COSHH (The Control of Substances Hazardous to Health)
What is ‘COSHH’, What ar the main risks arising from hazardous substances and how should I control them?
When we refer to hazardous substances, we are talking about either chemical agents, (which exist as liquids, gases, vapours, mists, fumes or dusts) or biological agents (fungi, bacteria or viruses).
The CHIP 3 (Chemicals (Hazard Information and Packaging for Supply) Regulations) deal with how substances should be classified and how hazard information should be communicated to users via safety data sheets. These regulations also require that all chemicals supplied are assessed as to whether they are inherently dangerous and if so that a ‘Category of danger’ is identified and a ‘Risk phrase’ or description of the hazard allocated. ‘Categories of danger’ define substances, for example, as ‘TOXIC’, ‘CORROSIVE’ or ‘IRRITANT’ which in turn dictate the type of square orange labels that appear on packaging.
Hazardous substances enter the body via certain ‘Routes of entry’. These may be by inhalation, ingestion (via mouth, stomach and intestines), absorption (through the skin or eyes), aspiration (where liquids or solids enter the lungs) or injection.
Adverse health effects range from relatively minor problems such as headaches and nausea, through to life-threatening illnesses such as cancer. They may be acute (taking effect within seconds, minutes or hours) or chronic (over months or years). Chronic effects may present particularly challenging management issues, simply because the time delay prior to symptoms becoming evident may encourage a false sense of security.
The COSHH regulations require employers to take certain actions to limit the exposure of employees to hazardous substances. For example Workplace Exposure Limits (WELs) are concentrations of a hazardous substance in air, averaged over a specified time period, which must not be exceeded.
A COSHH risk assessment must be carried out and exposure must be reduced to as low a level as is reasonably practicable. Regulation 7 clearly states that control of exposure to hazardous substances will only be treated as adequate if the ‘Principles of good practice’ have been applied.
The risk assessment involves both the analysis of risk present in the workplace and a critical evaluation of existing control measures. A decision is then required as to what improvements or additional controls may be necessary to reduce the level of risk.
Both the Management of Health and Safety at Work Regulations and the COSHH Regulations require the application of a hierarchy of control:
1. Eliminate the hazard, possibly by replacement with materials that do the same job, but present no risk to health.
2. Use physical or engineering controls such as enclosure or segregation that reduce risk at source and provide general rather than individual protection.
3. Apply controls to the individual by job design, process change, reduced time exposure or, as a last resort, use personal protective equipment (PPE).
In practice a combination of the above measures will usually be necessary.
Finally, a regime of health surveillance and monitoring should be implemented. This will comprise measures ranging from medical observation and testing (including pre-employment health screening) to workplace monitoring and ongoing self examination. In addition supervisors should carry out regular checks to ensure that controls are being observed by those at risk, or whose delegated duties involve the management of control measures.
It is important to ensure that all controls are proportionate to the risk and that they comprise practical measures that will be applied and observed. Whilst, theoretically, a risk assessment of a bottle of Tippex may be required, this should be balanced against the likely adverse health effects consequent upon its use, not to mention the equally likely and justifiable cynicism of the workforce!