The Ultimate Guide to COSHH Management
How to build a successful COSHH chemical management system
Download The Ultimate COSHH Management Guide:
Part B delves into eight key steps of building a COSHH management system.
Part C covers the important elements in creating and writing COSHH assessments.
After reading this guide you should have a better understanding of how to control the hazardous substances in your workplace, so they don’t cause harm or health issues to employees.
It will give you a better understanding of the COSHH Regulations 2002, why they are in place and what you must do to comply
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Are you aware of all the chemicals in your workplace? Do you know the potentially harmful effects they may have? Do you have relevant protection methods in place in terms of control measures and PPE to safeguard yourself or fellow staff members?
In your place of work do you have:
- cleaning products
- oils or lubricants for machines
- paints and adhesives
- chemicals that you process
- hidden chemicals
If you answered yes to any of the above you need to comply with the COSHH Regulations. Some chemicals are classified as hazardous and can be extremely harmful. Our job is to identify these chemicals and ensure control measures are put in place.
The term COSHH stands for 'Control of Substances Hazardous to Health'. COSHH is the law that requires employers to control substances that are hazardous. In particular, the COSHH identifies chemicals that are hazardous to health. Although most companies will also identify chemicals which have physical or environmental hazards associated with them as well. COSHH is applicable to the UK market and comes from the following Regulation:
COSHH Control of Substances Hazardous to Health Regulations, 2002.
An employer has the following responsibilities under COSHH:
- Implement control measures to protect workers from hazardous substances.
- Prevent or adequately controlling exposure to hazardous substances.
- Provide employees with suitable and sufficient information, instruction, training and appropriate protective equipment where necessary.
- Ensure that control measures are maintained, kept in full working order and in a clean condition where appropriate.
- Drawing up plans and procedures to deal with accidents and emergencies involving hazardous substances.
- Ensure that any employees exposed to hazardous substances whilst at work are under suitable health surveillance.
- Ensure that substances do not exceed the Workplace Exposure Limit (WEL).
- Carrying out a COSHH Risk Assessment.
An employee also has responsibilities they must adhere to:
- Make use of control measures and facilities provided by the employer.
- Ensure equipment is returned and stored properly.
- Reporting defects/insufficiencies in control measures
- Wearing and storing personal protective equipment (PPE)
- Removing PPE that could cause contamination before eating or drinking
- Making proper use of washing, showering and bathing facilities when required
- Maintaining a high level of personal hygiene
- Complying with any information, instruction or training that is provided
Chemicals may be present as dust, liquids, gases etc. There is four main routes of exposure:
- Absorption – skin/eyes
Which can cause harm in two ways:
• Direct effects at point of contact
• Absorbed into the body
Breathing in contaminated air is the most common way that workplace chemicals enter the body. Chemicals may be in the form of gases, vapours, dusts or mists. Once chemicals are breathed in, they can enter our lungs and from there be absorbed into the bloodstream.
Different chemicals can target different organs.
Absorption can occur through skin or eye contact. Some chemicals, by direct or indirect contact, can damage the skin/eyes or pass through them into the bloodstream. Broken, cut or cracked skin will allow substances to enter the body more easily. Sometimes rashes can occur, and skin irritations may develop over time through frequent use. Symptoms can be acute and sometimes chronic.
Do you have safety steps and procedures at your organisation if someone gets a chemical in their eye in your workplace? Timing is everything in such a serious situation. Having eye wash stations and procedures to assist injured employees, in an efficient and helpful manner relevant to their location, is crucial.
This route of exposure - ingestion through the mouth - is one that people often dismiss as something not likely to happen. However, workplace chemicals may be swallowed accidentally if food or hands are contaminated e.g. smoking cigarettes that have come in contact with a chemical or unclean hands.
Substances can be absorbed into the blood and then transported to the rest of the body.
A key topic to mitigate against such serious safety incidents like this, is to have a workplace policy and culture in the organisation to wash hands frequently and thoroughly. In addition, staff should be informed of the correct methods for donning and doffing gloves.
Injection can occur when a sharp object (e.g. needle) punctures the skin and injects a chemical directly into the bloodstream.
Safe handling practices for working with sharp objects should be implemented in the workplace. The steps to be taken if someone accidentally inoculated themselves with a sharp object should be communicated to all staff.
How do we know which chemicals are dangerous and which chemicals are not? This information is attained in the classification system. As you may be aware in 2015 the classification system for chemicals changed from the old CPL/CHIP to the new CLP Regulations which is part of the Globally Harmonised System of classification. As the name outlines the aim is to have a unified system used worldwide to give a common understanding. The old-style orange/yellow square symbols have been replaced by red bordered diamond pictograms.
This chart outlines what each pictogram means and the associated hazard.
The classification is broken into three categories, health hazards, physical hazards and environmental hazards.
When doing COSHH assessments we need to be aware of the hazards of the chemicals. Staff should be aware of the hazards and be able to easily identify them from the pictograms.
A chemical may have multiple hazards and pictograms associated with them. These combine to form the classification of the chemical.
The classification information for the chemical can be found in section 2 of the safety data sheet and also on the product label.
1. Develop a Chemical Safety (COSHH) Policy
From over 20 years’ experience working with over 6,000 clients, we have learned that many different organisations and its staff have varying levels of knowledge on chemical safety and best practices.
Chemical safety is often perceived by health and safety teams as intimidating and complex and is often the last area to recieve attention due to the nature of other tasks. Assumptions can often be made that members of certain departments have a high level of competency on chemical safety for instance, if they work in laboratories. Don’t make any assumptions. Regulations have changed over the years and constantly evolve. The new GHS system is something which all members may not be aware of.
To begin, you need to map out the organisation and the department structure. Ensure that you thoroughly document and cover all aspects of chemical safety. Share that knowledge with staff and ensure to train and retrain all staff to a sufficient level of competence that they can make safe choices. Assign roles and responsibilities to all employees where necessary (emergency response, storage, handling). Having a complete overview of chemical safety within your organisation will give you a clearer picture and help to put your mind at ease.
2. Build your Chemical Inventory
It is vital to have an accurate chemical inventory to work with. How many sites, and how many departments do we have. What chemicals do we have in each location?
Areas to consider for your chemical inventory:
1. List all Departments on the site regardless of chemical use. It possible there are chemicals present you are not aware of.
2. Allow for Multi-Site structure if required.
3. Design a consistent inventory template for use across the organisation. You must collect the full product name along with the
catalogue code. This is essential as it allows you to source the most up to date safety data sheet for each product.
4. Collect product information by department and store it centrally. This will avoid doing the same work on multiple occasions, and you can also control the information being gathered. It will also help in terms of getting the right safety data sheet for the product you are using and not a variation.
5. Full product name – e.g. “Bleach” Vs “Domestos Bleach Original”
6. Full manufacturer name – (preferable to supplier).
3. Source Safety Data Sheets (SDS)
An SDS is a very important and informative document which allows you to assess hazards associated with the products in use. The law requires that all chemical suppliers provide an SDS for a hazardous mixture they wish to supply. SDSs should be available where the chemicals are in use. It is important that all staff have read the SDS for all the chemicals that they are working with. Upon receipt of the SDS, it is important to check the document to ensure it is in compliance with the application legislation in the country where it is in use i.e. UK SDSs should be CLP and REACH compliant.
Do your staff know what an SDS is? Employers should provide some basic awareness on this. For example, section 4 is First Aid, do your staff know this? If not, the safety data sheet will not be useful to employees using the chemicals.
All sections of an SDS are important, however, the most useful sections that staff should have knowledge on is the information displayed in sections 1-10. Safety data sheets must be provided either electronically or in hard copy.
Manufactures/Suppliers will usually provide SDSs with the product either electronically or in hard copy. If possible, source the SDS before the product is brought on site in order to review the hazards and determine if it is suitable (we will cover this in more detail later). Record basic information related to the product in your inventory, this will help you maintain control of the chemicals you have onsite.
4. Design a COSHH Template
Keep it simple and relevant. An overly complex COSHH Assessment template will fail. Avoid long and lengthy worded pages, people won’t read it. Use as many multiple-choice options as possible.
Free text is slow and encourages “copy & paste” from safety data sheets. This does not allow for the evaluation of the hazards.
One of the biggest mistakes we see in COSHH Assessments is generic information being filled as a box ticking exercise which has no significance for the job in question.
You can pre-populate certain sections with approved statements for all controls/procedures that are most relevant to each location on your site. (First Aid, Fire, PPE, etc)
Put your brand-logo on the template. It differentiates the document from an SDS and highlights ownership of the document within your organisation.
5. Write COSHH Risk Assessments
Who will create your COSHH Assessments?
-Recommended to be completed by EHS in conjunction with staff
- Staff actively work with EHS to complete assessments
- Work completed ideally in work environment
-Completed by staff – Signed off by EHS
- Some training required – Possibly completed in-house
- EHS reviews all assessments before publishing
COSHH assessments must be accessible to all staff, ideally electronically. Make assessments and safety data sheets accessible to all staff for the chemicals they use in a timely manner. The completion of COSHH assessments is vital to ensure the health and safety of staff involved. The documents should not just be completed and placed in a folder until they require review again.
Distribute soft copies via organisational network. Ideally through a document management system with features to allow searching, revision control, etc.
If it is not possible to provide soft copies, they should be provided via Hard Copies (Printed).
In particular these are required in areas that do not have access to systems. Strict procedures to be put in place to ensure these are kept up to date in line with soft version. Ensure multiple revisions of the same document are not available to staff.
7. Procurement – new products
In our experience this is one of the most important aspects you need to get right for chemical safety and COSHH management to be successful. The rationale behind this is when you purchase a chemical you are often going to be using that chemical for 5, 10 or maybe even 15 years. Do you consider the potential impact of implementing control measures for that product? In order to understand how that chemical may affect your process it is important to complete you COSHH assessment early on i.e. before the chemical comes onsite. Liaise with your supplier to ascertain all key information on the product and check the SDS.
There are a number of areas to consider during procurement:
• Buy cheap - buy twice
• Hidden chemicals
• Fit for purpose
• Substitute for safer alternative
• Small sized containers
• Approval process
Inventory - procedures must be in place to ensure all products are placed on department inventory.
Safety Data Sheet - this should be sourced before the product is brought on site. In some cases, the staff member requesting the product is tasked with sourcing the safety data sheet.
COSHH Assessments - This is written (as much as possible) before product is used on site. Identify potential risks before they become an issue for your staff
8. Maintain & Update
Safety Data Sheets
- Check for up-to-date Safety Data Sheets with manufacturers – Ideally on an annual basis. On occasion you will find it difficult to source these documents.
- Archive old versions of Safety Data Sheets. (Ensure staff only have access to latest version).
- Ideally manage your inventory centrally.
- Update COSHH Assessments in line with revised SDSs.
Put procedures in place to review COSHH assessments on an annual basis.
ECHA are reviewing and revising the classification of substances on an ongoing basis so it is essential that you have the most up to date safety data sheet to reflect such a change. If for example something changes from an irritant to a corrosive substance you must update your COSHH Assessments accordingly as it poses a different risk.
Individual departments should review and update inventory lists accordingly, but it is essential that the SDS is managed centrally.
The workload to implement a good COSHH system is significant and requires a lot of hours and input. Some companies work hard to get COSHH Management updated to a good place and then they feel the work is done. It is an ongoing battle to maintain the quality of your COSHH system. If a product classification changes or you stop sourcing updated SDSs then you increase the risk to your staff members and open up your company reputation to damages, lawsuits and even closure.
You will need to include all aspects associated with the chemical onsite.
When completing a COSHH assessment you will need to include all tasks and activities related to the chemical and its use. Culture in your organisation in terms of safe use of chemicals is key.
Process Risk Assessment V Individual Risk Assessment
Take note of the task for which the chemical was purchased. If the chemical is used in a different area or for a different task later on then the COSHH assessment may not accurately identify all hazards.
If this chemical is used in 2 different tasks the COSHH assessment must have control measures for both tasks, have a unique risk rating for each. Key staff using the product would need to be trained on this and the different usage types.
Are chemicals segregated in accordance with their associated hazards? Are chemicals stored above should height? Is the packaging suitable for the chemicals stored within?
These are all issues which could cause accidents or incidents in the workplace.
Ensure all aspects of storage are considered when bringing new chemicals onsite.
Consider the transport of waste chemicals internally. How will these be transported? Where and how will they be stored?
- Identify the hazards
- Decide who may be harmed and how
- Assess the risk and decide if any additional control measures needed.
- Ensure that the control measures are recorded fully implemented.
- Review and update risk assessments
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