You may well know that CoSHH assessments are required by the Control of Substances Hazardous to Health Regulations. However, many organisations still think that a having a material safety data sheet on file is all that is required.
What are you using ?
The first step in complying with the regulations is to review what materials/chemicals are being used – even if these are proprietary brands bought form a local hardware store.
Once you have a full list of chemicals/substances, then make sure you have an up to date Material Safety Data Sheet for each chemical. The supplier of the chemical is obliged to provide you with one on request.
You will also need to keep this list up to date so think of an easy way for everyone in your organisation to update the list when a new material is ordered.
CoSHH assessment
The CoSHH assessment should include a review of the information on the material safety data sheet and also the application and frequency of use. The assessment should then identify and document the following areas:
- Identify the hazard – e.g. corrosives, irritants, toxic etc.
- What are the control measures – identify what control measures are in place currently – don’t forget if exhaust ventilation is required then make sure records of this are maintained and this is performed on an annual (not exceeding 14 months) basis.
- Do you need to use the material or could you use a less hazardous material? It is easy to forget this step but you are required by law to consider substitution/elimination of the material if it is hazardous.
- Do you need to consider additional control measures to comply with the recommendations in the data sheets? If so make a note of these and decide on a timetable to introduce the improved control measures.
Other things to consider
For more hazardous substances then you may need to do a more comprehensive assessment or even bring a consultant into to monitor and assess exposure levels. As a guide also ways review this need for any respiratory sensitisers, materials that can generate fumes or dust.
Check your equipment
An easy thing to over look but ask yourself – are the gloves or respirators you are using providing adequate protection? Is the extract system/Local Exhaust Ventilation (LEV) powerful enough? Information for the correct equipment to be used can all be found on the data sheet.
If you use LEV then you also need to pay attention to test records. These records by law should include the following information; extraction rates and confirmation that motors, ductwork, filters and alarms are working; operating performance of the LEV; testing methods used; details of any work carried out to adjust and test the LEV and; details and qualifications of the person carrying out the test. This is a statutory records must be kept for at least five years.
Don’t forget pregnant or nursing mothers
You may need to consider the needs of vulnerable workers in particular pregnant and nursing mothers. If a chemical has the risk code R40, R45, R46, R61, R63 or R64, then you will have to prevent exposure of any pregnant or nursing mother to the material. Don’t forget…Some chemicals are mutagenic which means that any women who may become pregnant should be made aware of the effects before potential exposure (this should include before they are pregnant).
HSE Resources
The HSE has some good resources to use – a summary guide to CoSHH can be down loaded here. HSE COSHH Guidance