The Control of Substances Hazardous to Health Regulations 2002 (COSHH) sometimes seem so complex they must surely be applicable only to a big business. This is not so: COSHH applies to all organisations.
Almost every business uses chemicals, even if just for cleaning, and the requirements of COSHH need to be considered. Expensive and unnecessary issues can arise if COSHH risk assessments and controls are not put in place, even small quantities of chemicals can lead to ill health or injury.
Risk assessment in COSHH is not just about reading the Safety Data Sheet (SDS). This is a common misunderstanding among SMEs. The SDS is an important document as it gives essential information, for occupational use, about the chemical, its health effects, toxicity, first aid, how it would react with other substances, storage, disposal, relevant personal protective equipment, and spill-handling procedures. However, it is not a risk assessment. Whether the chemical is a hair dye or an insecticide, it is necessary to look at the process involved, how the chemical will be used with other substances and any reaction that might happen. There is then the human element; how the frequency of use, as well as the training and awareness of those who will be exposed to the substance, will impact on the risk. These are all things that an SDS will not tell you.
The outcome of the risk assessment will normally lead either to the removal of certain elements of the risk or to putting controls in place. Controls need careful consideration. Small construction or cleaning companies may be involved in operations at several different client sites. This can create the need for careful selection of working methods and substances used, e.g. Having to store or use chemicals in areas difficult to access can make the risk greater than in other locations. COSHH controls, like all those relating to other health and safety aspects, need to be specific to individual projects. Generic approaches to risk controls can be beneficial for awareness and training but they do not replace the need to look at the specific approach.
There is a COSHH requirement that relates to the need to have arrangements in place for possible accidents, incidents and emergencies involving hazardous substances. This does not just mean first aid, although it is always worth checking that proper provision has been made for this: are there trained first aiders using proper equipment? It also includes reference to how spillages would be dealt with;
- Are there at least some staff trained to deal with spillages?
- Do they have the right personal protective equipment?
- Do they have the right materials or methods to clean up the spillage?
- How would the contaminated materials be disposed of legally?
These are all questions that need to be considered before the event; it is essential to act in an organised, effective way to avoid unnecessary safety and legal issues.
Any businesses using chemicals must comply with the regulations, using both the supplier information (Safety Data Sheets) and evaluating how the product will be used during the work activity and its environment will generate a robust COSHH Assessment, that must be communicated to the users and then monitored for compliance and continued suitability. Should you require further clarification or assistance compiling suitable and sufficient COSHH Assessments please speak to your Principal Health & Safety Advisor or call us on 01525 309 807.
