Control of Substances Hazardous to Health (COSHH) procedure

Issue 6 - November 2017

Purpose
  • This procedure sets the consistent way Hampshire County Council (HCC) manages the exposure of its employees, service users, contractors, volunteers, members of the public or any other persons to substances hazardous to health arising out of its activities. This procedure does not cover exposure to asbestos or legionella, which are dealt with in separately.
  • It sets a council-wide method for identifying, avoiding, assessing and controlling exposure to substances hazardous to health as defined by the Control of Substances Hazardous to Health Regulations 2002 (COSHH). This procedure should ensure compliance with COSHH and its Approved Code of Practice L5.
Scope
  • This procedure applies to any exposure from the purchasing, handling, storage and use of any substance hazardous to health; to any exposure to a substance hazardous to health as a waste product or by-product of another process; and to any work-related exposure, accidental or deliberate, to a biological agent.

This procedure replaces all previous corporate policies and procedures relating to the control of substances hazardous to health.

Terminology

The following terms should be used when interpreting and applying this procedure and the COSHH Regulations.

  • COSHH Regulations – the COSHH Regulations 2002 as amended and Approved Code of Practice and supporting guidance L5
  • COSHH assessment – a systematic assessment of the risks to the health of employees from work with substances hazardous to health. In addition, HCC will also consider the risks to the health of non-employees and others in its COSHH assessments.
    COSHH assessments can found on your Department health and safety website; for more technical assessments or advice on control measures, contact your Health and Safety Adviser.
  • Control measure – any measure taken to reduce exposure to a substance hazardous to health, including hardware and software systems and Personal Protective Equipment (PPE).
  • Health surveillance – a system of ongoing health checks that may be required by law if employees are exposed to hazardous substances or activities that could cause them harm. It can detect ill health effects at an early stage and highlight failures in workplace control measures.
  • Monitoring – measurement or assessment of the physical exposure of employees to a substance hazardous to health through air sampling, water sampling, etc.
  • Personal Protective Equipment (PPE) – all equipment, including clothing, which is worn or held by a person at work to protect them as an individual from exposure to substances hazardous to health.
  • Respiratory Protective Equipment (RPE) – Personal Protective Equipment specifically designed to prevent or reduce the risk to workers from inhaling substances hazardous to health. This includes disposable dust masks and high-efficiency equipment such as canister respirators and breathing apparatus.
  • Substance hazardous to health – any material which is classified as harmful for the purposes of supply or labelling and has a workplace exposure limit (WEL); biological agents such as a virus, bacteria or fungus; and any otherwise non-harmful dust present in the air in significant amounts.
  • Thorough examination – thorough inspection and, where necessary, testing of a control measure by an independent, competent person.
  • Workplace exposure limit (WEL) – this is an occupational exposure standard for chemicals and materials which can be inhaled. WELs are found in HSE document EH 40/2005.
Procedure

All employees and persons acting on behalf of HCC must ensure that whenever they procure, handle, store or use any substance which is hazardous to health; or when they are likely to be engaged in work which might expose them to a substance hazardous to health as a by-product or waste product; they comply with this procedure.

COSHH Assessment

Managers must ensure that COSHH assessments are carried out where required. Those responsible for carrying out COSHH assessments should first identify whether the material concerned is a substance hazardous to health as defined, or may become hazardous to health when later handled or used. The information provided on the label on a container, in the manufacturer's catalogue, or on a material safety data sheet should provide an initial indication as to whether the substance is classified as harmful. The current hazard labels and their definitions can be found at Appendix 1. If the material is labelled as corrosive, acute toxicity, serious health hazard, harmful, it should be regarded as hazardous to health. If the material is labelled as an oxidiser, flammable or harmful to the environment, it may be hazardous to health as well, and further information should be obtained to clarify this. A flowchart summarising the assessment process can be found at Appendix 2. Further guidance about carrying out the COSHH assessment can be found in Appendix 3.
COSHH assessments can found on your Department health and safety website; for more technical assessments or advice on control measures, contact your Health and Safety Adviser.
Records must be kept and maintained to comply with this procedure. Where applicable, follow HCC’s retention record schedules.
As a minimum, all COSHH assessments must be reviewed every three years. They may need reviewing more frequently if something about the work changes. This could be a change of material; a change of process; changing work rate; a change of personnel; a change in the published exposure standards of the material, etc. When a COSHH assessment is reviewed, the aim should be to reduce exposure to hazardous substances wherever possible.

Control measures

The COSHH assessments should be communicated to all relevant persons. Those persons should then receive appropriate information as to what the hazards are for the materials they are using, instruction in how to carry out the work safely and then be trained in that process. Managers must ensure that all persons working under their control understand the nature of the hazards from the materials they are working with, and are using all relevant controls appropriately. Whatever controls are put in place as a result of the COSHH assessment, whether engineering controls, such as exhaust ventilation, or safe systems of work, managers must ensure are used and maintained. Maintenance of the controls will include not only physical maintenance; planned preventative maintenance, condition maintenance, breakdown maintenance and cleaning, but also routine checks to ensure that the controls and safe systems of work are being used.
The COSHH Regulations require that some control measures are subject to thorough examination. Where engineering controls, such as local exhaust ventilation, are used these should be thoroughly examined at least every 14 months. Other types of physical controls, or those used to control exposure to specific high risk materials, may need thoroughly examining at different intervals (the health and safety team can advise). Respiratory protective equipment, other than disposable masks, must also be thoroughly examined at suitable intervals. The manufacturer or supplier, or the health and safety team, can advise on the frequency.

Monitoring

For some hazardous substances or processes, managers must ensure that levels of materials are monitored in the workplace. This should be done through air sampling, surface swabs, or some other sampling method. Individuals’ exposure may also need to be monitored through health surveillance. Such monitoring may be necessary as part of the initial evaluation of exposure, to help make a judgement as to the level of exposure and whether control is adequate. It may also be necessary, when the controls are in place, to make sure that they are working properly. It might also be necessary to monitor levels of the hazardous substance in real-time where there is a risk of a serious health effects if the control measures fail (e.g. working with chlorine or ammonia in a pressurised system).

PPE

Where PPE is to be provided, managers must ensure that it is suitable as a risk control measure and achieves an adequate level of protection; fit the person and be individually issued to them; be cleaned and maintained appropriately; and must not create any new risks or reduce the effectiveness of other control measures. The PPE will also need to be stored appropriately when not in use, in a location which is clean and secure. Persons using PPE should be trained in its use, adjustment and maintenance. For RPE (respiratory protective equipment) persons must also undergo face fit testing. The health and safety team can advise on appropriate face fit testing.

Guides
Appendices
Appendix 1 – CLP Labels on Packages, in use from June 2015
Appendix 2 – Flow Chart for COSHH Assessment
Appendix 3 – Guidance on carrying out a COSHH assessment
Appendices
The full procedure is available as a printable document. Corporate health & safety procedure - COSHH - Issue 6 - 2017-11