Director Briefings Part 5: Control of Substances Hazardous to Health
This week’s toolbox talk for Directors is presented in a short informative vodcast on the topic of control of substances hazardous to health (COSHH). Finch Consulting’s Health and Safety lawyer Sue Dearden and Occupational Hygienist Dr Steve Cowley discuss the following topics:
– practical ways in which the Board can help to support corporate compliance in this important area
– the use of purchasing controls and risk reviews
– what is meant by and the comparative benefits of quantitative, qualitative and process driven risk assessments
Please click the video to watch or alternatively you can read the transcript summary below.
Control of Substances Hazardous to Health Transcript Summary
This briefing is another in our series for Directors who have overall responsibility for health and safety within their business, but we are assuming that they have a health and safety manager or an external consultant in place who manages day to day health and safety for them.
These briefings are all about what the Board needs to know to have confidence that health and safety is being managed appropriately within their business and, hopefully, to not only avoid company liabilities but also personal liabilities for getting things wrong.
This briefing is focused on COSHH – the Control of Substances Hazardous to Health – largely because we see so many mistakes being made in workplaces where we think there could be better risk controls.
Directors can play a very important role in questioning whether the chemicals in the workplace are under control. There are chemicals in every workplace and looking for the controls in place, risk assessments, and the processes to back that up is key.
We are obviously concerned about the presence of chemicals in the workplace generally, but once they become airborne the risk dramatically increases so we often focus on airborne contaminants and the prevention of inhalation. That is not to say, however, that we shouldn’t also be looking at skin absorption of chemicals, or the potential for ingestion.
The main route of absorption into the body though is breathing, and it tends to be the lungs which are the main site for harm. Dermatitis is common, as a result of skin contact, but inhalation causes lung damage and also absorption of the chemical into the blood stream. The ingestion route of entry has become less and less significant as arrangements for personal hygiene have improved, and smoking and eating in the workplace have stopped.
Health monitoring is important. It’s part of the arsenal available in controlling the risk – but it is a bit after the fact because health monitoring identifies when people are starting to get sick or showing symptoms. Ideally, we are looking ahead of that, at what chemicals there are, what risks they create, who is exposed to them and how those risks can be better controlled, through risk assessments before there is any illness.
There is a hierarchy of controls. Ideally we wish to eliminate chemicals from the workplace which means asking, “Do we really need to use it?”, “Is there an alternative way of doing this work?”. If we have to use a chemical, ask the question, “Is there a safer alternative – a substitute?”. If that is not possible then we look for engineering controls and then as a last resort personal protective equipment.
Risk assessments must be reviewed periodically. Available chemicals do change so something better may come out into the market which you may not come across unless you look for it. It is also important to ensure that the information about the chemicals hasn’t changed – that we haven’t learned that they are more harmful, for example. Also think about how our processes might have changed – how people using the chemical might have changed the way that they are undertaking the process which exposes them to the risk just in case that changes the risk too. And also think about whether the process followed could be improved to better manage the risk.
We don’t always have to rush headlong into a full blown occupational hygiene survey to measure, or quantify, the concentration of a contaminant in the air as part of a risk assessment. We can use certain qualitative techniques, like a bright light source to illuminate a dust or a mist (but not gas) in the atmosphere. You will have seen that in a factory when you see a shaft of light coming through a skylight – it will illuminate a contaminant in the air. We can generate that illumination of contaminants using a bright light source called a tyndall beam. Or we can use smoke generators to see whether a ventilation system is working as part of our risk assessment. Or we can perhaps do something semi quantitative like using a colour change tube which changes colour in the presence of a chemical when air is drawn through it. These are ways in which we can short-circuit a risk assessment using a qualitative risk assessment.
Our health and safety specialists can undertake that sort of work as a “quick and dirty” risk assessment to save the time and money that might otherwise be spent on the risk control measures, which can then be checked to ensure that they are indeed working.
Quite often risk assessments use a safety data sheet as a basis for assessment of the risk from a particular chemical. These sheets can be quite complex. It is important to remember that all they do is tell us about the chemical as it is delivered.
Chemicals can be used in different ways in a workplace, and can create bi-products and combustion products that also need to be part of the risk assessment. So, it is the process that needs to be assessed – the use of the chemical from its delivery through its process of use and through to disposal.
One way to help ensure that you get control of substances hazardous to health controls right is for the board to ensure that purchasing procedures include questions about chemicals being ordered and reordered, to ensure that a check is made to see if they can be replaced by non harmful or less harmful chemicals, and to check whether they are still needed.
The HSE has some really good detail on its website about control of substances hazardous to health and about managing these risks. The COSHH Essentials tool is really good for guiding you through the risk management process with some great control examples.