INTRODUCTION TO COSHH SAFETY

What is COSHH?

COSHH is an acronym standing for Control of Substances Hazardous to Health.

It's an important branch of health and safety legislation, and like most official H&S protocols it's built around a clearly defined legal framework – namely the Control of Substances Hazardous to Health Regulations 2002 (updated in 2004).

The law states that employers are required to prevent, reduce or (at the very least, where total prevention or significant reduction are unfeasible) control their workers' exposure to hazardous substances for the protection of their health.

Awareness of issues around COSHH is a key part of any coherent health and safety approach, whether in the workplace or at home.

Awareness of general hazard types

Running almost any type of workplace today will typically involve some form of substance that, if used incorrectly or without the proper precautions in place, is potentially hazardous to the health of staff and/or the public.

Hazardous substances and materials may be present in many different physical forms. Manufacturing paints and sprays, biological waste, chemical disinfectants in cleaning or treatment environments, printing solvents, silica or metal residues from heavy industry, machined sawdust, and even bakery flour are all common examples of substances that fall under COSHH regulation.

The full list includes:

Chemicals and chemical-containing products
Substances liable to cause harm on direct skin contact
Nanoparticles
Fumes (metal, rubber, solder)
Gases, including asphyxiating gases (e.g. chlorine, carbon monoxide)
Vapours and mists (particularly of solvents, isocyanates, and irritants such as acids)
Dusts and powders (wood, cement, silica, flour)
Germs and other biological agents
Fibres (such as glass or ceramic fibre)

Exposure to any of the sorts of substances listed above can be harmful in a variety of ways, depending on the uptake method (the route a harmful substance takes into the body). The main potential uptake methods are inhalation, skin contact, injection and ingestion (swallowing).

Basic safety approaches

The crux of any sensible, legal and responsible approach to COSHH safety will always involve the following key steps:

Understanding COSHH regulations
Assessing exposure
Controlling exposure
Monitoring and reviewing protocols
Educating workers
Planning for emergencies

The rest of this guide will cover each of the above steps in more detail.

UNDERSTANDING COSHH REGULATIONS

The COSHH Regulations 2002 introduce a number of separate rules and guidelines that apply to all workplaces in addition to the existing General Health and Safety Legislation.

Breach of these regulations by an employer is a crime, punishable by an unlimited fine. Conviction can apply either to individuals or to entire corporations.

Substances directly identified as COSHH concerns in the regulations include all materials classed as toxic, very toxic, corrosive, harmful or irritant. In addition, biological agents and dusts in substantial concentrations are also covered by the regulations.

Eight core principles

The Regulations are based on eight core principles, which apply to all employers regardless of whether a particular substance being used has a Workplace Exposure Limit (WEL).

The key principles and obligations for employers are broadly defined as follows:

Assess the risks to health of hazardous substances used in or created by all workplace activities
Decide what precautions are needed, and do not carry out work that could expose staff to hazardous substances without ensuring full COSHH compliance is in place
Prevent or adequately control exposure employee exposure
Ensure control measures are used and maintained 24/7 and at all stages of production
Monitor exposure levels and continually amend processes, safety guidelines and responses as necessary
Carry out appropriate health surveillance in response to risk assessment or specific COSHH requirements
Prepare plans and procedures in case of accident or incident, including a suitable and well-drilled emergency response protocol
Ensure all employees are properly educated, trained and informed, providing them with all the latest information on new products, systems and potential risks

Workplace Exposure Limits (WELs)

As part of the updated COSHH Regulations, a new system of Workplace Exposure Limits (WELs) has now replaced the former Maximum Exposure Limits (MELs) and Occupational Exposure Standards (OESs).

Regulation 7 of the COSHH framework states that an employer's control of exposure may only be deemed adequate if the Workplace Exposure Limit (WEL) for any given substance is not exceeded.

The WEL value of a potentially hazardous substance is expressed as a time weighted average (TWA), and there are two variations:

Long-term Exposure Limit (LTEL) – the maximum level of exposure permitted in an 8-hour period. LTEL limits are designed to reduce the risk of harm from cumulative exposure, where chronic ill-health conditions arise from daily uptake of hazardous substances in smaller doses.
Short-term exposure limit (STEL) – the maximum level of exposure permitted in a 15-minute period. STEL limits typically relate to 'peak exposure' incidents, and are designed to protect against any acute ill-health effects caused by sudden and more direct exposure to higher concentrations of hazardous substances.

Important: not all chemicals used in the workplace have defined WEL values, but this doesn't mean they're not hazardous.

The sheer number and diversity of products being used in workplaces today makes it impossible for a truly definitive, up-to-the-minute list to exist at all times, but new substances are frequently added and revised in regular edits and supplements to the HSE's core EH40 Workplace Exposure Limits handbook (see resources section).

Although COSHH Regulations are complementary to the CLP Regulation on chemical labelling, it's also important to remember that not all potentially harmful substances will necessarily carry a hazard warning label. Many substances that are technically classed as non-hazardous can quickly become COSHH concerns if used incorrectly or without due care.

ASSESSING, CONTROLLING AND MONITORING COSHH SAFETY AT WORK

ASSESSING

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 round 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 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 relatively minimal risk during transport or direct handling, for example, but much higher risk during heating, mixing, cleaning or disposal)

CONTROLLING

Controlling exposure and risk through COSHH is about putting your risk assessment observations into a coherent plan of action.

This in itself is a three-stage process:

deciding on necessary precautions
preventing or limiting exposure
ensuring safety measures are used and maintained

In working out which precautions will be necessary, it's useful to consider 'What?, Where?, Who?, When?, and Why?':
What processes are being undertaken, and what hazardous substances are being used, generated and recorded on safety sheets?
Where are these activities taking place, and how might the immediate workplace environment be reducing or exacerbating risk to staff and other people?
Who is carrying out specific actions? Are they fully trained to do so, and do they understand the risks?
When are exposure-related activities taking place – how often, and for how long? Are there regular peak exposure times that might require additional measures?
Why are potential exposure levels higher than they could be, and is there a practical way to make changes to reduce them?

Once you've identified which precautions will be important to take, it's time to move on to implementing these controls to reduce exposure levels. This can be done in various ways, listed here in order of most to least preferable/effective:

A) Eliminating the source of the risk/hazard

The ideal solution when dealing with COSHH issues is to remove the source of the hazard entirely
In many cases this will be impossible, as the substance or practice concerned will be central to the job at hand
However, it's always worth questioning whether a specific product or process is absolutely essential to arriving at the end goal

B) Substituting hazardous substances to lower risk levels

Where elimination isn't practical, substitution might be the next best option
Are there different substances or systems that can be used to achieve similar effects at lower exposure risk?
Be aware that any substitutions made can potentially introduce new hazards, and should also form part of a risk assessment update

C) Improving infrastructure, processes or systems

If a workplace can't feasibly eliminate OR substitute hazardous substances, changing and improving the ways they're physically handled or used should be the aim of any control measures
Engineering-based updates to working practices might involve looking at such areas as modification of machinery, automation of certain processes, better isolation of hazardous materials and tasks, or improvements to the physical environment (e.g. improving ventilation or disposal systems)

D) Administrative changes for better hazard management can often help reduce risk among staff. This might include such measures as:

working out improved shift patterns to achieve lower exposure times or more continual supervision
publishing risk-related rules and guidelines more visibly to achieve greater general awareness
greater provision of frequent training sessions and courses to help employees retain up-to-date knowledge and skills

E) Personal Protective Equipment (PPE) supply and monitoring
Although equipping staff with all necessary clothing and tools for physical protection is a legal requirement in most workplaces, it's important for employers to remember that this is always a last line of defence

It is not a substitute for optimal practice and procedure elsewhere, and does not transfer full responsibility for safety management to the wearer
Supply of PPE can also be significantly more expensive in the long-run than other engineered or administrative safety measures, as items will need to be repaired and replaced on a regular basis
Any PPE supplied must be suitable for both the task and the wearer to be effective, and always paired with ongoing education and monitoring regarding its proper use

MONITORING AND REVIEWING

After the risk assessment has been done, measures to control exposure levels have been identified, and practical steps to improve COSHH have been taken, it's important to maintain a system of regular checks and balances to ensure that safety management continues to be effective.

A key element in this is keeping risk assessment and safety knowledge up to date.

New products or systems are continually introduced into manufacturing processes that, while often lowering a specific area of risk, can frequently introduce new potential hazards of their own.

Good times to update or re-run an assessment include:

Annually, as part of a regular schedule
Whenever changes are made to design or suppliers of tools and machinery
Whenever a new substance or chemical is introduced
Whenever an existing substance is modified, updated, or new information on it becomes available
Before and after changes to processes or workflow
During relocation to new premises, or physical alterations to a work area or environment
As newer staff are hired, or responsibilities transferred
Before starting a new project or product line

Another hugely important stage in the ongoing monitoring process is giving and receiving feedback on worker behaviour regarding COSHH practices.

It can prove difficult to encourage workers to abide by best practice guidelines, particularly when introducing more experienced staff to new protocols. To combat this, it's crucial to make employees feel more invested in defining and upholding safety measures. This can be helped by:

Directly involving them, through regular consultation, in the design of machinery, products and safety systems wherever possible
Publishing and displaying rules and guidelines very visibly, and providing regular training updates
Ensuring there is always adequate supervision available in the immediate environment
Strict logging and archiving of all records regarding equipment use, maintenance or replacement, employee requests or concerns, and full incident reports
Frequently reviewing procedures and protocols – again, with direct employer input – to ensure checks and supervision systems don't feel excessive or outdated

Health surveillance

Health surveillance is a system of ongoing health checks for employees that can be extremely important in certain types of workplace.

Some types of regular health check are required by law for employees who are unavoidably exposed to substances or environments hazardous to health.

Health surveillance is important for:

detecting ill-health effects at an early stage
providing data to help employers evaluate risk
enabling employees to raise concerns health at work
highlighting lapses in control measures for improved risk assessment
providing an opportunity to back up staff training and education programmes

Important notes on health surveillance:

It is not a substitute for a comprehensive risk assessment
It should be specifically targeted, not used in a 'blanket coverage' approach - this is costly and can yield misleading results
As a legal requirement, it should not be confused with general health-monitoring activities in cases where work-related health effects are suspected but unestablished
It should not be confused with general workplace wellbeing programmes and initiatives (exercise, mindfulness, diet etc)
It is unrelated to other legal obligations in line with specific 'fitness to work' requirements, including relevant tests for drivers and machine operators

Training and educating workers

Full, certified training should be given to all workforces involved in procedures that could potentially result exposure to harmful substances, either directly or through proximity/secondary contact.

The core aims of training sessions and courses should be to give all employees:

An understanding of which workplace substances be hazardous to health, and how
Up-to-date knowledge and clear definitions of exposure limits
The skills to understand exposure issues, and to conduct COSHH risk assessments for their own individual areas and tasks
A greater understanding of practical control measures and safer methods of working

It's also vital to provide full training on the importance, correct use and maintenance of any PPE equipment supplied, including respirators, protective gloves, eyewear, and all clothing. Be sure to include guidance on:

What constitutes an effective and comfortable fit
How to spot and report issues or problems with PPE
Whether it requires any regular user maintenance or cleaning
Whether it potentially introduces any new hazards of its own

You'll find some useful, officially certified training options in the links and resources section at the end of this guide.

Emergency planning

Emergency planning should be carried out as part of an overall risk assessment strategy. The key elements of a good emergency plan are:

Identification of different potential emergency types (e.g. explosion, flooding, leaks and spills), and devising of a suitable response process for each case
Publication of clear, visible, and universally understood procedures to be followed in the event of an emergency – including nomination of competent persons and assignment of specific responsibilities, instructions on raising an alarm, location and use exits or escape routes, location of assembly points, protocol for contacting emergency services, and evacuation of disabled persons
Assigning specific responsibilities to competent persons, all of whom have formally agreed and are aware of their role, and have been fully trained to perform it using the most recent systems and equipment in place
Keeping accurate, up-to-date, accessible maintenance and instruction logs for all alarms, backup systems and other emergency equipment
Outlining of any potential risks posed to non-employees (e.g. other building users, nearby businesses or members of the public), and identification of measures to mitigate these risks
Regular scheduling of training updates and drill sessions

COSHH LINKS, DOWNLOADS AND RESOURCES

General guides and further information

A brief guide to COSHH safety – HSE overview
www.hse.gov.uk/pubns/indg136.pdf

Warehouse storage COSHH safety – HSE overview
www.hse.gov.uk/pUbns/priced/hsg76.pdf

CLP Regulation on chemical labelling – HSE overview
http://www.hse.gov.uk/chemical-classification/legal/clp-regulation.htm

Hazardous substances labelling
https://www.onsafelines.com/qhse/qhse-support/index.htm?context=412

Table of new hazard labels
https://www.onsafelines.com/qhse/qhse-support/index.htm?context=413

Risk assessment

Example COSHH risk assessments for various business types
http://www.hse.gov.uk/coshh/riskassess/index.htm

Operation-specific risk assessment tool
http://www.coshh-essentials.org.uk/unit-operations.asp

A Step-By-Step Guide to COSHH Assessment – HSE handbook
http://www.hse.gov.uk/pubns/books/hsg97.htm

Monitoring and control

EH40 Workplace Exposure Limits handbook – HSE handbook
http://www.hse.gov.uk/pubns/books/eh40.htm

Construction dust: Controlling the risks
http://envirocare.org/Construction-Dust-Controlling-The-Risks

Isocyanate exposure in the workplace: Monitoring and control
http://envirocare.org/isocyanate-exposure-workplace

Plastic fume exposure monitoring
http://envirocare.org/plastic-fume-monitoring-exposure

HSE guide to respirator types and uses
http://www.hse.gov.uk/pubns/guidance/rseries.htm

Guide to glove types, uses and fitting
https://uk.rs-online.com/web/generalDisplay.html?id=solutions/gloves-guide

HSE Health Surveillance Cycle
http://www.hse.gov.uk/health-surveillance/assets/documents/health-surveillance-cycle.pdf

Training

COSHH safety symbol quiz
https://rospaworkplacesafety.com/2014/04/08/what-is-coshh-quiz/

HSL training (various topics and areas)
https://www.hsl.gov.uk/training.aspx

IOSH training (various topics and areas)
https://www.iosh.co.uk/Training.aspx

BOHS training (various topics and areas)
http://www.bohs.org/qualifications-training/bohs-endorsed-courses/

Royal Society for the Prevention of Accidents – COSHH Training
https://www.rospa.com/safety-training/work/ra/coshh-training/

ROSPA-approved online COSHH training
https://newskillsacademy.co.uk/course/control-substances-hazardous-health-coshh-training/

HSE-compliant training modules for COSHH
http://www.procoshh.co.uk/

Emergency planning

A Guide to the Control of Major Accident Hazards Regulations (COMAH) 2015 – HSE handbook
http://www.hse.gov.uk/pubns/books/l111.htm

Understanding COMAH: A guide for new entrants
http://www.hse.gov.uk/comah/guidance/understanding-comah-new-entrants.pdf

Understanding COMAH: A guide for operators
http://www.hse.gov.uk/comah/guidance/understanding-comah-operators.pdf

COMAH notification form
http://www.hse.gov.uk/comah/notification/comah-notification-form-v2.3.xlsx

Miscellaneous

Free HSE leaflets on numerous aspects of COSHH management
http://www.hse.gov.uk/coshh/further/publications.htm

COSHH case studies and examples
http://www.hse.gov.uk/coshh/casestudies/index.htm

HSE workplace full product catalogue 2017-18
https://books.hse.gov.uk/gempdf/HSE_Catalogue_2017-2018.pdf

HSE COSHH-specific publication catalogue
https://books.hse.gov.uk/COSHH/

A Practical Guide to COSHH Safety