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COSHH Risk Assessments | Do they apply to your business?

Only if you use chemicals in your workplace.  Things like washing up liquid and bleach don’t need assessing but your staff should still be informed of the correct way to use them.lungs

Assessment is the responsibility of the employer.  Persons preparing the assessment will need to have access to, and understand, COSHH related legislation, Codes of Practice and published guidance.  They will need to be competent to carry through the work of assessment and consult with the workforce and inform them of results accordingly.

Assessment is a step-by-step approach: Identify what hazards there are then evaluate the risks to people.  For significant risks, decide on the action needed to remove or reduce them to insignificant levels.

COSHH Risk Assessments | Do they apply to your business?

COSHH risk assessments need to meet the requirements of The Control of Substances Hazardous to Health Regulations 2002.  So, in simple terms, your risk assessments need to be completed in ‘Sections’ ensure that you meet the requirements.

These may be broken down as follows:-

  1. Date of assessment and review date – You should always have a review date even if the substance or method of using it isn’t going to change.
  2. The Substance name, and a description of the process in which the substance is used.
  3. You also need to list the hazardous properties of the substance, and any information on the possible health effects of using it.
  4. A simple statement of the level, type and duration of exposure to the substance, and any relevant Occupational Exposure Standards should be included.
  5. You need to show how effective is your use of the preventative and control measures that you have put into place.
  6. If you use chemicals that could cause sensitisation or irritation to the skin, or substances that can be breathed into the lungs, or can be absorbed through the skin then some form of Health Surveillance will need to be carried out.  You will need to detail the type and results of this surveillance which could take the form of questionnaires as well as biological monitoring.
  7. If you use higher risk substances such as isocyanates or chromate based paints then the results of biological monitoring should be available for inspection by the Health & Safety Executive  and it should be stated in the assessment that this is the case and you must retain these records for at least 30 years.
  8. If you use substances in combination then the risk presented by the mixture should be stated.
  9. Explain also how you will address the issues of Information, Instruction and Training for persons exposed.

Finally, all employees should read and understand the details of the risk assessments. All employees should receive instruction in relation to the substance involved and to the work processes in which it is used from a competent person.  Employees could, for example, attend a suitable awareness course related to the substances, the hazards to which they give rise to, and the preventative and control measures necessary for their protection. The proper fitting, use and care of PPE should be included in the content of this training as should relevant emergency measures such as fire fighting, spill control, and the recognition of symptoms related to exposure and first aid measures.

A record should be kept to this effect in the personnel file for the employees concerned   Instruction and training should be reviewed annually or whenever the risk changes and records re?made.

As always, if you have questions related to specific COSHH assessments please call one of our safety consultants for advice and support on 01453 800100.

If you’ve got questions or need support on safety in the industrial, contracting or construction sectors please contact us for sensible and proportionate advice on 01453 800 100

Posted by Roger Hart

COSHH Health Surveillance

Introduction

Health surveillance is a subject which is not commonly addressed by SME organisations but one which can have an important role in managing the health and safety of your employees and also in controlling any civil liability which might arise from claims related to workplace health.

Perhaps the most common example would be audiometric testing for high noise level environments, most people know of a business which uses these tests but what about other workplace health problems such as dermatitis (shown right) and respiratory problems?

By taking a quick look through the hazard data sheets of the substances to which your staff are exposed your are likely to come across a range of products which refer to the potential for dermatitis and some which refer to skin or respiratory sensitisation (Risk Phrases R42 / R43).

The Case for Health Surveillance

Should you have identified substances which do carry these types of risks it is very likely that your risk assessments have identified the need to staff to wear gloves or other PPE or perhaps your have put in extraction systems or, best of all, eliminated or at least reduced exposure.

However, it is likely that some exposure will still occur, staff don’t always use all of the precautions which we would wish them to do as they are, after all, human.  Health surveillance will give you evidence that staff who are protecting themselves remain healthy and for those who might be prone to take more chances with their health it can give an early warning of future problems, for example;

A staff member experiences skin problems which are worse during the winter months (when wind, wet and rain could put skin under additional stress).  They put this down to the weather and a host of other factors when the root cause is exposure to a hazardous substance without using their gloves.  You carry on assuming that all staff are working without problems when, in the background, these unprotected exposures are growing into a health problem which could result in months away from the workplace, a RIDDOR reportable workplace disease and perhaps even a civil claim.  Health surveillance should have raised this issue through the completion of a simple annual questionnaire allowing you to act at an early stage.

Legal Requirements for Health Surveillance

The Control Of Substances Hazardous to Health Regulations 2002 Regulation 11 (COSHH) requires employers to implement a system of health surveillance where:

  • The exposure of the employee to a substance hazardous to health is such that identifiable disease or adverse health effect may be related to the exposure;
  • There is a reasonable likelihood that the disease or effect may occur under the particular conditions of the work;
  • There are valid techniques for detecting indications of the disease or effect.

When Should Health Surveillance be Applied

The best time to start is when you first employ a new member of staff.  They will most likely have experience of your industry and the substances which you use but what of their previous employer?  Will they have taken safety as seriously as you? This person could have received exposure to hazardous chemicals for years and so make sure they do not exhibit any symptoms of skin or respiratory sensitisation (contacting you HR advisor is recommended at this point).

How can we implement Health Surveillance

You may be surprised to hear that you are probably implanting a level of health surveillance already.  If you have surveyed your staff regarding the Display Screen Equipment regulations and their comfort whilst using computers you have completed health surveillance.

Whilst it would be true to say that a questionnaire will not be appropriate in every situation it will suffice for the majority of circumstances.  Once you have identified any issues you can flag those staff with concerns for further investigation but this can take the form of finding out more from them and what the causes could be before sending them to an occupational health specialist or their local GP.

What should my next steps be?

A responsible person can be trained to make basic checks such as skin inspections for first signs of redness and could, for example, be a supervisor, employee representative or a first aider.

For more complicated assessments such as medicals fitness for specific jobs, lung function tests, hearing tests etc, an Occupational Health Nurse can perform the assessment and do various examinations. Some jobs may only require the employee to fill in a questionnaire which can then be screened. This is normally done for new employees to ensure fitness for the type of post but can also be done periodically for jobs with specific hazards. For more complicated procedures, an Occupational Health Physician may be required.

Common Examples of health surveillance

TasksType of surveillance
DSE Use Vision Screening
Muscular Assessment
Workstation Assessment
Drivers OH Assessment
Manual Handling work OH Assessment or questionnaire
Noise Hearing test if exposure at levels of 80Db or above
Vibration Self reporting examination or questionnaire + OH examination if required
Asbestos, lead, compressed air OH assessment
Substances Hazardous to Health:
Chemicals, vapours, solvents, fumes
Dusts, gases, aerosols
Biological agents 		Varies depending on substance:
Self reporting
OH assessment
Respiratory function tests
Skin surveillance
Blood test
Urine tests
Ionising Radiations Dosimetry
Personal monitoring
Laser users Eye examination
Confined spaces – use of respirators OH medical
Pregnant workers OH assessment or questionnaire
Night work OH assessment or questionnaire

 

Health Records

Where any health information is written such, lung function tests, records have to be kept for a minimum of 40 years, typically by the Occupational health provider.

We trust that the above provides a useful summary and food for thought but if you have further questions we here to help, just call 01453 800 100 to speak to an expert COSHH Safety Consultant to guide you through your specific requirements.

Posted by Roger Hart

Storage of petrol and diesel fuel in the workplace

Important: Please note that we do not provide advice on this issue unless you are a retained client under our Safety~net support scheme. if you’d like to explore the benefits of membership please contact us or request a callback.

Guidance on Storage of petrol

Many businesses store quantities of petrol fuel within the workplace.  They could be for plant and equipment used on site such as lift trucks, or for maintenance needs, strimmers, lawnmowers and the like.  However, you are storing a highly flammable substance and certain precautions are required but what are they?

Since the introduction of DSEAR (Dangerous Substances and Explosive Atmospheres Regulations), there are no longer any specific controls over the storage of petrol at workplace sites other than at petrol filling stations. However, you will need to follow the requirements of DSEAR as petrol is classified as a ‘dangerous substance.’

Key requirements for the safe storage of petrol

If the petrol is being stored in a place which is also a workroom then no more than 50 litres of highly flammable liquids should be stored – this is a general requirement which applies as much to thinners or any other highly flammable liquids as it does to petrol.

If the storage area is not a workroom, then DSEAR also requires, as far as is reasonably practicable, risks from ‘dangerous substances’ are controlled and to mitigate against the effects of any fire or explosion arising from these dangerous substances. This means conducting a risk assessment and recording its findings then acting on them. Identifying how you can reduce risks to a minimum – look at the storage area to ensure that:

  • It does not have any sources of ignition and none should be bought into the area (compressors, electrical switching)
  • It should be properly ventilated (large vents in doors and on one outside wall would be good practice)
  • It should be secure (padlocked and not able to be accessed except by authorised persons – consider arson risks also)
  • Refilling of equipment should preferably take place in the open air and away from sources of ignition (you could refill on hard standing outside and clear of the building – something your insurers will appreciate as well as the environment)
  • Care is taken to avoid spills and the consequences of a leak or spill is assessed(could a spillage leak to surface water drains – the consequences could be serious for the environment and your business)
  • Containers should be kept closed when not in use.

Storing diesel

There are no specific legal requirements on how to store diesel or the quantity allowed either in workplaces or domestic premises. It is not, from a health and safety point of view, a particularly hazardous substance within the meaning of the Dangerous Substances and Explosive Atmospheres Regulations 2002 – its vapour flash point is too high. This means that its vapour will not ignite at normal room temperatures.

That said, there are some general issues you’ll need to take into account:

  • no ‘hotwork’ should be performed on the vessel unless it is emptied and purged of any remaining vapour.
  • the drum should be positioned away from any source of direct heat.
  • the drum should be located in an area where there is no risk of collision with vehicles, fork-lift trucks etc. (diesel splashing onto a hot engine will probably ignite).
  • leaks and spills should be contained to the vicinity of the drum and mopped up quickly, to lessen the risk of slipping.
  • refilling and dispensing activities need to take account of manual handling issues etc.

While diesel is not a particularly dangerous substance from a health and safety point of view, it is an environmental hazard, with considerable clean-up costs if it should leak into a drain, watercourse or the soil. You may, therefore, wish to contact the Environment Agency for further information.

More good advice on safe storage of petrol

Cans and drums can provide an adequate means of storing petrol. When considering this method of storage remember to take into account the method by which the petrol will be used or disposed of and whether the use of small containers increases the overall risks and handling problems during their filling and emptying (think about manual handling). Where you need to store larger quantities than 300litres you should consider installing tanks and referring to the more detailed advice in HS(G)51. You should not store more than 50 litres of petrol within a workroom and then only when it is kept in a properly labelled metal cabinet or bin with adequate spillage retention.

Containers should, where reasonably practicable, be stored in the open air at ground level (singularly or in stacks). This enables leaks to be quickly seen and any vapours to be easily dispersed. They should not be stored on the roof of a building. Where the best option of storing containers outside is not reasonably practicable they should be kept in suitable storerooms, preferably separate buildings, specifically designed for the purpose.

Finally, remember that other activities, including filling and emptying containers, must not be carried out in the designated storage area. This is to prevent other activities that are a higher risk causing a fire, which then spreads to involve the larger quantities in storage.

Notes on application

Information should be incorporated into your Risk Assessments, Health and Safety Policy or Construction Phase Health and Safety Plan (CDM Regulations).  If you have questions please post below, more information can also be found from manufacturers safety data sheet (MSDS).  Don’t confuse this with COSHH Risk Assessment but you can refer to section 16 – Storage Requirements.

Contact us on 01453 800100 if you need expert help with health and safety for a fixed cost or use contact us above of the form to request a Call back

Posted by Roger Hart