covered by the Dangerous Substances and
Explosive Atmospheres Regulations (DSEAR). Work involving high pressures
or extreme temperatures must be assessed and controlled as hazards under
the more general Management of Health and Safety at Work Regulations.
[2] Asbestos or lead, which have their own regulations
[3] Biological agents over which you have no control, e.g. someone catching a
cold from another person in the laboratory.
What COSHH Requires
If your work involves the use of any potentially hazardous substances, then
you must comply with the COSHH Regulations, the main requirements of
which are detailed below. The stipulated Steps to follow shown below are the
same as those given in, ‘COSHH: a brief guide to the Regulations’, which can
be downloaded from the HSE website - www.hse.gov.uk
You should also plan the work according to the principles of good practice for
the control of exposure to substances hazardous to health detailed in
Schedule 2A of the COSHH ACOP and listed in Table 1
Table 1 Principles of good practice for the control of exposure to
substances hazardous to health
Design and operate processes and activities to minimise emission, release and
(a)
spread of substances hazardous to health.
(b)
Take into account all relevant routes of exposure - inhalation, skin absorption
and ingestion
(c)
- 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
(d)
and spread of substances hazardous to health.
Where adequate control of exposure cannot be achieved by other means, provide,
(e)
in combination with other control measures, suitable personal protective
equipment.
Check and review regularly all elements of control measures for their continuing
(f)
effectiveness.
Inform and train all employees on the hazards and risks from the substances with
(g)
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
(h)
risk to health and safety.
Step 1 Assess the Risk
Risk assessment is central to the COSHH Regulations and it is essential that
you carry out a ‘suitable and sufficient’ assessment following the process
recommended by the HSE. These steps are explained in the HSE leaflet,
Five Steps to Risk Assessment, available free of charge from www.hse.gov.uk
or from OSHEU. OSHEU has prepared a Generic Risk Assessment Form
which follows these Five Steps and strongly recommends that you use it for
this purpose. It can be downloaded from the OSHEU website as a Word
form, together with associated guidance on how to carry out the assessment.
If, however, you decide that you have good reason for not using this form,
then you must ensure that your own follows and includes the Five Steps,
otherwise it may well not comply with the requirement in the Regulations to be
‘suitable and sufficient’
Do not forget that, when you do a risk assessment for a procedure, you must
consider all the associated hazards, not only those related to COSHH. For
example, there may be hazards specifically related to the equipment
(electrical, mechanical, noise, etc) or the substances may be flammable or
explosive.
Gathering information on the substances
Before you are able to properly assess the risks from the substances which
you will be using you must have sufficient information on any hazardous
properties it may have. This can be obtained in various ways:
[A] Chemical agents
There is a number of different sources for obtaining information on chemicals.
By law, a Materials Safety Data Sheet [MSDS] must be provided by the
supplier of a chemical and these provide a lot of information on the associated
hazards and recommended control measures. If you do not have the
manufacturer’s MSDS, these may be obtained from CD-Rom databases
provided by subscription from some of the large chemical suppliers, e.g.
Sigma and Fisher. These services are expensive and only include MSDSs for
those chemicals supplied by the manufacturer, but your School may
subscribe, so you should check on this. Alternatively, some of the large
chemical suppliers also provide MSDS information via their Internet websites,
again only for their own products..
There are also some very useful independent websites for obtaining MSDS
information, including: www.physchem.ox.ac.uk , www.cdc.gov , and
http://ull.chemistry.uakron.edu/erd/.
Free information leaflets are available on a number of specific chemicals via
the HSE website www.hse.gov.uk, which also supplies information on
Chemical Hazard Alert Notices (CHANS) and Methods for the Determination
of Hazardous Substances (MDHS), providing guidance on identifying and
promoting good practice for hazardous chemicals. . Finally, it is essential to
provide adequate information when disposing of the chemical waste. Further
information and advice on disposal of hazardous chemical waste can be
obtained from Environmental Safety at OSHEU
Other points to consider:
[a] the physical form of the substance can affect the hazard it poses, e.g. it
may not be hazardous as a solid, but may become so as a fine, breathable
powder or vapour.
[b] impurities can increase hazard, e.g. crystalline silica is often present in
other wise low hazard minerals
[c] some substances have a fibrous form which, due to its shape or size,
makes it more hazardous to health
[d] some substances are known to adversely affect health, but by an as yet
undetermined mechanism, e.g. byssinosis caused by certain textile dusts.
[e] exposure to two or more substances at the same time or in sequence can
produce an added, or synergistic, effect
[f] an unexpected event or emergency, such as a dangerous chemical
reaction or fire may produce a substance hazardous to health; if such an
event is foreseeable it should be considered in your risk assessment and
included in your emergency action plan.
[B] Biological Agents
Further advice on working with biological agents is also given in the Biological
Safety section of this website, which should be consulted.
In order to be able to carry out a Risk Assessment you should know to which
hazard group the biological agent belongs. This information can be obtained
by checking the most recent Approved List of Biological Agents provided by
the Advisory Committee on Dangerous Pathogens (ACDP) and published by
the HSE (http://www.hse.gov.uk/pubns/misc208pdf). The latest website
version should always be consulted as it is updated periodically. Organisms
in Hazard Group 1 are not included.
If you are working with an unlisted organism however, you should not
automatically assume that it is Hazard Group 1. Information needs to be
gathered about the organism and then a decision made when measured
against the criteria for each Hazard Group (see Genetically Modified
Organisms and Biological Agents, OSHEU website).
Information can be obtained from a number of sources, including websites
such as:
Health Protection Agency http://www.hpa.org.uk/
Public Health Agency of Canada http://www.phac-aspc.gc.ca/msdsftss/index.html
References such as Topley and Wilson’s ‘Microbiology and Microbial
Infection’ can be used. Checks should also be made in scientific literature for
information.
Information gleaned from the above will give the hazardous properties of
biological agents with regard to human health. Before carrying out the Risk
Assessment it should also be checked whether or not the biological agent
appears in the DEFRA Groups listed in the Animal Pathogens Order 1980,
available on
http://www.defra.gov.uk/animalh/diseases/control/animal_pathogens.htm. and
also whether or not the biological agents is a plant pathogen.
If the work is being carried out with substances which may contain biological
agents, e.g. blood and body fluids, sewage, effluent from landfill sites, then
you should consider which biological agents are likely to present and prepare
the Risk Assessment accordingly. Consideration must also be given as to
whether the experimental procedure may result in inadvertent culture.
Advice on carrying out Risk Assessment for work with biological agents is
given in the guidance “Biological agents: managing the risks in laboratories
and healthcare premises” which is available to download from the HSE
website at http://www.hse.gov.uk/biosafety/biologagents.pdf
Selection of the control measures for work with biological agents is largely
dictated by the requirements of COSHH. The minimum required is that the
Containment Level matches the Hazard Group of the agent used [Schedule 3,
COSHH Regulations 2002 (as amended)].
Step 2 Decide what precautions are needed
If your Risk Assessment reveals a significant risk to health from the
substance[s], then the COSHH Regulations require that you must decide on
which measures you should implement in order to completely prevent
exposure. Only if that is not practicably possible, should you select
measures designed to reduce the risk of exposure to an acceptable level. In
the latter case, your risk assessment should indicate the extent to which
prevention or substitution of a process were considered. In considering this
aspect, refer to the principles of good practice for the control of exposure to
substances hazardous to health detailed in Schedule 2A of the COSHH
ACOP and listed in Table 1
Step 3 Prevent or Adequately control exposure
Prevention of Exposure
This can best be done by one of the following:
[1]
Select a different procedure, which eliminates the need to use
this substance
[2]
Substitute the substance with one, which is safe
[3]
Where the substance is being produced as a waste product,
modify the process to eliminate its production
Control of Exposure
Only where you have concluded that it is not reasonably practicable to
prevent exposure, should you select measures, which are designed only to
control exposure as a means of reducing the risk to an acceptable level.
To achieve the appropriate level of control you should select and apply the
appropriate control measures from those approved by the COSHH
Regulations. These are set out in a list, which is in order of priority. That is,
you should always select a measure from as high up the list as reasonably
practicable.
For example, you should not select Personal Protective
Equipment when you are reasonably able to use a method such as a fume
cupboard to contain the hazard.
[1]
Enclose the process
This involves the installation and use of equipment designed to
completely enclose or isolate the process. Such equipment would
include fully sealed isolator cabinets [e.g. Sealed Glove boxes for
chemicals and Class III Microbiological Safety Cabinets for biological
agents. These may also be remote systems, where the process is
situated in a contained enclosure and operated from a distance by
computer.
[2]
Contain the process and remove hazardous substance by exhaust
ventilation
The most common form of this in laboratories would be fume
cupboards or Class I and II Microbiological Safety Cabinets. Other
examples are local exhaust ventilation [LEV] systems to remove fume
from welding operations and in wood-working where wood dust is
created.
[3]
Change the systems of work in order to minimise exposure
[i]
Look for methods of work, which minimise emission of or
potential exposure to the hazardous substance. For example,
production of hazardous dusts can be reduced by wet-working;
use of chemicals in pellet, rather than powder form.
[ii]
Reduce the time, frequency and amount of exposure. Fro
example, use the minimum amount necessary for the minimum
period
[iii]
Minimise the number of people exposed
[4]
Provide safe systems for handling, storage, transport and
disposal as waste of hazardous substances
[i] handling should only be done by means which minimise the risk of
exposure.
[ii] storage must be in appropriate, labelled containers in a suitable
location.
[iii] transport within a site must utilise appropriate, secure and robust
containers. Transport outside a site must conform to the appropriate
Regulations
[iv] waste disposal must only be by approved routes and in accordance
with the university policy on disposal of hazardous waste provided
elsewhere on the OSHEU website
[5]
Provide good hygiene and housekeeping
There should be:
[i] adequate facilities for washing, changing and storage of clothing
and PPE
[ii] arrangements for laundering contaminated clothing
[iii] separate accommodation for clothing worn at work which may
become contaminated
[iv] prohibition of eating, drinking and smoking in contaminated areas
which may result in the ingestion of hazardous substances
[6]
Provide safe methods of work and appropriate supervision
You should ensure that there is appropriate supervision of those
working with the hazardous substances to ensure that they follow good
practice and any defined methods of work at all times. An important
part of this is a written Standard Operating Procedure, which details the
precautions to be taken during the work in order to minimise the risk of
exposure.
[7]
Provide Personal Protective Equipment [PPE]
PPE should be used when it is not possible to achieve adequate
control over exposure by any of the other means shown above. Even
then, it should be used only in addition to the other appropriate
measures and should always be seen as the measure of last choice. If
PPE is required, then it must be carefully selected to be appropriate
and properly maintained and serviced, including cleaning, and staff
should be fully trained in its use. Anyone considering the use of PPE
should consult the specific guidance given elsewhere on the OSHEU
website.
Control of exposure to substances which cause occupational asthma
Hazardous substances which may cause occupational asthma are subject to
additional duties under COSHH. A list of such substances is provided on the
HSE website at www.hse.gov.uk/asthma/causes.htm. If you are planning to
use any of these or your work may involve exposure to them, you should
inform Occupational Health at OSHEU and obtain appropriate advice.
Substances subject to a Workplace Exposure Limit [WEL]
A wide range of subjects can cause harm by inhalation from the air and many
of these are subject to a statutory Workplace Exposure Limit [WEL] which
limits the amount in the air to which a person can be exposed over a standard
period of time. These are published in EH40/2005 Workplace Exposure
Limits which can be ordered from HSE books at www.hse.gov.uk, together
with guidance on how and when to apply them. If you are using s substance
which is listed as an inhalation hazard on its MSDS, then you must consult
this document and act appropriately. Further advice on occupational hygiene
monitoring may be obtained from Environmental Safety at OSHEU
Step 4. Ensure that control measures are used and
maintained
It is your responsibility to ensure that anyone under your supervision makes
proper use of all of the control measures which have been provided for the
procedure in question and that they report any defects which they find. An
important component of this is information and training and an appropriate
level of supervision
COSHH also requires that you ensure that any control measures are properly
maintained and continue to perform as originally intended. This includes both
systems of work and maintenance checks on items of equipment. For some
equipment, such as local exhaust ventilation [LEV], which includes fume
cupboards, microbiological safety cabinets and extract ventilation for
machinery, there is a statutory requirement for regular testing, which must be
complied with. If you use such equipment, you should read the OSHEU
guidance on this web site
Step 5. Monitor Exposure
COSHH requires that you measure the concentration of hazardous
substances in the air where your assessment concludes:
a) there could be serious risks to health if control measures failed or
deteriorated
b) exposure limits might be exceeded
c) control measures might not be working properly
This is not required if you can show by another method of evaluation that you
are preventing or adequately controlling exposure to your employees.
Air monitoring of the worker’s breathing zone must be carried out when
employees are exposed to certain substances and processes stated in
schedule 5 of the COSHH Regulations.
Records must be maintained of any exposure monitoring for at least 5 years.
Where an employee has a health record, monitoring results relevant to them
must be kept with their health record.
Step 6 Carry out appropriate health surveillance
For certain substances, which are known causes of ill health, health
surveillance is appropriate. For this to be the case, the following criteria need
to be met:
(a) an identifiable disease or adverse health effect may be relate to
exposure to the substance,
(b) there is a reasonable likelihood that the disease or effect may occur
under the conditions of this work, and
(c) there are valid techniques for detecting indications of the onset of this
disease or effect.
If you believe from the information you have about the substance that this
may be the case, consult Occupational Health in OSHEU for further advice
Step 7 Prepare plans and procedures to deal with accidents,
incidents and emergencies
It should be a normal part of the risk assessment procedure that you consider
the need for special procedures to be used in the event of an accidental
release or exposure to the substance(s) in question. However, COSHH also
requires that you prepare special written emergency plans and procedures
where the potential risks from such an exposure go well beyond those
associated with normal day-to-day work.
Examples given in the COSHH ACOP of events which may fall within this
category are:
[1]
any serious process fire which could give rise to a serious risk to health
[2]
any serious spillage or flood of corrosive agent liable to make contact
with an employee’s skin
[3]
any failure to contain biological, carcinogenic or mutagenic agents
[4]
any acute process failure that could lead to a sudden release of
chemicals, e.g. an exothermic reaction that results in the release of
toxic fumes.
[5]
Any threatened significant exposure over a WEL
Special emergency plans and procedures should be capable of:
[a]
mitigating the effects of the incident
[b]
restoring the situation to normal as soon as possible
[c]
limiting the extent of any risks to the health of any employees and
anyone else likely to be affected [e.g. people in the neighbourhood]
Further details of the required content of such a plan are given in the COSHH
ACOP.
Step 8 Ensure that employees are properly informed, trained
and supervised
You must ensure that anyone working with the substance(s) in question
receives suitable and sufficient information instruction and training.
This should include:
[1]
[2]
[3]
[4]
[5]
[6]
The associated hazards and risks and the main findings of your risk
assessment
The relevant control measures and how and when to use them
The defined method of work [standard operating procedure]
If PPE is required, its correct use, storage and cleaning
Cleaning, storage and waste disposal procedures
The procedures to be followed in the event of an emergency
It is important that this information and training is appropriate to the level of
risk and in a form, which will be understood by those involved in the work. It
is also vital to keep the information up to date, taking into account any
significant changes in the type of work or the methods used. Your control
measures will not be effective if those involved n the work do not know their
purpose, how to use them properly, or the importance of reporting faults.
Training records
It is good practice to keep records of training given to individual employees.
This can act as a useful checklist and confirmation that appropriate
information, instruction and training has been received. Such a record can
consist of a simple list of entries for each aspect of training, with the date
given and signed by trainer and trainee.
Carcinogens and Mutagens
COSHH includes special provisions for preventing or adequately controlling
exposure to carcinogens and mutagens (additional information Appendix 1 of
the ACOP). The major reasons for this are that the development of the
clinical effects may take many years after first exposure, often with no early
warning of adverse effects, and that cancer is frequently fatal.
Definitions of Carcinogen and Mutagen
Carcinogen
COSHH defines a as a substance or preparation (i.e. a mixture or solution of
two or more substances) which either:
a.
is classified for labelling purposes as carcinogenic category 1 or 2
carrying the risk phrases R45 ‘May cause cancer’, or R49 ‘May
cause cancer by inhalation’; or
b.
would be so classified if the European system for classifying
substances and preparations dangerous for supply was applied
(even if the law does not require this, as with certain pharmaceutical
products or by-products such as hardwood dust).
Substances or processes listed in Schedule 1 to the Regulations are
also included in the definition, because of historic evidence of a risk of
cancer in humans, though the precise agent may be unclear.
The descriptors assigned to the three categories of carcinogens are:
Carcinogenic Category 1 - substances known to cause cancer on the
basis of human experience;
Carcinogenic Category 2 – substances which it is assumed can cause
cancer on the basis of reliable animal evidence;
Carcinogenic Category 3- substances where there is only evidence in
animals, which is of doubtful relevance to human health (i.e. the
evidence is not good enough for Category 1 or 2.)
In the case of mutagens, there are three similar categories with
analogous descriptors, based on the strength of evidence for heritable
genetic damage.
Category 3 carcinogens, with the risk phrase R40 ‘Limited evidence of a
carcinogenic effect’, and Category 3 mutagens, with the risk phrase R68
‘Possible risk of irreversible effects’ are not included in the COSHH
definitions of ‘carcinogen’ and ‘mutagen’ respectively, but are subject to
the general requirements of COSHH.
A comprehensive list of
substances defined as carcinogens or mutagens for the purposes of
COSHH is in HSE’s publication EH40/2005 Workplace exposure limits
Mutagen
COSHH defines a mutagen as a substance or preparation which either:
a.
is classified for labelling purposes as mutagenic category 1 or 2
carrying the risk phrase R46 ‘May cause heritable genetic damage’;
or
b.
would be so classified if the European system for classifying
substances and preparations dangerous for supply was applied
(even if the law does not require this).
Prohibitions relating to certain substances
A number of known carcinogens are prohibited substances. If you are
planning to use a carcinogen, you should check the list of these substances in
Schedule 2 to the Regulations. If the carcinogen in question is listed in
Schedule 2, your must contact OSHEU for further guidance.
The importance of the risk assessment and control of the risk
Because of the peculiar nature of the risks associated with carcinogens and
mutagens risk assessment has an especially vital role to play and the COSHH
ACOP gives specific guidance on this aspect. The basic principles are no
different from those for risk assessment of other hazardous substances as
described elsewhere in COSHH and in this guidance, but due care should be
taken to properly take into account the peculiar and insidious nature of the
risk.
When selecting the appropriate measures for controlling the risk, you must
take into account the potential for long-term and possibly fatal effects, which
provide a compelling reason why you should make every effort to substitute
the chemical in question with a non-carcinogenic or non-mutagenic
alternative. If you have considered such alternatives and found them to be not
reasonably practicable you must state this in your assessment, giving your
reasons.
If you are synthesising chemicals you should choose synthetic routes which:
[a] avoid the use of carcinogenic or mutagenic substances at the start,
or as part of any process or activity; and
[b] avoid if possible the formation of by-products, intermediates, wastes
or residual containments consisting of or containing carcinogenic or
mutagenic substances and the conditions under which substances are
used.
Further guidance on substitution is provided in the ACOP (see paragraphs 8992) and in HSE’s publication. Seven steps to successful substitution of
hazardous substances.
If no suitable alternative to the carcinogen or mutagen is available, your
objective must be to try to prevent exposure to the chemical by the best
practicable means and following the hierarchy of control measures given
earlier in this guidance. Again, because of the nature of the risks posed by
carcinogens and mutagens, it is particularly important that you select the most
effective measure possible and your first choice of control measure should
always be the use of totally enclosed systems, unless this is not practicably
possible.
In all circumstances, employers should prevent or adequately control
exposures by measures other than personal protective equipment (PPE), so
far as is reasonably practicable. However, PPE, e.g. gloves, coats etc., and
respiratory protective equipment (RPE) in particular, may be used as
secondary protection in combination with other control methods, if those
methods do not adequately control exposure by themselves. If the use of
PPE and clothing is unavoidable, e.g. during a plant failure or maintenance
operations, employers should follow the guidance in the ACOP on the
standards for PPE, and the considerations that apply to the use of RPE.
Incidents Involving Carcinogens and Mutagens
In your risk assessment you must consider what actions may be needed in
the event uncontrolled release of a carcinogen or mutagen into the workplace.
If you conclude that this may result in the need for RPE which is capable of
providing adequate control of exposure to the carcinogenic or mutagenic
substances concerned, then you must make sure that they are provided and
that the staff concerned made aware of the circumstances in which it may be
required and are trained in their use..
Use, storage, labelling and disposal
You should:
c. keep carcinogenic or mutagenic substances to be used in the
workplace to the minimum needed for the process and, where
appropriate, store and transport them on site in closed containers,
clearly labelled and with clearly visible warning and hazard signs.
d.
clearly label and securely store carcinogenic or mutagenic waste
products until they are removed according to the official University
procedures for removal of hazardous waste.
e.
clearly identify the areas in which exposure to carcinogens or
mutagens may occur and take measures to prevent the spread of
contamination within and beyond these areas. The number of
people likely to be exposed to carcinogenic or mutagenic
substances and the duration of their exposure must be kept to the
minimum necessary for the work. Non-essential personnel must be
excluded.
Monitoring exposure in the workplace (regulation 10)
2.
Monitoring employees’ exposure to carcinogens or mutagens is normally
necessary because of the increased risk of serious health effects if
controls fail. Where the assessment concludes that air monitoring is
necessary, the employer should set up and follow a monitoring
programme to determine the extend of employees’ exposure, so that the
results can be compared with approved workplace exposure limits. If
there is no approved limit for a particular carcinogenic or mutagenic
substance, it is important that the employer sets an in-house
occupational exposure limit to detect any deterioration in standards of
control.
Information, instruction and training
The risk of cancer from exposure to a hazardous substance cannot in most
cases be presumed to be reduced to zero except by eliminating exposure.
Furthermore, the adverse effects may not show in the short term. It is,
therefore, especially important to ensure the information, instruction and
training is of an appropriately high standard. Employers should ensure that
employees are aware not only of the need to maintain control of exposure, but
also the additional compounding risks due to smoking. Smokers appear to
face an increased risk of occupational cancer, since they take a mixture of
substances into their lungs with the smoke.
In addition to the information specified by COSHH and the ACOP, employers
should keep employees and their safety representatives, and any other
people likely to be exposed to carcinogenic or mutagenic substances, aware
of:
a.
the type or form of the risk;
b.
the special features of carcinogenic and mutagenic substances; and
c.
the circumstances in which they may be exposed to carcinogenic or
mutagenic substances.
Health surveillance
You should be aware of the objectives of health surveillance and its limitations
in the case of carcinogenic or mutagenic substances.
Health surveillance has its limitations in identifying people at risk or in
detecting signs of cancer early enough for treatment to aid a full recovery.
For this reason, it is largely restricted to keeping health records, through skin
cancer is a good example where appropriate health surveillance can detect
the condition at an early stage when it can be cured. Medical surveillance by
a medical inspector of HSE’s Employment Medical Advisory Service or
appointed doctor is, however, required for employees exposed to any of the
substances and who are working in the related processes listed in Schedule 6
of the COSHH ACOP. Some of the substances listed are carcinogens.
[1]
Health surveillance is appropriate where employees are exposed to
carcinogenic or mutagenic substances, unless the result of the risk
assessment indicates that exposure is so adequately controlled that
there is no reasonable likelihood of an identifiable disease or adverse
health effect resulting from the exposure.
[2]
Where there is evidence from safety data sheets, risk phrases on labels
etc. that a substance is known to cause, or is suspected of causing,
cancer of the skin, e.g. arsenic, coal soot, coal tar, non-solvent refined
mineral oils, contaminated used mineral oils, health surveillance should
include:
[a] regular skin inspection by a suitably qualified person; or
[b] regular enquiries by a responsible person about symptoms, following
self-inspection by the employees concerned.
[3]
Where [1] and [2] do not apply, employers need only keep a health
record, as described in paragraph 235(a) of the ACOP.
There is usually a long time delay between exposure to a carcinogenic
substance and any related health effect. Therefore, employers should provide
employees who have been exposed with information about any need for
continuing health surveillance after exposure has ended, e.g. where a
substance may cause cancer of the urinary tract.