How to ensure that your business is COSHH compliant

Last updated in 2002, the control of substances hazardous to health (COSHH) helps businesses to identify and reduce the risks to their workforce when dealing with potentially dangerous substances.

The law states that an employer must control substances that are hazardous to the workforce’s health, as an employer you should:

  • find out what the health hazards are
  • decide how to prevent harm to health (risk assessment)
  • provide control measures to reduce harm to health
  • make sure they are used
  • keep all control measures in good working order
  • provide information, instruction and training for employees and others
  • provide monitoring and health surveillance in appropriate cases
  • plan for emergencies.

It’s very common for businesses to either use substances, or products that contain a mixture of substances. There may also be processes in place that create hazardous substances which could cause harm to employees, contractors and other people.

Sometimes substances are easily recognised as harmful. Common substances such as paint, bleach or dust from natural materials may also be harmful.

Most substances that are hazardous to health are covered by COSHH however some will need their own COSHH assessments, substances include:

  • chemicals
  • products containing chemicals
  • fumes
  • dusts
  • vapours
  • mists
  • nanotechnology
  • gases and asphyxiating gases and
  • biological agents (germs). If the packaging has any of the hazard symbols, then it is classed as a hazardous substance.
  • germs that cause diseases such as leptospirosis or legionnaires disease and germs used in laboratories.

Areas not covered by COSHH are:

  • Lead
  • Asbestos
  • Radioactive substances

Self-employed:

If you’re self-employed COSHH regulations will still apply to your business as it not only covers employees but anyone who may be affected by the substances you’re using. Not all parts of COSHH regulations will apply, those about monitoring and health surveillance will not apply to your business.

What do you need to do?

The first thing you will need to consider when doing your COSHH is:

  • What do you do that involves hazardous substances?
  • How can these cause harm?
  • How can you reduce the risk of harm occurring?

You should also do as much as you can to stop any exposure by identifying and stopping it at source, for example:

  • Can you avoid using a hazardous substance or use a safer process – preventing exposure, e.g using water-based rather than solvent-based products, applying by brush rather than spraying?
  • Can you substitute it for something safer – e.g swap an irritant cleaning product for something milder, or using a vacuum cleaner rather than a brush?
  • Can you use a safer form, e.g can you use a solid rather than liquid to avoid splashes or a waxy solid instead of a dry powder to avoid dust?

If you’re struggling to think of risks that might apply to your business, you can always ask employees or if you attend trade meetings as them for ideas.

In some cases, you won’t be able to prevent exposure to certain substances and therefore you will need to start planning on how you can control it.

The HSE states that “Control is adequate when the risk of harm is ‘as low as is reasonably practicable’.” This means:

  • All control measures are in good working order.
  • Exposures are below the Workplace Exposure Limit, where one exists.
  • Exposure to substances that cause cancer, asthma or genetic damage is reduced to as low a level as possible.

Switching up your substances

If a substance you currently use is causing issues, then you might be able to reduce or mitigate the risks by changing it. For example

  • substituting a powder for a liquid
  • removing the need to weigh out powders by buying it pre-packed.

Below are six steps to practical, well-thought-out decisions about substance substitution.

  1. Decide whether the substance or process is a hazard. Does storing, using or disposing a substance cause significant risks or exposure?
  2. Look for and identify any alternatives.
  3. Run the same checks against the alternatives as you have your current substance. (Storing, using and disposing).
  4. Decide whether substituting the substance will reduce risks.
  5. Introduce the substitute.
  6. Assess how it is working.

For more information about the effect of substances you use visit the HSE REACH web pages. You can also ask supplies or trade associates about what substitutions can be made and look for advice from other businesses in your industry.

Other considerations:

Exposure limits: How are you being exposed (skin, breathing etc) and what are the exposure limits on the substances being used?

Chemical safety data sheets: Use the safety data sheets for chemicals you’re using to help with your risk assessment.

Control measures: Consider using a wide variety of control measures, these could be ways of working, control equipment or worker behaviour.

Permits: Some tasks may require experts and therefore using a permit to work will help identify who will be carrying out the work and when it will be completed.

PPE: Employers and responsible for the supply of the correct PPE, so make sure your employers have the correct equipment for any given exposure.

Monitoring: You may need to put monitoring systems in place to show compliance with a WEL (Workplace Exposure Limit) or BMGV (Biological Monitoring Guidance Value) or when you need to show that control equipment or personal protective equipment is working well enough.

Health Surveillance: Monitoring the health of your employees to make sure they are not falling ill or unwell from work. This is not to be confused with general health screening could involve a scheduled annual check-up on, for example: lung function and skin conditions.

Training: Providing appropriate training for those who will be subject to exposure of the hazardous substances. This involves anyone who may be involved in cleaning and maintenance.

Emergencies: Make sure your business has a plan for accidents, incidents, and emergencies. This includes equipment, people, training, procedures and arrangements of any waste created.

For more information on COSHH and everything we have gone over, visit HSE.