Coshh - A Briefer History To Coshh Assessment
I have written this article so that employers can understand their general duties under the CoSHH regulations (2002)
. It will also be useful to safety people, health and safety professionals and other that are interested in health and safety compliance pertaining to the safe use of hazardous substances.
CoSHH stands for the Control of Substances Hazardous to Health which is a regulation that applies to every business in the United Kingdom. Some businesses believe that if they have less than five employees? they are immune from the CoSHH regulations which is not the case.
Your company will inevitably be using some products that contain substances. These products can be thinners, air fresheners, washing up liquid, lubricants and much much more. If you do use these then you need to adhere to the CoSHH regulations. The reason for this is because you may subject not only your employee but the public to any one of these substances and therefore there MUST be prevention of damage to health put in place.
As a basic example, imagine a decorator who is painting a home working as a sub contractor for a larger enterprise. The decorator mixes white spirits with the paint he is using to help thin the paint before application. This process is something a decorator carries out as an everyday task.
Here are the possible risks to health from this process:
1. There is the risk of dermatitis being caused due to the decorator not wearing suitable hand protection from the white spirits mixed with the paint. The Safety Data Sheet for paint may say that it is non-hazardous; however the manufacturer and provider of the SDS did not take into account the use of the thinners and has no legal obligation to do so.
2. The decorator may leave white spirits or paint lying about the home of the customer and this may come into the hands of a child.
3. Being white spirits is extremely flammable we must protect it from coming into contact with a naked flame. Does the decorator smoke?
This is why we must risk assessment and in this specific case produce a CoSHH assessment. CoSHH risk assessment is unique and must be treated separately from all other forms of risk assessment that a business would do under the requirements of the Health and Safety at Work Act. This is why chemical risk assessment has its own regulation so that it can be treated as a different animal.
There is no requirement to be qualified to produce a CoSHH assessment. In fact there is no legal quality standard that a CoSHH assessment must follow. The reason for this is because if you have a CoSHH assessment and an accident occurs then is has failed and it wasn't good enough. Thereafter there will be repercussions the extent of which will be decided on the reasonable controls that where put in place to prevent the incident occurring.
So the premise is that if you produce a CoSHH assessment, you must produce the best CoSHH assessment you can. If you do not you may receive heavy fines both to the company and personally with the potential of imprisonment for severe breaches of the regulation for Directors' or the offending party.
Remember ignorance will not be tolerated by the Health and Safety Executive! If you are going to take on the responsibility of producing CoSHH assessments for your business then you must understand both the task that is being performed by the operator and the substance that is being used. The substance and the environment it is used in must be considered when making the task safe through CoSHH risk assessment. I recommend that you at least take a basic risk assessment course so that you can become familiar with assessment. By doing this you will under the risked that are present and be able to put sufficient control mechanisms in place.
If you have many chemicals and many processes that are being carried out DO NOT be tempted to download template assessments from assessment vendors. This is not only frowned upon by the Health and Safety Executive but is a significant risk to the operator who may be carrying out a task differently. The person who produced the assessment you downloaded may not know that the decorator was using white spirits as a thinner or possibly any of the other substances the use during their working day or even at home. This is why the risk assessor must have seen the process, must have spoken with the operator so that all risks can be assessed as they are and not as they are assumed to be.
DO NOT let a simple solution land you with heavy fines, damage the health of your workers or land you behind bars. You should produce your own CoSHH assessments or seek professional advice from an on site consultant to carry out the CoSHH assessments.
It is advisable that you find a CoSHH management solution to help control your CoSHH assessments and to remind to you to periodically review each of your assessments. If something in the process changes then a CoSHH assessment needs to be reviewed. If a Safety Data Sheet is updated by a manufacturer then you MUST have the latest copy and you MUST review your CoSHH assessment.
There are online service providers that can provide management solutions to help you control your CoSHH compliance. CoSHH is a specialist subject to it is advisable that if you don't know, then ask!
If you have read this article and you do not have CoSHH assessments in place and they have not been provided to your workers, then take it from me that you are doing something very wrong. If you think that your business does not use hazardous substances then think again, even in an office products are used that contain chemicals and you would be surprised what your workers can get up to with them!
The Health and Safety Executive are seldom surprised because they've seen it and heard it all before. Did you know that flour dust and poor ventilation led to a school chef developing severe asthma? No? Well you probably wouldn't have thought of that unless you'd carried out an assessment and this claim would have cost you 200,000 in compensation.
So, please think again, do you really use hazardous substances?
by: Dale Allen
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