Everything from a common cleaning product to an industrial chemical can be categorised as a hazardous substance. If you work with or store hazardous substances in your business, then by law you need to complete a regular COSHH assessment.
But what is a COSHH assessment and why is it so important to make sure you conduct one? We explain what the COSHH regulations require and how you can make sure your business is safe and complies with the law.
What Is a COSHH Assessment? What You Need to Know for Your Business
The ways in which hazardous substances can be legally used and stored are detailed in the Control of Substances Hazardous to Health Regulations (COSHH). The COSHH regulations place responsibilities on all employers that require their employees to use hazardous substances in the course of their daily duties. One of these responsibilities is the obligation to perform a risk assessment.
The COSHH regulations state that:
‘An employer shall not carry out work which is liable to expose any employees to any substance hazardous to health unless he has made a suitable and sufficient assessment of the risk created by that work to the health of those employees and of the steps that need to be taken to meet the requirements of these Regulations.’
A COSHH assessment aims to determine the level of risk posed by duties involving hazardous substances. It focuses on how hazardous substances are used, how they are stored, who could be harmed by them, and how they might be harmed. Once risks have been identified, steps must be taken to eliminate or mitigate them.
Why Is a COSHH Assessment Required?
Any employer that stores and uses hazardous substances in their place of business must ensure that a COSHH assessment is performed regularly. Failure to adhere to the COSHH regulations can result in criminal charges and heavy financial penalties. Corporations and individuals can be held liable if they are found to be in breach of COSHH regulations.
What Can Happen If You Breach COSHH Regulations?
In 2009, the Prysmian Cables and Systems Limited company was found guilty of three breaches of COSHH related to incidents that occurred between January 2006 and March 2008.
The Health and Safety Executive (HSE) alleged that the company failed to perform adequate risk assessments which led to employees being exposed to hazardous substances, including a potent skin irritant. One employee suffered such a severe case of dermatitis that he was forced to take early retirement for medical reasons.
Prysmian Cables and Systems Limited was fined £27,500 and made to pay costs of £10,700.
After the trial, HSE Specialist Inspector in Occupational Health Anne Bartlett stated that, ‘All employers should undertake risk assessments that correctly identify all of the significant risks, including those to health, and as a result ensure that an appropriate package of measures, including physical safeguards, safe systems of work, protective clothing, consistent training and appropriate health surveillance are provided for the safety of all workers.’
Who Can Perform a COSHH Assessment?
Legally speaking, a person does not need any special training or qualifications to perform a COSHH assessment, according to the HSE. However, the HSE goes on to state that the person responsible for the COSHH assessment must be competent.
A ‘competent person’ is defined by the HSE as someone who has ‘sufficient training and experience or knowledge and other qualities’ that allow them to perform their duties properly.
What Should a COSHH Assessment Cover?
A COSHH assessment needs to include the following information about any hazardous substances stored or used in the workplace:
- What the substance is called
- Its classification and properties
- Information on the risks to health
- What task/s require the use of the substance or produce the substance
- The extent and length of exposure to the substance
- Information on relevant Workplace Exposure Limits (WELs)
- Details of control measures such as the use and handling of the substance, how it is disposed of, and emergency procedures
- Details on procedures to monitor employee health
- Risks posed by the combination of hazardous substances
- Other information that may be relevant
5 Steps to Complete a COSHH Assessment
When conducting a COSHH assessment it is advisable to follow the five steps involved in any risk assessment:
Step 1: Identify Any Hazards
Make a list of all hazardous substances used or stored in your workplace. Information on substances considered hazardous should be listed in safety data sheets (SDS) provided by the manufacturer. If a hazardous substance is produced by a work activity, for instance, wood dust, then refer to an authority such as the HSE for advice.
Step 2: Identify Who Is at Risk and How They May Be Harmed
Consider who may be exposed to the substance. This could be the employee completing the task, but may also be co-workers or members of the public. To determine the level of harm, consider the nature of the substance and how long the exposure may last.
Many hazardous substances have immediate effects that only last for a short time; for example, burns from chemicals. Repeated exposure to some substances can result in health conditions that take many years to become apparent; for example, lung conditions caused by repeated exposure to concrete dust.
Step 3: Develop Control Measures
Once you have determined who may be harmed and the severity of the risks they face, the next step is to develop procedures to eliminate or mitigate the risks.
Firstly, take note of any existing control measures and evaluate how effective they are. If the current measures are adequate, then there is no need to take further action.
If the current measures are not sufficient to protect people from possible harm, then you will need to make improvements or develop new strategies to eliminate or mitigate risks.
This may involve actions such as implementing the use of personal protective equipment (PPE), increasing ventilation in a workspace or finding other ways to complete a task that does not involve the use of a hazardous substance.
Keep in mind that the COSHH regulations require you to manage risks ‘so far as is reasonably practicable’. This means that while you may not be able to remove risks entirely, you should take all reasonable measures to eliminate or control risks.
Step 4: Make an Accurate Record of Your Findings
Any business that has five or more employees must make a record of all findings from the COSHH assessment. This is a legal requirement. However, all businesses should record the information gained from a COSHH assessment, as this can assist with assessing and developing health and safety measures.
The record can be kept as a paper document or in digital format. It must show the hazards found, the control measures that were implemented, and the reasons why the control measures were chosen.
Step 5: Regularly Review Your COSHH Assessment
To be sure that the control measures you have chosen are effective, you should regularly review your COSHH assessment and update it when required. Often, a quick review of the COSHH assessment is all that is needed to see that it is still relevant.
If there are any changes to the working environment or your working procedures, then you must assess your COSHH assessment right away. If an employee reports that they feel the COSHH assessment is no longer valid, or if it becomes obvious that it is no longer suitable, then it must be thoroughly reviewed immediately.
Find Further Training on How to Conduct a COSHH Assessment
Hazardous substances can be found in a variety of workplaces throughout the UK. Knowing how to correctly store and use these substances is crucial for the health of your employees. Providing COSHH training will ensure that your workplace is safe and that you meet your obligations under the law.
You can sign up for an accredited COSHH training course via the Human Focus website. Our COSHH course can be taken completely online in segments at your convenience. This course is approved and recognised by respected health and safety authorities such as the International Institute of Risk and Safety Management (iiRSM). Trainees will gain a full understanding of COSHH principles, learn how to identify hazardous substances, and be taught how to conduct a COSHH assessment.