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COSHH essentials

OC 273/16

This OC describes the recently launched package COSHH essentials: easy steps to control chemicals(INDG193) (file 273) and gives information to inspectors about enforcement policy in relation to it.

Background

1 The Control of Substances Hazardous to Health Regulations (COSHH) were first introduced in 1988. At the time they represented a major shift in chemicals legislation with prescriptive and piecemeal requirements being replaced by modern, goal-setting regulations. There are clear duties on employers to assess risk, then identify and implement appropriate controls.

2 While COSHH has been successfully implemented in many sectors, research has shown that many small and medium-sized enterprises (SMEs) have genuine difficulty with the risk assessment requirements and need help to identify what they have to do. COSHH essentials has been developed in response to this need (see para 4). It will help employers, particularly SMEs who may not have access to specialist expertise, comply with their main duties under COSHH by helping them identify the risks and appropriate control measures for supplied chemicals. The guide does not replace an employer's duties under the Regulations and COSHH essentials makes it clear that there are some duties, eg health surveillance, which also need to be complied with but are not covered by the guide. Nevertheless,COSHH essentials will help firms to benchmark their activities and to control health risks from chemicals in a straightforward way.

3 Inspectors will also find the pack helpful when initially considering 'risk gaps' and coming to an enforcement decision on COSHH (Enforcement Management Model). The principles of COSHH essentials will also provide a useful framework to help further refine the EMM for health risk enforcement.

The pack

4 COSHH essentials was developed by a subgroup of HSC's Advisory Committee on Toxic Substances. All aspects of the scheme - the technical basis, the risk assessment scheme and the control guidance sheets - have been peer- reviewed by professional bodies and extensively tested by SMEs to ensure usability. HSE is therefore confident that in the vast majority of situations implementing the advice given by COSHH essentials will lead to adequate controls of the risks.

5 COSHH essentials provides a structured approach to assessing the risk from chemicals in the workplace under a variety of conditions of use. Users are led through the steps from deciding on the hazard to selecting appropriate control measures. Exposure via the skin is included within the system and it also flags up those chemicals or exposure scenarios that cannot be accommodated within a simplified structure and need an expert input. The appendix to this document gives an overview of its structure. The scheme does not, at present, apply to process generated substances nor substances such as pesticides covered by the Food and Environment Act 1985 (FEPA) or veterinary medicines, which do not have risk phrases generated through the Chemicals (Hazard Information and Packaging for Supply) Regulations (CHIP).

6 COSHH essentials is a priced pack containing:

1) the COSHH essentials: easy steps to control chemicals guide (this contains the generic risk assessment model);

2) sixty control guidance sheets covering common tasks (these provide basic control advice for tasks such as mixing, weighing);

3) INDG136 (rev1)Working with substances hazardous to health: A brief guide to COSHH; and

4) INDG181 (rev1)The complete idiot's guide to CHIP.

((3) and (4) are included to provide the legal context for the scheme).

The pack has been distributed to operational inspectors, sector inspectors, selected specialist inspectors and file 273. A separate, free leaflet entitled Ill Informed, which publicises and gives details of where to obtain it has also been produced and distributed to offices.

7 COSHH essentials works on a system of hazard banding of chemicals but it does not replace the system of occupational exposure standards (OESs) or maximum exposure limits (MELs) set under COSHH. However, it can be expected that proper application of the step-by-step approach and implementation of the appropriate control strategy will reduce personal exposures to below the applicable OES. Substances that have a MEL will normally be in the special category requiring an individual assessment and selection of control measures.

8 To use COSHH essentials, employers will need information from the safety data sheet (SDS). If the information on the SDS is insufficient to identify the correct risk phrases, employers should contact their suppliers to get adequate data. It is a legal requirement under CHIP for suppliers to provide information on SDSs to enable users to take the necessary precautions to protect their employees' health and safety.

9 To make COSHH essentials applicable across a broad spectrum of industry, the control guidance sheets are designed for common operations, such as weighing, mixing, drying. It is hoped that sector guidance will be produced based on COSHH essentials with control measures tailored to the specific circumstances of the sector. The Printing Industry Advisory Committee (PIAC) already has a project underway to develop guidance for their sector using the COSHH essentials approach. Where sector-specific guidance exists (whether already published or published in support of COSHH essentials) it will take precedence over the general advice in COSHH essentials. Through time it is hoped that COSHH essentials will build into a comprehensive package and will be the main source of information and advice for SMEs about the control of chemicals in the workplace.

10 Although primarily directed at employers, who have the legal duty to protect employees and others from the risks associated with hazardous chemicals,COSHH essentials will also be of use to others, eg safety representatives, who need to assess the risks in the workplace. The TUC is aiming to update its COSHH training course materials to ensure safety representatives can use COSHH essentials to best advantage.

Action by inspectors and enforcement advice

11 Where employers, particularly SMEs, are having difficulty with assessment of risks from and/or control of hazardous chemicals used in the workplace, inspectors are asked to strongly recommend the use of the COSHH essentials package. The leaflet Ill informed can be provided to give details of how to obtain it.

12 The scheme will help employers through the assessment process to reach the correct approach to controlling exposure and from there to identify the most appropriate engineering control measure. However, it does not provide a complete control strategy. Each COSHH essentials guidance sheet gives general advice on other measures to be taken (eg housekeeping, PPE) but it is the duty of the employer to make sure that these are properly implemented. If inspectors judge control to be inadequate despite the employer having followed this guidance, then enforcement should still be considered but the level at which this is pitched should take account of the efforts already made and willingness of the employer to bring exposure under control (see para 13).COSHH essentials does not cover all situations, especially those that involve the handling or use of the most toxic materials (such as carcinogens or respiratory sensitisers) nor does it cover process generated hazards. In these cases individual assessments need to be done, if necessary by specialists, and control measures tailored specifically to the circumstances.

13 COSHH essentials is a good source of information to both inform inspectors' judgements with respect to 'actual risk' in the EMM, and help establish the 'benchmark' indicating adequate control of the risk and compliance with the law. The consequential 'risk gap' will inform the type of enforcement action taken subject to factors relevant to the circumstances of the case.

14 Because the information on SDSs is crucial to the proper application of COSHH essentials, suppliers need to provide adequate information in accordance with the requirements of CHIP. Inspectors should consider appropriate enforcement action against suppliers to provide adequate SDSs in line with the EMM.

Further advice

15 Inspectors should inform Health Unit of any significant issues arising from the use of COSHH essentials in practice, particularly if situations are encountered where the guide does not give suitable control advice . Further advice can also be obtained from these sources.

Date first issued: 20 August 1999
(220/FOD/1039/1999)

Appendix
(para 5)

Written in easy to understand terms,COSHH essentials focuses on practical advice. Using simple information, a checklist and examples, it takes the reader step-by-step through risk assessment to identify the right type of control, or control approach, and the control guidance sheets that are needed.

Step 1 Getting started . Identify the chemical and task that is being assessed and find the relevant safety data sheet.
Step 2 Look at the factors that decide the control approach . What is the health hazard? How much chemical is being used and how dusty or volatile is it?COSHH essentials uses information from the safety data sheet, plus tables to help answer the questions and complete a check list.
Step 3 Find the control approach . Using the information from Steps 1 and 2,COSHH essentials specifies what control approach is needed and what to do.
Step 4 Find the task-specific control guidance sheets . As well as general control advice, there are more detailed control guidance sheets covering a range of tasks from mixing and storage to spraying and drying. The guide helps you find the sheet(s) relevant to the task.
Step 5 Implement the action and review . Before putting controls into practice, this step is a reminder of other factors that may need to be considered. For example, other tasks that may need assessing, other COSHH requirements and when to check and review controls.
Updated 2015-09-14