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Introduction to COSHH

Introduction to COSHH

Chemicals and other hazardous substances can put people’s health at risk. The law requires that employers must control the exposure of their employees to hazardous substances in compliance with the Control of Substance Hazardous to Health (COSHH) regulations, which were first introduced in 1988. Since then there have been a number of changes to the regulations with the most recent update being in 2002, which was was amended in 2004. The main objective of the regulations is to reduce occupational ill health by setting out a simple framework for controlling hazardous substances in the workplace.

The Health and Safety Executive (HSE) have part of their website devoted to COSHH. They provide a free booklet describing guidelines to the COSHH regulations which can be downloaded here:

COSHH: a brief guide to the regulations

A general review of COSHH, and how it affects the Department of Physics, is given below.

What Does COSHH Require?

Complying with COSHH involves:

  • assessing the risks to health arising from hazardous substances at work,
  • deciding what precautions are needed,
  • preventing or adequately controlling exposure,
  • ensuring that control measures are used, maintained, examined and tested,
  • if necessary, monitoring exposure,
  • if necessary, carrying out appropriate health surveillance, and
  • ensuring that employees and non-employees (e.g. students) are properly informed, trained and supervised.

Hazardous Substances

In terms of the Regulations, a Substance Hazardous to Health is:

  • one that has already been classified as being very toxic (T+), toxic (T), harmful (X), corrosive (C) or irritant (Xi) under the Chemicals Hazard Information and Packaging (CHIP) Regulations.
  • or a substance which has been assigned exposure limits
  • or a substance that is carcinogenic, mutagenic or toxic to reproduction
  • or a biological agent,
  • or dust in substantial concentrations in air and
  • any substance not mentioned above but which creates a hazard to health comparable to those mentioned above.

Duties

As with all other regulations building on the Health and Safety at Work Act etc., legal duties under COSHH are laid primarily on employers and it is their duty to see that proper systems of work and management are in place.  In higher education, the “employer” is taken to be the governing body of the University. The responsibility of carrying out this duty is delegated to the Head of Department who, in turn, delegates the responsibility to managers and supervisors within the department.

Duties on employees include making proper use of any control measures, following safe systems of work, abiding by local rules and reporting defects in safety equipment.  Non-employees have no specific duties under COSHH but the requirements of the Health and Safety at Work Act etc. do apply, forbidding the misuse of anything provided in the interests of health, safety or welfare.

 Assessment

“Suitable and sufficient” assessment includes determining the hazardous substances that are likely to be encountered, thinking about the risks they present to health, asking how much and how often the substances are used, how hazardous they are and what are the exposure routes and finally deciding on the action needed to prevent exposure or to reduce it as far as is reasonably practicable.  This will also include the actions to be taken in an Emergency, to clear up any spills and to safely dispose of any residues. Except for the most trivial cases, the conclusions of this assessment must be recorded, made readily accessible and reviewed regularly.

In the Department of Physics we currently adopt the approach to COSHH assessment developed by the Royal Society of Chemistry, which involves the use of tables to determine the overall level of risk of the working activity involving hazardous substances.

Preventing or Controlling Exposure

Employers must ensure that the exposure of employees to hazardous substances is either prevented (i.e. no exposure) or adequately controlled.  This can be done by:

  • Preventing exposure by changing the process or activity so that the hazardous substance is not required or generated, or replacing it with a safer alternative (especially important if the substance is a carcinogen), or using it in a safer form. 
  • If prevention is not reasonably practicable, exposure must be adequately controlled by one or more of the measures outlined in the regulations e.g. total enclosure of the process, suitable ventilation etc. (If total enclosure is not practicable for a carcinogen then all the other methods of control mentioned in the regulations must be used.)

Note that adequately controlling volatile or airborne substances can be assessed by reference to the set Exposure Limits. Adequate control also means having systems in place to deal with emergencies, spills and disposal.

Only as a last resort should personal protective equipment be used as a means of protection.  (However, the routine wearing of laboratory coats and safety glasses is generally regarded as a basic measure to minimise risks from foreseeable hazards.)

Ensuring that Control Measures are Used and Maintained

Employees are required to make proper use of control measures (e.g. fume-cupboards) and to report defects and employers must take all reasonable steps to ensure that they do so.  Employers must also ensure that the equipment is kept in efficient working order and good repair and that it is tested regularly.

Monitoring Exposure and Health Surveillance

Monitoring of the concentrations of hazardous substances in the air must be carried out in certain circumstances e.g. where there could be a serious risk to health if control measures failed or deteriorated. 

Where the assessment has shown this to be necessary e.g. use of a substance known to cause occupational asthma or severe dermatitis, then health surveillance must be carried out.

Information, Training and Supervision

COSHH requires that employers provide their employees with suitable information, instruction and training about:

  • the nature of the substances they work with or are exposed to and the risks created by exposure to those substances and
  • the precautions they should take

Employers should give sufficient information and instruction on

  • control measures and how to use them,
  • the use of any personal protective equipment and clothing,
  • results of any exposure monitoring or health surveillance and
  • emergency procedures.

Carcinogens

Carcinogens are treated separately by COSHH with an individual Approved Code of Practice and the rules for their use are stringent. Their use requires justification, the use of all recommended control measures and record keeping.

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