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REACH and COSHH working together

COSHH and REACH sit side-by-side.  Both of them call for risk assessment. This page sets out the overlaps and differences, as we see them in 2009. 

What are the main obligations?

Issue COSHH REACH

Who must assess risk?

The employer

The manufacturer or  importer, mostly

What substances?

Hazardous to health, including those arising from processes and germs

Manufactured or imported in quantities of 10 or more tonnes per year in the EU

What duty?

Control exposure in all uses by site and process-specific measures

Develop exposure scenarios and identify ‘Risk Management Measures' for named tasks and procedures

REACH identifies a Derived No Effect Level for substances (DNEL). This is a benchmark not an exposure limit. The manufacturer or importer uses this DNEL to identify the correct Risk Management Measures for your task or procedure the exposure scenario.

Exposure scenarios and the ‘Risk Management Measures' (RMM) appear in the REACH Safety Data Sheet for a substance or product. REACH is being phased in until 2018.

By using the RMM in the Safety Data Sheet, you are likely to comply with the DNEL. By using good control practice such as is given by COSHH essentials, you are likely to comply with any Workplace Exposure Limit.

Good practice under COSHH and RMM under REACH should match up. If your COSHH assessment calls for extra controls, use these too.

Importantly if the RMM in the safety data sheet don't seem to apply to your use, you must provide feedback to the supplier.

What if?

2012-01-26