COSHH regulations impose duties on employers to demonstrate due care and attention regarding employee health, by ensuring that suitable and sufficient COSHH risk assessments are undertaken.
Any workplace with five or more employees must record its COSHH risk assessment. However, all workplaces are advised to do so regardless of staff numbers, in case of need for future reference and to help with ongoing safety improvement plans.
It's important to note that a proper risk assessment is far more than just an 'on paper' exercise.
Depending on the environment, it will commonly involve specific activities such as scientific monitoring of air quality for the presence of hazardous substances (used or generated, including dust and particulates), ensuring levels remain within any stated WEL values.
Like any health and safety assessment, a COSHH assessment should begin with a thorough walk-around observation of all areas and processes in the workplace, including waste storage and disposal systems.
In doing so, be aware of the difference between a 'hazard' and a 'risk' – a hazard is a source of potential harm, whereas the risk is the likelihood of that harm occurring.
In conducting a comprehensive risk assessment, employers should take all of the following steps. The aim is to identify any situations, products or activities (directed or otherwise) that may cause harm:
- Walking around the workplace and observing processes and behaviours
- Examining accident, incident and near-miss records, even under previous ownership where applicable
- Listing all substances and products used or generated in the workplace, and gathering as much information as possible on each substance and the risks associated with them
- Looking at the information on labels, in suppliers' catalogues, and on material safety data sheets
- Contacting the substance supplier
- Speaking to an independent consultant
- Gathering feedback and perspective from employees (include both experienced and newer staff wherever possible)
Once potential hazards have been identified, the next stage involves building an understanding of how harm may come about, and precisely who is at risk in each case:
- What are the potential uptake methods (spills, swallowing, breathing, injection) at each site?
- What would the effects of different types of exposures be?
- Who else might come into contact with a particular hazardous substance, besides the employee handling it directly? (Consider cleaners, maintenance workers and non-employees at risk through secondary exposure)
- How often, and for how long, are different employees exposed to varying levels of hazardous substances?
- What actions can lead to greater levels of exposure for some people than others? (Certain substances can pose a relatively minimal risk during transport or direct handling, for example, but a much higher risk during heating, mixing, cleaning or disposal)