Protection COSHH requirements

In the case of substances identified as hazardous to health, the Control of Substances Hazardous to Health Regulations 1988 (COSHH) require that exposure to them must be either prevented or controlled. Prevention of exposure can be achieved by either a prohibition on the use of the substance, total enclosure of the source or by substituting a less hazardous substance. Control, on the other hand, may entail an engineering solution, such as the installation and operation of local exhaust ventilation systems, or by changing the process to afford better operator protection. In relatively low risk situations the provision and use of specific items of personal protective equipment may afford the appropriate level of operator protection. In all cases, prevention and control strategies should be supported by the provision of information, instruction and training for staff and adequate supervision. 

The EU issued a Directive in 1998 covering the protection of health and safety of workers from the risks related to chemical substances [11]. In the UK there is a legal requirement based on this Directive, namely Statutory Instrument 2002/2677 [12]. The UK Health and Safety Executive issues guidance on implementing COSHH (Control of Substances Hazardous to Health) Regulations. Each laboratory is required to assess the risk associated with each chemical (or generic families of chemicals) in use in that laboratory. This risk is assessed according... 

The Control of Substances Hazardous to Health Regulations 1994 (COSHH) are set out under the HSWA and protect workers against risk to health from exposure to substances in the workplace. A risk assessment is required and must be made available to workers, with training given to those who might be exposed to such substances. The HSE is the competent authority for CHIP and COSHH in the United Kingdom. 

Enforcement powers. Compliance with OELs is a legal requirement under the COSHH Regulations. Under the HSW Act 1974 HSE inspectors have powers to issue two types of enforcement notice - an improvement notice or a prohibition notice - as well as powers to prosecute for criminal offences in the courts. Improvement notices are nomally used to instruct duty holders to remedy a situation in which an inspector believes that there has been a breach of the law resulting in a risk to the health or safety of persons that the law is intended to protect. The duty-holder is normally requir to remedy tiie situation within a specified time period in accordance wath the requirements laid out in the notice. Prohibition notices are normally issued where inspectors fell there is m imminent and serious risk to health and safety. They have the effect of prohibiting... 

Based on these conclusions a Consultation Document was published that made proposals to introduce a new OEL Framework (HSC 2003) that was a combination of the second and third options described in the Discussion Document. It reiterated the belief that many employers, particularly in small firms, did not know about OELs and of those that did, very few understood how to work out whether the chemicals in the air at their workplaces were above or below the relevant OELs. Because of this and other work on small firms it argued that a new approach was necessary. It advocated the replacement of the two types of OELs that had been in use since the mid-1980s (the OES and MEL) with a single type of OEL to be known as a workplace exposure limit (WEL). Employers would be required to ensure that the amount of chemical in workplace air did not exceed the WEL. However, since it was recognised that only for very few chemicals was there sufficient information to be able to say with certainty that harm would not occur to anyone exposed at the WEL, it was not possible to regard them as safe limits . Since it was essential that such uncertainties be accounted for in any system that aimed to protect workers properly a new COSHH Regulation 7 (7) replaced the COSH 2002 Reg. (7) and 7 (8). It stated ... 

Although there are many causes of health hazards at work, there are also a wide range of equipment and techniques to protect employees from them. Protection from these hazards is required by COSHH Regulations and is dealt with in Sections 11.1 to 11.8. 

The COSHH Regulations require the prevention or adequate control of exposure by measures other than personal protective equipment, so far as is reasonably practicable, taking into account the degree of exposure and current knowledge of the health risks and associated technical remedies. The hierarchy of control measures are as follows ... 

All personal protective equipment, except respiratory protection equipment (which is covered by specific Regulations, such as COSHH, lead, etc) is controlled by its own set of regulations - the Personal Protective Equipment at Work Regulations. A detailed summary of these Regulations is given in Chapter 20 and needs to be studied in detail with this section. The principal requirements of these regulations are as follows ... 

Where there is overlap in the duties in these Regulations and those covering lead, ionising radiations, asbestos, hazardous substances (COSHH), noise, and construction head protection then the specific legislative requirements should prevail. 

Wherever dangerous chemicals are supplied for use at work, CHIP 3 requires tirat safety data sheets must be provided when the chemical is first ordered and tiiat they must contain sufficient information to enable the recipient to take the precautions necessary to protect his employees health. This information should also include environmental data. The approved code of practice gives detailed advice on the information to be made available to employers. This could be useful when carrying out a COSHH assessment, but the data sheet should not be considered as a substitute for an assessment. 

Engineering methods of noise control should be used in preference to hearing protection for reduction of exposure to noise. Noise hazard zones must be established and marked where applicable. Local exhaust ventilation must be installed to reduce exposure levels of wood dust, glues, paints and wood treatment chemicals and must be inspected regularly, as required by the COSHH Regulations. Dust extraction equipment must be fitted on all machines which produce dust. Machine guards must be provided as required by the Standards listed, and always used when machines are in motion. 

Hearing, eye, head and foot protective equipment and respiratory protective equipment as required by COSHH assessments must be supplied and used. Machines must be checked before use to ensure guards are correctly fitted and work properly. Only 110 volt equipment is to be used where practicable, with leads positioned to prevent trip... 

The Confined Spaces Regulations (SI 1997 No 1713) came into force on 28 January 1998, and apply in all premises and circumstances where the Health and Safety at Work Act applies. To comply with the Confined Spaces Regulations it will be necessary to consider other Regulations including COSHH 99, PUWER 98, PPE and MHSWR. The Regulations specify requirements and prohibitions to protect the health and safety of persons working in confined spaces and also those who may be affected by the work. 

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