Hazardous Substances (COSHH)
This section will consider controlling exposure to substances that are hazardous to the health of
employees, pupils and third parties. It will help you understand what you need to do to comply with
the Control of Substances Hazardous to Health (COSHH) Regulations 2002 (as amended) which
apply to hazardous substances used in your school.
What is COSHH for?
The objective of COSHH is to prevent, or to adequately control, exposure to substances hazardous
to health, so as to prevent ill health.
You can do this by:

Eliminating the use of a certain substance if exposure cannot be controlled adequately; or

Substituting substances with others that are less hazardous in composition.
If it is not possible to do this consider the following:

using control equipment, e.g. total enclosure, partial enclosure, local exhaust ventilation
(LEV);

controlling procedures, e.g. ways of working, supervision and training to reduce exposure,
maintenance, examination and testing of control measures;

worker behaviour, making sure employees follow the control measures;

Providing personal protective equipment (PPE) as a last resort to minimise exposure.
Changing how often a task is undertaken, or when, or reducing the number of employees nearby,
can make an improvement to exposure control.
A substance hazardous to health is considered to be:
(i)
Any substance designated as toxic, corrosive, harmful or irritant. In 2009 International hazard
symbols were introduced to replace the European ones; however the European ones are still
widely used. Some of the International ones are similar to the European symbols but there is
no single word describing the hazard.
You should read the hazard statement on the
packaging and the safety data sheet from the supplier for further information;
(ii)
Any dust in significant quantities;
(iii)
Any substance allocated an occupational Workplace Exposure Limit (WEL) by the Health and
Safety Executive;
(iv)
Any micro-organism involved in a working activity which creates a hazard to health i.e.
leptospirosis or legionnaires' disease;
(v)
Anything else that can cause an ill-health effect!
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Symbols to note:
See also - http://www.hse.gov.uk/pubns/indg352.pdf
Toxic/Very Toxic - substances and preparations which cause
death or chronic damage to health when inhaled swallowed or
absorbed via the skin.
Harmful Substances - any preparations which may cause death
or acute chronic damage to health when inhaled, swallowed or
absorbed via the skin.
Irritant - non-corrosive substances and preparations which,
through immediate, prolonged or repeated contact with skin or
mucous membrane, may cause inflammation.
i
Corrosive Substances - any preparations which may, on
contact with living tissues, destroy them.
What you need to do
You need to control the risks to your staff from exposure to hazardous substances. To do this you
have responsibility for:

identification of substances that may be hazardous when used;

elimination or substitution to reduce the risk;

preparation of a suitable and sufficient risk assessments;

implementation of control measures that are proportionate to the risks posed by that
substance;

provision of information, instruction, training and supervision for employees in proportion to
the risks associated with that substance;

arrangement of suitable labelling and storage;

monitoring and review of the effectiveness of arrangements in controlling the risk from
hazardous substances;

keeping records of the above.
Remember that hazards and risks are not limited to substances labelled as ‘hazardous’.
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COSHH Assessments
Identification
The process should start by identifying and compiling an inventory all hazardous substances that are
used or generated on site. You could use this as a good exercise to tidy up storage areas and
dispose of safely any items that are no longer used. Remember that not all substances come in
containers – some are produced naturally or by processes such as bodily fluids, sawing and drilling
(dust) or exhaust fumes.
Generic lists of materials might be a useful starting point such as:
cleaning materials (e.g. bleach, detergents);

bodily fluids (e.g. blood, vomit);

materials associated with conservation (e.g. mould spores);

samples (e.g. of carcasses, food etc);

arts and crafts materials (e.g. solvents and dyes, pottery silicadust);

oils and greases from vehicle maintenance (e.g. lubricating oils);

paints and brush cleaning solutions (e.g. thinners, white spirit);

design and technology materials (e.g. wood dusts) etc.
Examining the activities undertaken in a particular workplace, workshop, classroom etc will assist the
assessment:
maintenance of swimming pools;

cleaning duties;

woodworking;

pottery;

painting, paint stripping;

servicing machinery, vehicles etc.
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Material Safety Data Sheets (MSDS)
Safety data sheets provide information on chemical products that help users of those chemicals to
make a risk assessment. They describe the hazards the chemical presents, and give information on
handling, storage and emergency measures in case of accident.
All safety data sheets must contain information set out under 16 standard headings. At first sight
some safety data sheets may appear complicated. The safety data sheet shall be dated and shall
contain the following headings:
1. Identification of the substance/mixture and of the company/undertaking;
2. Hazards identification;
3. Composition/information on ingredients;
4. First-aid measures;
5. Fire-fighting measures;
6. Accidental release measures;
7. Handling and storage;
8. Exposure controls/personal protection;
9. Physical and chemical properties;
10. Stability and reactivity;
11. Toxicological information;
12. Ecological information;
13. Disposal considerations;
14. Transport information;
15. Regulatory information (which includes the Risk (R) or Hazard (H) statements that describe the
hazards);
16. Other information.
However, you can find the most useful information under the sections which have been underlined.
Caution - A safety data sheet is not a risk assessment. You should use the information it contains to
help make your own assessment, that not only details potential hazards associated with use and
storage, but that clearly identifies frequency of use, quantities stored, duration of use and those
potentially exposed.
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Conducting an Assessment
A COSHH and Cleaning Toolkit has been developed especially for schools which can be found at
http://wisenet.wiltshire.gov.uk/documents/dsweb/View/Collection-2181
This toolkit gives you all the guidance and forms to develop a robust COSHH system. Using this
toolkit you should do the following:
1.
Review hazardous substances on site and dispose of (eliminate) any items no longer required
(in accordance with the safety data sheet);
2.
Compile an inventory of the remaining hazardous substances;
3.
Obtain the most up to date safety data sheets;
4.
Carry out initial assessment of all products;
5.
Carry out full COSHH assessment for those products falling into Exposure Banding 2 or 3;
6.
Provide appropriate personal protective equipment;
7.
Develop task risk assessments and safe systems of work;
8.
Provide staff with information, instruction and training (record all training).
Control Measures
In general terms, the most effective control measure should be adopted to reduce exposure. Ideally,
elimination – withdraw the substance from use (and local purchasing controls to prevent staff
ordering the substance in the first place). Alternatively, reduce – find an alternative substance that
will do the job but is less hazardous. Other control measures may include:
allowing only competent personnel to handle the material;

containing it in fume cupboards;

adequate ventilation;

personal hygiene (not eating, drinking when using substance);

issuing appropriate personal protective equipment (PPE) – this is regarded as a last resort
where adequate control cannot be achieved by other reasonably practicable means;

provision of appropriate information, instruction and training.
Purchasing New Substances
COSHH assessments should be carried out before purchasing substances not previously used or in
a process not carried out before. The safety data sheet must be obtained from the supplier before
purchase and an assessment carried out. The least hazardous suitable substance available should
always be purchased.
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Emergency Arrangements
If, in spite of the use of control measures, leaks, spills or uncontrolled releases of hazardous
substances could still occur. Suitable means should be available to limit the extent of risk to health
(and pollution of the environment) and to enable adequate control to be regained as soon as
possible, e.g. establish emergency response and disposal procedures, provision of adequate PPE.
Workplace Exposure Limits (WEL)
What is exposure?
Exposure to a substance is uptake into the body. The exposure routes are:

By breathing fume, dust, gas or mist

By skin contact

By absorption

By swallowing
Many thousands of substances are used at work but only about 500 substances have WELs listed in
'EH40 workplace exposure limits'
In practice schools are unlikely to have many products with a WEL. Where any products are used
you are advised to in the first instance to try to eliminate their use.
In relation to WELs you must ensure that ‘adequate’ control of exposure is implemented. Where
listed substances are used, EH/40 Workplace Exposure Limits must be checked and suitable
exposure monitoring must be instigated where this is ‘required so as to be sure that a WEL is not
exceeded’.
For example well controlled (effectively extracted) wood dust may not necessitate exposure
monitoring however woodworking that generates dust where LEV is absent or has been found to be
ineffective would require exposure monitoring (e.g. air sampling or personal sampling)
Maintenance, Examination and Testing of Controls
You must ensure that control measures are maintained, examined and tested as required by the
COSHH assessment, for example:

Visual checks of equipment – e.g. weekly;

Observations of staff following procedures or using equipment and PPE to ensure compliance
– e.g. during audits, inspections, lesson observations etc. at various frequencies;
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
Local exhaust ventilation (LEV) e.g. fume cupboards, dust extraction systems – at least once
every 14 months;

Respiratory Protective Equipment (RPE) - every 3 months if little used, monthly if regularly;

Inspection of PPE – on a risk basis depending on duty/wear rates established from
observation and manufacturer’s information;

Servicing intervals for equipment – generally in line with manufacturer’s guidelines;

Locally created records of examination and tests should be kept and available for inspection
for at least 5 years.
Manufacturer’s recommendations for care and use of PPE should also be followed.
Working procedures should be reviewed periodically to confirm they are still appropriate and
workable and whether they can be improved. For example small scale and irregular use of spray
mount adhesives may have become more commonplace necessitating use of an extraction booth.
Exposure Monitoring
Where the risk assessment has concluded that routine ongoing exposure monitoring is required, it is
the line manager’s responsibility to ensure that it is undertaken at the prescribed intervals.
It may be enough to inspect and test control measures alone, provided that this has been done
diligently. This will probably include monitoring to ensure compliance with standards as well as the
effectiveness of the control measures themselves
In many instances complex exposure monitoring such as air sampling or personal sampling will not
be necessary where control measures are clearly and demonstrably effective – for example in
woodworking areas where the dust extraction system (LEV) is effectively capturing wood dust and
the LEV system is used and maintained appropriately. In this instance as an additional check a
strong lamp in a darkened room may further indicate how effective dust capture is.
Records of all routine ongoing monitoring results, by activity, must be kept with the relevant
assessment. Where exposure levels in relation to Occupational Exposure Limits are concerned,
detailed information can be found in HSE publication EH40 Workplace Exposure Limits which
continues to provide the supporting guidance and a list of occupational exposure limits. Occasional
supplements to this book are issued and reference should be made to the HSE website searching
on ‘COSHH’.
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Health Surveillance
The use of some substances may require the health of users to be monitored to ensure that no illhealth effects are occurring. Areas where additional health surveillance may be specified are:
respiratory sensitisers (isocyanates);

skin sensitisers;

carcinogens (cancer causing substances);

herbicides (weedkillers).
The level of health surveillance may be:
medical examination and test;

questionnaire;

self examination (after appropriate instruction);

supervisor examination;

reporting symptoms.
Training for employees working with substances hazardous to health
Provide information, training and instruction for employees who work with substances hazardous to
health. This includes cleaning and maintenance staff.
Employees need to understand the outcome of your risk assessment and what this means for them.
Tell them:

what the hazards and risks are;

Any control measures identified, and what users MUST do i.e. wear any PPE identified or
comply with other controls;

about any workplace exposure limit;

the results of any monitoring of exposure;

the general results of health surveillance;

what to do if there is an accident (e.g. spillage) or emergency;

Ideally eliminate the use of, or substitute substances that could lead to health surveillance.
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Employees should have access to safety data sheets and the COSHH assessments.
Keep employees informed about planned future changes in processes or substances used.
When a contractor comes on site, they need to know what the risks are and how you are controlling
them if they are likely to be exposed to any substances used or stored on site. Also you need to
know if they are bringing hazardous substances onto your premises, and how they will prevent harm
to your employees.
Ensure you keep training records.
Contractors
Contractors must practice the same standard of care. Arrangements for compliance with the
obligations imposed by the COSHH Regulations should be determined clearly at the pre-tendering
stage of any contract.
Storage and Security
For most substances, unless it is released or used, it does not present a risk to health and safety. A
well designed and properly used storage facility, and the segregation and separation of incompatible
hazardous substances should therefore present a low risk.
Store rooms/areas should be secure and warning signs used. They should be regularly reviewed to
avoid unnecessary accumulation.
The bulk quantities of petroleum spirits, highly flammable solvents and compressed gas cylinders
should be stored outside the main building i.e. in the suitable ventilated storage facilities in
compliance with HSE guidelines.
Review of Assessments
All COSHH assessments should be reviewed by a competent COSHH assessor at or before the
planned review dates as specified in the assessment.
A review might also be prompted by circumstances such as:
part of an accident or ill health investigation where hazardous substances are involved;

a change to the substances (e.g. supplied as powder instead of granules);

evidence that existing control measures are inadequate;

Notification from the supplier that the chemical composition has changed via revised hazard
data sheets.
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Good practice advice on controlling chemicals is available at the HSE's COSHH Essentials
website:
http://www.coshh-essentials.org.uk/
and
HSE
guide
http://www.hse.gov.uk/pubns/indg136.pdf

PLEASE NOTE
Prepared assessments for science and design technology substances in Secondary and Middle
schools are provided by CLEAPSS (Consortium of Local Education Authorities for the Provision
of Science Services) which the LA subscribes to.
In science these take the form of the CLEAPSS Recipe Book; for design technology it is an A4
book, ‘Risk Assessment for Technology’.
If your school does not have these documents contact the Schools Health and Safety Advisor at
County Hall.
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