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.