Six Steps to COSHH Compliance

Hazardous Substance management can be a complex task. Changing legislation, the introduction of new substances and a lack of specialist knowledge can result in staff suffering from work-related ill health and businesses facing significant fines, prosecution and irreparable reputational damage.

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Written by: alcumus
17th January

COSHH is short for the Control of Substances Hazardous to Health, which is the primary set of regulations in the UK that govern the use of hazardous substances. Just as you would control a slip or a trip, electricity or a large piece of machinery, you must control your hazardous substances in the workplace. This is to make sure that you’re not exposing employees to the potential long-term and short-term health effects that are associated with working around these types of chemicals.

COSHH covers a wide variety of substances, including:

  • All purchased hazardous materials a company may use
  • Substances that form naturally in the workplace
  • Substances that form as a result of workplace processes

Failure to comply can increase the risk of financial implications and legal action:

  • An ejector seat manufacturer was fined £800,000 with costs of £36,900 in 2016 involving breaches of the COSHH Regulations 2002 where three skilled CNC machine operators developed lung conditions after being exposed for at least three-years to the mist produced from metalworking fluid.
  • Workers at a company in Bristol were exposed to hazardous chemicals over a four-year period leading to the onset of a disease called 'allergic contact dermatitis.'  They were fined a total of £100,000 and ordered to pay £30,000 costs for breaching The Health and Safety at Work Act 1974, and six separate breaches of the Control of Substances Hazardous to Health (COSHH) Regulations for not making adequate risk assessments, not preventing or controlling exposure of employees to chemicals, and for not providing any 'health surveillance' of employees at-risk.
  • A furniture retailer was fined £400,000 and costs of £94,904 in 2020 for failing to protect its employees from hazardous and explosive conditions at its premises.

So, what are the six steps to chemical management and COSHH compliance? These steps have been observed by both the Health and Safety Executive (HSE) and the Alcumus Sypol team.  Avoiding common errors can result in businesses either failing audits or any other areas of compliance checking within COSHH management.

  1. Identify the Substances and Eliminate Exposure
    • Ensure the substance is covered under COSHH, or a different legislation (e.g. Asbestos, lead)
    • Use the Hierarchy of Controls to eliminate exposure
  2. Gather the SDS and Exposure Scenario Information
    • Safety Data Sheets (SDS) will be available for all manufactured substances. They give all of the hazard information you require.
  3. Assess the Risks and Identify Control Measures
    • Identify Acute and Chronic risks and set appropriate control measures, ensuring consideration of all possible routes of entry.
  4. Writing the COSHH Assessment
    • This can be done manually or via COSHH assessment software
  5. Implement Control Measures and Train Employees
    • Implementing control measures identified in Step 3.
    • Additional actions include air monitoring, biological monitoring, health surveillance and training.
    • Training employees is vital to maintain health and safety of staff and to reduce the likelihood of financial penalties.
  6. Ensure Ongoing COSHH Management and Review Assessments
    • An assessment should be reviewed periodically or when any changes are made to any aspect of the assessment.

Some of the areas that cause some of the most basic failures in compliance come down to people genuinely not understanding exactly what's classified as a hazardous substance. It’s therefore important to familiarise yourself with it, for example, there are hazardous substances that wouldn't be covered under COSHH because they're covered by other sets of regulations. Elements like asbestos, lead and radioactive materials all have their own sets of regulations.

Another important thing to remember with hazardous substances is, many don't even look, smell or feel hazardous.  Although they may look totally innocuous, they could be damaging to someone’s health. So, it’s also important to make sure you consider things like inert asphyxiant gasses or low hazard dusts.

Some hazardous substances are obviously dangerous, such as corrosives or carcinogens, but there are many where you must think about the situation they're being used in, which will determine whether they pose a risk to health.  For instance, natural products, just because they’re not man-made, does not stop them being hazardous e.g. lemon juice which is still citric acid.

Another misconception is around smell, but this is not a reliable indicator of hazard or risk. Many hazardous substances, especially if they're derived from hydrocarbons, will have a strong smell.  However, there are plenty of non-hazardous materials with a strong odour and plenty of hazardous things which are odourless.

Next steps

To protect your people and your business, speak to Alcumus Sypol about our simple and effective COSHH management solutions.

Hazardous Substance management can be a complex task. Changing legislation, the introduction of new substances and a lack of specialist knowledge can result in staff suffering from work-related ill health and businesses facing significant fines, prosecution and irreparable reputational damage.