Introduction from Bill Belshaw, Chairman of the Mechanical and Electrical Health, Safety and Environment Committee

When I wrote the foreword to the first HVCA COSHH manual I did not realise how widely used it would become. Since the Control of Substances Hazardous to Health Regulations (COSHH), was first introduced in 1989, there have been a number of revisions to the Regulations and the products themselves have changed. Hence the reason for this, the sixth issue of this Online COSHH management system. It has been further updated, and the way that the information may be read has been enhanced, by issuing the information online. This contains all the information that you need to help you to fill the requirements placed on you by these regulations.

Despite the passage of time, many businesses continue to look on the use of the COSHH Assessments as a paperwork exercise, which the client imposes on them. If the information were actually used by each business, it would have a dramatic effect on general safety practices and procedures in the HVCA industry. Your first choice in risk control should be to substitute lower risk substances or process, wherever it is reasonably practicable.

This online COSHH management system contains assessments for the majority of chemicals and/or substances that you may use. These Assessments provide details of the risks, how to treat emergencies and the control measures to be employed under certain circumstances. Please use them to make sure that each site of work has the lowest risk substances that will adequately perform the task required. Always read the COSHH Assessment before you use a new substance and make sure that you understand how to use it safely. Following the workplace precautions detailed in the COSHH Assessment will help towards your safety and the safety of others working around you.

It must be recognised that the COSHH Assessment Sheets do not cover all of the substances you may encounter. Additional Sheets will be produced from time to time to meet the needs of the industry, but assistance is required from you to identify other substances for which assessments may be needed. It is also essential that you are provided with COSHH material safety data sheets (MSDS) which will contain important information on the chemical, its risks and hazards. These information sheets should be provided by the substance/chemical manufacturer/supplier.

The provision of these Assessment Sheets does not relieve you of your duties under the COSHH Regulations. These place specific responsibilities on you to assess, prevent or control exposure and to monitor the effects of substances used in your business. Please study the Assessments carefully and apply the advice and guidance given on them.

I wish to express my thanks to Sypol Environmental Management Ltd, who have provided the technical content for the Assessments. Without their support, it would not be possible to produce this online COSHH management system. My thanks also go to the Heating and Ventilating Mechanical and Electrical Health Safety and Environment Committee whose time and knowledge has enabled this online COSHH management system to be updated.

WHAT IS COSHH?  (back to the top)

The Control of Substances Hazardous to Health (COSHH) is a set of Regulations for controlling the exposure of workers to substances that can harm their health.

When we think of substances, we think of materials we bring to the workplace, but COSHH is more than this and includes any substance that can cause harm.

For example: - COSHH covers the dust cloud caused by sweeping in a dusty area.

THE COSHH ASSESSMENT  (back to the top)

The first step in complying with COSHH, is the production of the COSHH Assessment. This should define the inherent hazards associated with work activities or the materials to be used, taking into account where and how they are to be used, together with the detail of all precautions that should be taken to control the risk associated with the activity or product used.

Materials

Obtain the Material Safety Data Sheet (MSDS) from suppliers and use it to judge whether a material is hazardous to health. Consider the way that the material is used i.e. quantities involved, length of time in use, method and location of the planned use. Use this to evaluate the risk.

Detail those precautions to be taken to control the risk. For example,

• eliminate hazard
• substitute with a less hazardous alternative
• isolate the worker, enclose the process
• ventilate the work areas using local extraction techniques forced ventilation, or general ventilation
• control work practices - by producing a method statement and by supervision
• ensure good housekeeping
• provide any personal protection equipment deemed necessary.

The Assessment should also indicate further actions needed to ensure compliance with COSHH Regulations 6-13, i.e. assessment, control, maintenance, monitoring, health surveillance, training/information requirements and dealing with incidents.

Activities

Assess the work activity and use it to judge whether this will be hazardous to health. Consider the way that the activity will be carried out i.e. quantities involved, duration, method and location of the planned activity. Use this to evaluate the risk.

OTHER REGULATIONS of COSHH  (back to the top)

COSHH does not simply require the provision of the COSHH Assessment. Arrangements will need to be made to train employees, provide and maintain control measures and in some cases, monitor exposure levels and carry out health surveillance.

Maintenance, testing and examination

Engineering controls provided such as Local Exhaust Ventilation (LEV) systems must be maintained so that they continue to provide effective control. Whatever controls are in place, a systematic approach to their maintenance, testing and examination and decommissioning – at no more than 14 month intervals (see HSE HSG258 Controlling airborne contaminants at work.) - should be specified. Results should be documented and kept for 5 years.

HVCA publications TR/19, SFG 20, DW144 and DW172 have further information.

Monitoring

Workplace monitoring should be undertaken if a material or process poses a serious risk to health, if doubt exists as to whether or not limits are exceeded, or to ensure that controls are working effectively. Personal monitoring results should be documented and kept for 40 years, results of environmental monitoring should be documented and kept for five years.

However monitoring is of little use unless results can be compared against bench mark standards below which exposure via inhalation is unlikely to cause harm to health.

Monitoring can therefore be defined as the collection of a number of air samples from a workplace in order to derive a quantitative measure of exposure to airborne contaminants in the workplace as a whole.

Standards and Legislation

The COSHH Regulations have now set a single Workplace Exposure Limit (WEL).

Overview:

• A single type of exposure limit has been introduced with Workplace Exposure Limits (WELs) replacing Maximum Exposure Limits (MELs) and Occupational Exposure Standards (OESs) The OESs for around 100 substances will be deleted as the substances are now banned. As the numerical values of the other limits being transferred to the new system are unchanged, suppliers may exhaust stocks of safety data sheets that refer to MELs and OESs before producing new ones that refer to WELs. Similarly, COSHH assessments can be updated as part of duty holders periodic reviews.
• Apply the eight principles of good practice for the control of substances hazardous to health;
• Ensure that the WEL is not exceeded; and
• Ensure that exposure to substances that can cause occupational asthma, cancer, or damage to genes that can be passed from one generation to another, is reduced as low as is reasonably practicable, design and operate processes and activities to minimise emission, release and spread of substances hazardous to health.

The 8 Principles of COSHH are:-

• design and operate processes and activities to minimise emission, release and spread of substances hazardous to health
• take into account all relevant routes of exposure - inhalation, skin absorption and ingestion - when developing control measures
• control exposure by measures that are proportionate to the health risk
• choose the most effective and reliable control options which minimise the escape and spread of substances hazardous to health
• where adequate control of exposure cannot be achieved by other means, provide, in combination with other control measures, suitable personal protective equipment
• check and review regularly all elements of control measures for their continuing effectiveness
• inform and train all employees on the hazards and risks from the substances with which they work and the use of control measures developed to minimise the risks.
• ensure that the introduction of control measures does not increase the overall risk to health and safety.

Health Surveillance

Health surveillance should be undertaken to detect changes before signs and symptoms show in exposed workers. This may be a simple skin check, lung function test, urine or blood test. Records should be kept for 40 years.

Training

This involves the provision of:-

* Information as to the hazards and risks associated with materials used.

* Instruction on how to work safely.

* Training in the use and maintenance of any controls provided.

Records and Review

A suitable record of all COSHH activities should be kept, either on paper or a computer database. A re-assessment should be made when work practices change and an assessment is no longer valid or in any case at least every 5 years.

COSHH AND CDM   (back to the top)

The Construction (Design and Management) Regulations 2007, known as CDM, have created a legal framework for the management of construction and maintenance work which applies to all but the smallest of jobs. There are duties assigned to clients, their designers and provision made for the instatement of a Health and Safety Coordinator - and in each case this requires a response from contractors who also have their own duties. CDM has an impact on the way in which hazardous substances are managed and COSHH compliance is achieved.

Qualification of Contractors

Any person selecting or appointing contractors is required to assess their competence. To demonstrate competence as regards COSHH, subscribers should cite the HVCA system and their use of the general assessments and processes set out in the document. This should be supplemented with an indication of how the assessments are used on site.

Resources

On appointment, it may be necessary for a contractor to confirm the resources available for safely managing the work and the availability of further advice from HVCA may be cited.

Design

Designers of any aspect of a building, including services, are required by CDM to seek to minimise risks by the appropriate selection of safer materials, and to advise the Health and Safety Coordinator of any materials specified which require special handling precautions. The HVCA COSHH Assessments may be used as the basis for both the judgements and the information to pass on.

Health and Safety Plan

The Health and Safety Coordinator must ensure that a Health and Safety Plan is prepared, and the pre-tender version of this plan has to be ready before any work (including preparation of tenders) on the project is undertaken.

The Principal Contractor is required to develop and maintain the construction phase of the Health and Safety Plan defining the safe system of work operating throughout the project. The COSHH Assessments form an essential element of this process, for the Principal Contractor and for all specialist and sub-contractors. Users of the HVCA Online COSHH management system should incorporate appropriate references to specific assessments in their own sections of the Health and Safety Plan, Method Statements and other similar documents. In addition, on request from the Principal Contractor, copies of the relevant COSHH assessments may be furnished to the Principal Contractor and/or the Health and Safety Coordinator.

Users of the HVCA Online COSHH management system will find the management of hazardous substances in accordance with the guidance provided meets the relevant CDM requirements.

Any hazardous substances permanently incorporated into the structure of the project which are likely to pose a significant risk to the end user of the building when responsibility future works will need to have their presence recorded in the Safety File. The Health and Safety Coordinator must ensure that the Safety File is prepared, handed to the client at the end of the contract and subsequently maintained throughout the life of the building.

MEETING THE REQUIREMENTS OF COSHH  (back to the top)

The management system for meeting the requirements of COSHH when using this online COSHH management system is outlined below.

MANAGEMENT SYSTEM

A formal management system should be established for the distribution and use of assessments, and their use in guiding safe working practices. The system should be explicit, requiring amendment of the Safety Policy Statement, and subject to routine audit. The system should describe responsibilities for:-

Assessment of Risk

Before any work activity is carried out, all materials which workers are likely to come into contact with or use must be subject to an assessment of risk to the workers’ health.

The risk assessment/method statement must consider:

• the properties of the material
• information provided by the manufacturer on health effects
• the level type and duration of exposure
• the work to be carried out
• any occupational exposure data
• any factors which might apply which relate to the location of the work
• the effect of control measures
• information obtained from operative health surveillance and monitoring
• any other information which may be relevant

A record of the risk assessment must be made and retained.

Prevention or Control of Exposure

Before any work is carried out, every effort should be made to minimise the risk of contact with hazardous substances. Consideration should be given to sourcing safer alternative methods of working or materials wherever possible.

Material Purchasing

The preparation of a list of all materials to be used should be produced. If a COSHH Assessment is available in the online COSHH management system for a material this may be used. If not, together with Material Safety Data Sheets from the material manufacturers or suppliers, you should carry out your own assessments.

Consideration should be given to sourcing safer alternative materials wherever possible.

General Assessments

The majority of materials used, and/or processes undertaken can be subjected to a standard, general assessment. Many of these will be available in this online COSHH management system.

Note, where a material is not listed, further assessments may be available.

Estimating

Consider COSHH when surveying buildings to be refurbished. Identify hazardous substances e.g. dust etc. within the building that need to be considered, as well as putting together "materials to be used" lists.

Responsibility

Within the company, assign responsibility for co-ordinating COSHH. Delegate to managers who are responsible for other areas of health and safety management.

Sub-contractors

Sub-contractors must comply with COSHH. Assessments should be obtained from sub-contractors for substances they intend to use, when they tender for the work.

MANAGING COSHH ON SITE  (back to the top)

Copies of the COSHH Assessments should be provided to Line Managers responsible for the implementation of COSHH on site. It is their responsibility to ensure that assessments for the materials to be used are readily accessible and the controls required available. Line Managers should also identify any new materials, activities and processes under their authority which are not covered so that assessments can be prepared.

Checking Implementation

Employees must comply with COSHH. They have a duty to implement the documented controls. The assessments should be used as mini method statements and the guidance provided implemented. The Guide to COSHH Assessment Interpretation section of this online COSHH management system with the assessments should be used as a ready reference. Posters summarising the pictogram interpretation are also available upon request.

Sub-contractors

LIAISON  (back to the top)

Successful implementation of COSHH requires liaison with various parties, good communication and the flow of information. The following considerations should be taken into account.

WITH THIRD PARTIES

Reassurance

Reassure them that you have a clear policy for complying with COSHH. The COSHH Assessments in this online COSHH management system represent an Industry Standard. The important aspect remains local management of hazardous substances.

Information

If your staff work on other premises, ask the person in charge there for information on any hazards which you need to know about, in order to ensure the protection of your own staff. The host company has responsibilities under COSHH to assist in protecting your staff.

WITH SUB-CONTRACTORS

Ensure that sub-contractors have valid COSHH Assessments before work starts. For major works, even after you have checked the assessments; ask at a progress meeting and minute the response: "Is there any aspect of your work which is a potential hazard to others on site, and which you wish to bring to our attention?"
Assessments are only guides to action - it is necessary to check that the precautions and controls indicated as being necessary are put into practice and continue to be so throughout the duration of the job.

WITH STAFF

There is a legal obligation to ensure that workers are informed, instructed and trained in connection with the hazardous substances with which they work.

The COSHH assessments have been designed to be used as the means for conveying the relevant information - that is one of the reasons for using the pictograms and producing the poster.

Use the assessments as a written instruction - supplemented as necessary by verbal or further written instructions on how the job is to be done.

Make sure that the staff concerned are capable of following the instructions and that they are trained so that they are "competent". This training may be formal, or in the form of "tool box talks" on for example skin care, use of dust masks etc. The HVCA series of Toolbox Talks includes ones on PPE, COSHH and the use of Respirators and Breathing Masks. Advice on how to give a Toolbox Talk is also included.