What are the COSHH Requirements in a School?

Let’s start with breaking down the acronym COSHH. It stands for Control of Substances Hazardous to Health. The law places responsibility on employers to control any substances that have the potential to cause harm to health. Following COSHH guidelines is essential given the level of risk involved.

Around 13,000 people die each year, from health conditions related to the exposure to hazardous substances, according to Health and Safety Executive (HSE) figures.

Substances that have the potential to cause harm to people or objects are classed as hazardous substances under UK COSHH regulations. This includes substances that are flammable, toxic, corrosive, can irritate, explode or any combination of these properties.

Hazardous substances come in a variety of forms. In a school setting this may include:

• Glues
• Paints
• Dust
• Chemicals
• Cleaning products
• Disinfectants

These substances are often used on a daily basis in schools. Other substances include gases, biological agents, nanotechnology and mists. These may not be used in all schools, but are used in some higher education institutions like universities and technology academies.

School employees or students may be exposed to hazardous substances by inhaling or ingesting them accidentally. Or, entry into the body can happen through cuts, punctures or accidental contact with their eyes or skin. Harm can occur from just one exposure, or sustained exposure, over a period of time.

Effects can be mild, like a slight irritation on the skin when exposed to bleach, for example. But if exposure is prolonged, for example a cleaner is not provided with gloves and gets bleach on their skin on a daily basis, they could develop contact dermatitis. More severe exposure to hazardous substances could lead to lung cancer and even death.

The best way to prevent exposure is to conduct a COSHH risk assessment, to understand what the risks are and how best to control them.

There are numerous consequences of failing to adhere to COSHH legislation. Consider this example of a school cook, who was required to mix dough in a large mixer. This daily task involved the use of flour in a small, poorly ventilated school kitchen There were no controls in place to adequately disperse the flour dust.

As a result, the employee was diagnosed with occupational asthma. The 46-year-old developed such severe breathing problems that she had to sleep sitting up and could hardly walk without fighting for breath.

The council (the employer) was found to be in breach of the COSHH regulations, and admitted to not taking sufficient action to prevent this injury, even after complaints were received.

Although the cook was awarded £200,000 in damages, her life has been negatively altered forever.

If a COSHH policy was in place and regular COSHH risk assessments had been done, this injury probably wouldn’t have happened.

If schools are government owned the local authority is the employer. If schools are private and independent, they are usually managed by a board of trustees.

Regardless, whoever is considered the ‘employer’ is who legal responsibilities fall to. However, employers may assign this duty to someone else, such as the school’s headmaster or a health and safety manager.

These responsibilities include:

• Ensuring controls are in place to prevent any exposure to hazardous substances
• Implementing and following safety measures to protect all school staff and pupils from hazardous substances
• Providing adequate information, training, instructions and where necessary supervision to all school workers
• Providing suitable personal protective equipment
• Making sure that all control measures are kept clean, are well maintained and in full working order, at all times
• Developing emergency procedures that cover what to do in the event of accidents that involve hazardous substances
• Making sure that hazardous substances never exceed the Workplace Exposure Limit (WEL)
• Completing and regularly reviewing the COSHH risk assessment

School employees, namely senior management, also have responsibilities under the regulations. It is their responsibility to:

• Follow the COSHH policy that is in place
• Use facilities and control measures as instructed by the employer
• Store and wear PPE provided to them, appropriately
• Report any insufficiencies or defects they discover to the employer
• Comply with all the instructions, training and information provided to them

If your school has hazardous substances, from the cleaners’ cupboard to the design and technology room, then the answer is a firm yes. It’s a legal requirement under the COSHH regulations to manage the risks to school staff and students and have an assessment in place.

A COSHH risk assessment follows the same principles as a general risk assessment. The steps of a COSHH risk assessment are to:

1. Identify the hazards
2. Identify who may be harmed and how they may be harmed
3. Evaluate the risks and develop control measures
4. Record all the findings and implement control measures
5. Review the assessment regularly and update when necessary

Ultimately, this is a careful assessment of any hazardous substances you have on the premises and considering who can be harmed by them. In the case of schools, this includes faculty, students, other staff such as janitors and any contractors on site.

After completion of the COSHH assessment, it’s essential that adequate safety controls are put in place to reduce the chance of harm occurring to a suitable level.

Your COSHH assessment should be regularly reviewed to ensure that it’s suitable and adequate.

A COSHH policy sets out the roles and responsibilities of school management and all employees. How and when substances should be used, by whom and where and how they will be stored should be included in the policy.

It will also mention the COSHH risk assessment, what to do in the event of an emergency and how substances should be discarded. Just like the risk assessment, the policy should be regularly reviewed to make sure it’s up-to-date and fit for purpose.

Teaching staff, caretakers and cleaners all need to know how to remain safe and to protect students from being harmed. If they handle hazardous substances, they must be trained. Even if the assessment is outsourced to a health and safety professional, there are great benefits in providing awareness training to employees. They, in turn, will be doing their part in helping their employer to do their duty.

Whether COSHH is new to you or you would like to refresh your existing knowledge on COSHH requirements, there are  COSHH courses in the Human Focus library that you will find beneficial. Human Focus COSHH courses are assured by highly respected organisations including RoSPA and iiRSM, and you can learn at your own pace, in your own time.

Training employees in the management and safe handling of hazardous substances is the best way to prevent accidents and keep employers on the right side of the law.