A Guide To CoSHH Assessment
CoSHH assessment is a step-by-step process by which you should identify and reduce the impact that a hazardous substance can have on the operator or other people who may be affected.
I am writing this article based on two principles, one, I have worked as a CoSHH manager for tens of thousands of substances over many sites and two; I own a business which improves the process for the safe use of hazardous substances daily. I listen to companies, I listen to new issues and I develop solutions to these issues.
Here's a simple approach to CoSHH assessment that should work for everyone:
1. Identify what substances your company actually uses. Not the ones that are locked away or have no labels on (you can probably dispose of them) but the one's you use each day.
2. Put these substances into some sort of rational order such as most hazardous and most used first.
3. Get rid of substances that you don't use anymore off site (legally).
4. Check for similar groups of substances and see whether substitutes can be used or one substance which covers multiple purposes. Then you would have less substances to assess, this may then enable you to purchase the substances at a lower price.
5. Start at the top of your list and collect of manufacturer original Safety Data Sheets where possible.
6. Hand part one of the CoSHH risk assessment form to the operator or line manager (the person who actually knows how the substance is used). Do this for all of your substances. Your assessment needs to be task based, it's absolutely useless to assess a substance in isolation and it's dangerous!
7. Set a timescale to receive the completed Part one of the CoSHH risk assessment form back. People work better when they have targets.
8. Use part two of the CoSHH risk assessment form to identify what hazards there are. This could involve training, PPE, emergency procedures... anything!
9. Calculate the risk to your employees and business.
10. For significant risks, decide on the action needed to remove or reduce them to insignificant levels. You should consider the cost of safety controls against the amount of risk. It's far easier to approve something when it is financially realistic.
Employers are responsible for CoSHH assessment. Persons preparing to carry out Part 2 of the CoSHH risk assessment form will need to:
- Have access to, and understand, COSHH, related legislation, codes of practice and published guidance. - Be competent to carry through the work of assessment. It may be worth considering training with CIEH. Search for 'CIEH Risk assessment training' in a search engine. - Consult widely within the workforce and inform them of results accordingly. Substances hazardous to health include: - Substances classified as dangerous to health under the Chemicals Hazard Information and Packing for Supply (CHIP3) Regulations 2002. You will find several are documented in "The Approved Supply List" This is part of the "CHIP 3" Regulations - Substances with occupational exposure limits (these are specified in Guidance Note EH40 which is revised annually) - Biological agents - Dusts of any kind in substantial concentrations
Identification of hazardous substances can be found from:
- Hazard data sheets, labels etc. from suppliers (required by law) - Knowledge from within your business or industry; trade literature - Published guidance/documents - Part V of the Approved Supply List (HSE) The CoSHH Risk Assessment involves looking at: - Use, handling, generation, release etc. of hazardous substances - Who might be affected and likely exposure level/extent - The type or nature of the exposure (Skin absorption, Inhalation,Ingestion etc.) - Present control measures to manage/Prevent exposure - Accidental leakage, spillage or release - Cleaning and maintenance operations
For those people that use CoSHH Essentials to carry out CoSHH assessment, please be aware that you will only receive advice or guidance. CoSHH Essentials does not provide task based CoSHH risk assessments! You must do your tasked based CoSHH assessment once you receive their guidance information.
The manufacturer is the best source of information for a substance. If you have no luck with the supplier, speak direct with the manufacturer. If they do not help then inform them about Section 6.1 of the Health and Safety at Work Act and add that it's their legal duty to help. Please ensure you have read and understood their Safety Data Sheet first.
The CoSHH risk assessment produced is evidence of the assessment procedure with signatures on it, Therefore it is important that you keep your copy locked away safe.
REMEMBER: Once you have completed the CoSHH assessment process you must produce a CoSHH assessment report that is easy to read and straight forward. It's not good practice to show the investigation forms to the end user.
About the Author
Dale Allen delivers HSE CoSHH compliance as one of the UK's leading compliance authorities. Find out more about how you can use his online COSHH365 CoSHH assessment tool to produce compliant CoSHH assessments with the benefits of a managed Safety Data Sheet library.
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