COSHH is the acronym for “Control of Substances Hazardous to Health.” This is a law in Great Britain that requires employers to control substances that are hazardous to health. COSHH is administered and enforced by the Health Safety Executive (HSE), which is Great Britain's equivalent of OSHA in the United States.
HSE's job is to serve as a national independent watchdog for work-related health, safety, and illness in Great Britain. They define themselves as:
We are an independent regulator and act in the public interest to reduce work-related death and serious injury across Great Britain’s workplaces.
COSHH - Control of Substances Hazardous to Health
COSHH makes the employer responsible for protecting employee's health and controlling exposure to hazardous substances. This is done through a proactive, deliberate approach to workplace health that involves:
Control of exposure
COSHH – Risk Assessment
Before an assessment can be conducted we need to know what we are looking for. What types of health hazards are covered by COSHH?
COSHH covers exposure to most substances that are hazardous to health. A list published by the HSE identifies possible forms of exposure, such as from (HSE):
Products containing chemicals
Fumes, dusts, vapours, and mists
Gases and asphyxiating gases
Biological agents (germs).
However, not every hazardous material is covered by COSHH. The following are not covered because there are specific regulations outside of COSHH that address their hazards:
Workplace assessments should still look for these hazardous substances; however the control measures are governed by regulations outside of COSHH.
Substances can have dangerous properties other than negative health effects. For example, some substances are flammable and present a fire hazard. Even substances we don't suspect as being flammable can have a very high level of flammability. For example, a solvent may not be directly flammable, but it could give off a flammable vapour. And dust from everyday materials such as wood or flour may not seem dangerous, but they can violently explode if suspended in air and ignited.
A COSHH assessment involves a number of steps. The HSE has listed these as:
Walk around your workplace looking for locations and activities than can result in an exposure to a substance that might be hazardous to health. Look for:
Processes that emit dust, fumes, vapours, mists, or gases. Also look for locations where substances of any type are suspended in the air.
Substances that are flammable or produce flammable vapours.
Locations where hazardous substances are stored or transferred.
Identify the substances and the ways those substances are hazardous. How can you identify substances that are hazardous? Be proactive by:
Reading the safety data sheets for all materials that come into your facility.
Contacting manufacturers and inquire about safety hazards.
Reading trade magazines
Attending trade shows and conferences and asking others about potential hazards.
Reading the HSE web site.
Some hazardous substances are generated in the workplace, and that means there are no safety data sheets. For example, fumes from welding or soldering, mist from metalworking, dust from quarrying, and gases from silage. How can all potential exposures to hazardous substances be identified? Here are some suggestions (HSE):
Identify those people who might be exposed to a hazardous substance.
People who work with hazardous substances.
People who work in the area where the hazard exists, and who may be exposed.
People who may incidentally be exposed.
Are there existing areas of concern that can be identified?
Use the records in your Accident Book to identify potentially hazardous areas based on past experience.
Take reports of sickness, such as nausea or lightheadedness, seriously.
Follow up on reports of burns from splashes or drips.
Talk with equipment suppliers to identify hazards associated with machines.
Get information about potential hazards from your trade associations.
Talk with your counterparts when attending trade shows and conferences
Involve your workers
Talk with workers to gather information that may point to hazards.
Involve workers in the process of establishing control measures.
Encourage workers to suggest improvements.
Identify and evaluate the control measures that are already in use.
Evaluate each substance used in your workplace.
Evaluate the potential for an incident could result in an over-exposure.
Identify the way(s) substances are harmful.
Check the Safety Data Sheet.
COSHH – Control Of Exposure
There is a three stage hierarchy of control measures used to protect employee's health and safety. These are:
Control the Equipment
Control the People
Use Personal Protective Equipment
In most cases a combination of these methods are used to provide the necessary protection. The following lists the control measures in the preferred order that they be applied:
Control The Equipment
Eliminate the use of hazardous products or substances.
Replacing them with a safer product or substance.
Redesign the equipment or process such that the hazardous substance is no longer needed.
Use a safer form of the product. For example use a paste form of a product rather than a powder that can become airborne.
Change the design of the process so that it emits less of the hazardous substance.
Eliminate the step in the process that produces the hazardous substance
Use water, or another appropriate material, for dust suppression.
Disinfect recycled water.
Enclose the process so the hazardous substance does not escape.
Extract hazardous emissions from a location at or near their source.
Use ventilation to extract dust, mist, and fumes.
Prevent access to the hazardous substances by:
using glove boxes and fume cupboards
using spray booths
using refuges (clean rooms in dirty work areas)
using robotics to do the work
using barriers to restrict access by unauthorized people
Control The People
Limit the number of workers who could be exposed to the hazard.
Change work schedules so that the work requiring the use of hazardous substances is done when fewer people are present (such as at night).
Limit access to areas where there is a hazard.
Provide training to ensure all equipment is operated properly.
Conduct regular equipment inspections and preventative maintenance.
Establish work rules that limit the amount of time an individual spends working while exposed to a hazardous substance.
Personal Protective Equipment
Provide appropriate personal protective equipment (PPE) such as gloves, coveralls, and a respirator.
Conduct fit tests. PPE must properly fit the wearer.
Train employees in how to do PPE inspection, cleaning, and maintenance. PPE is the last line of defense. If it fails, the worker will no longer have protection.
Protecting workers from hazardous substances typically involves a mixture of all three of the above approaches. However, keep in mind that no matter what protective measures are used, they must be used correctly and appropriately. This means that training, and refresher training, is important. Don't assume that employees, including supervisors, know what to do.
COSHH - Health Surveillance
Getting exposure to hazardous substances under control is not the end of the job. You need to keep them under control. Machines experience wear, equipment can fail, and people make mistakes. The employer is responsible for ensuring their people are not exposed to health hazards under any circumstances. An important part of this is that employers need to have someone who is responsible for monitoring, checking, and maintaining the control measures. This person needs to be “competent” to:
Monitor the workplace to detect any uncontrolled contaminants;
Inspect the control equipment to ensure it is continuing to work as designed;
Monitor workers to ensure they are complying with all protective requirements.
Monitoring the workplace may mean:
Conducting air sampling (verifying exposures are less than the “Workplace Exposure Limits” (WELs) published by HSE).
Taking biological samples, such as breath or urine samples.
Conducting visual inspections.
Verifying that Safety Data Sheets are available and current.
Ensuring health checks are conducted as needed.
COSHH - Incident Planning
You need to be prepared for emergency situations. This not only includes accidents such as spills involving hazardous substances, but also situations involving fires, structural failure, or severe weather. Good planning, and in some cases prepositioning materials and equipment that may be needed during an emergency, is necessary. It all begins with developing an emergency plan:
An emergency plan needs to address at least the following basic requirements:
Get people away from immediate danger and to a safe location. This includes:
Accounting for all employees
Providing first aid and medical assistance
Informing the community, if necessary
Summon and assist emergency services.
Contacting emergency services and other authorities.
If the situation is serious, hand over responsibility for the emergency to outside authorities.
Establish procedures for equipment shutdown, and the personal who will remain behind to ensure a safe shutdown.
Identify specific people, and backups, who will be responsible for the following types of tasks:
Summoning the emergency services
Liaison with emergency services
Informing the public
Conduct the on-site emergency response (on-site firefighting, for example)
Be responsible for the evacuation
Assuring everyone has evacuated and have reached a safe location
Assuring people with disabilities are safe
Assuring that those who remain behind to shutdown equipment are known and evacuated safely
First aid and medical response
Overall incident control
COSHH – Training
Training is critical. With the proper training people will know what the dangers are, how they are protected from the hazard, and what to do in case of an emergency. Handing people a book, or a set of printed instructions, is not training. Few people learn well just by reading a book.
Training should include:
Show workers how to use control measures properly.
Demonstrate how to check control measures to ensure they are working.
Practice drills for dealing with common types of accidents (such as cleaning up spills safely).
Practice respirator fit, maintenance, and use.
Demonstrate how to use and put on other PPE such as protective gloves (employees need to know how to put gloves on and take them off without contaminating their skin).
COSHH – Visual Communication Using Labels and Signs
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