Using OELs at the Workplace

The Regulations were of course not without their detractors amongst the organisatiems rq)resaitmg enployers sand esf cially those representing the chemical industry. However, even here tiie criticism and concern was not so much directed at the role of OELs as it was more widely directed at for exanple, the notion that under COSHH all chemical sul tances were treated as dangmms because the regulations concerned then lves witii hazards rather than risks and tii ore placed unnecessary and unacceptable burdens on the resources of the chemicals indust and the users of chemicals. 

Section 6 of the HSW Act and Regulation 6 of the CHIP Regulations define what information suppliers are required to provide in the suppliers safety data sheets 

Of coume, even if the information was of a suitable and sufficient quality this did not me that employe would use it appropriately or that they made it available to their workers and their ropresentatives. There is, for example, a considerable 

The role of OELs in enforcement actions. Comphance with OELs is a legal requirement under the COSHH Regulations. Under the HSW Act 1974 HSE inspectors have powers to institute a range of formal enforcement actions. These include two types of enforcement notice - an improvement notice or a prohibition notice - as well as powers to institute prosecution for criminal offences in the 

Nevertheless as the research reported in the next section shows, trade union health and safety representatives surveyed in the study commissioned by the HSE (Research International 1997) were considerably better informed about OELs than were enqjloyers. The explanation the researchers offered for this finding was that the safety representatives in their survey were mostly drawn from larger enterprises. A further factor would have been the extent of health and safety training received by the representatives - which is considerably greater than that received by the average small enterprise owner manager and which deals specifically with representing workers that use hazardous substances. 

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