CoSHH Regulations Explained: Control of Substances Hazardous to Health (2023)

COSHH is the law that obliges employers to control substances hazardous to health.

This in-depth guide includes a definition of COSHH, a summary of what is covered by COSHH, explanations of important symbols, details on how to create a COSHH assessment, common mistakes, and a compilation of the latest articles on the subject.

• DOWNLOAD: Chemicals and COSHH data sheet
• Handling hazardous substances – important tips
• Essential health and safety guide to COSHH
• Chemical Safety Data Sheets
• Take the What is COSHH Quiz? by RoSPA
• Barbour Hazardous Substances/COSHH EHS-Leitfaden

pollutant video

COSHH stands forControl of substances hazardous to health.

these regulations,Created in 1999and substituted2002 to incorporate EU directives, oblige employers to control exposure to hazardous substances to prevent health problems.

Hazardous substances include:

• chemicals
• Products containing chemicals
• fumes
• Staub
• fumes
• Fog
• Nanotechnology
• asphyxiating gases and gases
• Biological means
• germs that cause disease

TheNOinclude asbestos, lead or radioactive materials.

Essential COSHH symbols

exposure prevention

They can prevent or reduce worker exposure to hazardous substances:

• Know the health hazards
• risk assessment (HSE models here)
• Control measures to reduce harm
• Provision of information and training for employees
• health monitoring
• contingency plan

Most companies use substances or products that are mixtures of substances.

Some processes create substances. This can harm employees, contractors and others.

Sometimes substances are easily recognized as harmful. common substanceslike ink, bleach orDust from natural materialsit can also be harmful.

30 minute video explaining COSHH

7 steps from COSHH

This infographic fromabacus securityexplains seven steps that practitioners can follow.

How to create a COSHH assessment

Check out this helpful video fromSevron security solutionsTo create assessments and compliance:

Five Common COSHH MistakesPhil Chambers BSc CMIOSH

Over the years I've seen a number of reviews of hazardous substances. Some pose problems, so here are five common mistakes and what you need to do to avoid them.

Mistake 1: A collection of datasheets

Sometimes I walk into companies and management says, "Here's our COSHH file." You look at it and realize it's just a collection of (often incomplete) datasheets.

What you need to do is assess the risks of each substance based on how you use it in your workplace, and then take appropriate action to control the risk.

Finally, you need to verify that these control measures are working. And don't just go by what you recently bought; Open the cupboards and see what might be hidden.

Mistake 2: A perfect set of COSHH reviews on the shelf

The next mistake is having a perfect set of COSHH ratings in a pristine folder while the people on the shop floor know nothing about them.

A thick manual full of reviews and datasheets in the shop is not a viable solution, so I advocate the practice of having summaries in the field.

These indicate how the substances are to be used and which emergency measures are to be taken in the event of an incident. You should also talk to people about these instructions.

It's good practice to involve them in the creation of the controls from the start - that way they're more likely to agree with them.

Mistake 3: Getting distracted by little things

I saw control measures for a carcinogen missing from a collection Mr. Glanz (with separate ratings for Original and Pot Pourri).

On top of the overhead involved, if you assess every substance at your site, you end up with an impractical system where critical substances are masked by tis trivial.

It is important that people who use substances believe that following control measures is a necessity. Asking them to follow steps they think are stupid can devalue the whole approach.

Please protect yourself by listing low risk substances, but don't clog the main system.

Another way to make it manageable is to group the substances. For example, for a particular type of printing process, inks are generally the same regardless of their color.

Therefore, only make one assessment for traditional lithographic inks and one for digital inks. Have none for magenta, none for cyan, etc.

Mistake 4: Disregarding the hierarchy of control measures

There is a hierarchy of control measures that you must follow, with elimination/replacement at the top of the list and PPE at the bottom. Often people struggle with mid- and low-order control measures and never consider a replacement.

When a substance is an integral part of your process, substitution may be unrealistic.

But many solvents and cleaning agents are used for which less dangerous alternatives are available.

To support management engagement I use a color coding system from:

• green - no effect
• Amber - short-term effect, like solvents that cause dizziness with overexposure by inhalation
• red - medium/long-term effect, e.g. B. corrosive substances that burn the skin or cause permanent eye damage
• purple - long-term effects such as carcinogens.Once you have a color code, agree on a working guideline for the green end of the color code, starting with trying to remove purple substances, with KPIs of how many of each color have been removed.

Mistake 5: Unrealistic use of personal protective equipment (PPE)

People in production have to “buy” practices related to hazardous substances.. A good way around this is to require employees to wear PPE for everything.

A substance can irritate the eyes, but so can soap,and you don't wear glasses when you wash your face. You want to make sure people wear eye protection when handling a substance that poses a serious risk of eye damage.

Data sheets tend to recommend PPE even when there is no effect.What the supplier must address in his technical data sheet are all possible uses of the substance.

Evaluate the outcome based on what you are doing and take appropriate action. The two may not be the same and your PPE requirements must match the latter.

All risk management measures must focus on effectiveness and implementation. If you avoid the above pitfalls, you are well on your way to good control of hazardous substances in your workplace.

The six essential elements of COSHH

History of COSHH

The doctor. Adrian Hirst speaks to industry experts about how COSHH has improved workplace health and what further action is needed.

COSHH is such an integral part of today's confrontation with occupational exposure to hazardous substances that one might wonder what it was like before 1989.

Martin Stear, Co-Director of WES,anan independent occupational hygiene advice and registration office of the BOHS Faculty for Occupational Hygiene:

“Employers were still required to conduct assessments under the Occupational Health and Safety Act 1974 (HSWA) and the Factory Act 1961.

"It would be wrong to say that industry hasn't done much, but COSHH has brought more prominence to hazardous substances and encouraged employers to focus better on what is already in the law."

El Morgan CEO Lynne Morgan notes that the same hierarchy of controls was used for all types of industrial hygiene surveys and audits:

"We just didn't do full, formalized written risk assessments."

Tracey Boyle, Coder von WES, The arrival of COSHH in 1989 was "a wake-up call" for the industry.

“The interest was great. COSHH was widely publicized and viewed as the greatest thing since HSWA.

“The unions were very enthusiastic about the legislation.

"People in the industry had concerns about how the new laws would be administered and enforced by employers."

Andy Gillies, Managing Director of Gillies Associates Ltd and The Dow Chemical Company, where his role was specifically created due to a perceived need for insider knowledge of how to successfully implement COSHH:

“The Dow Chemical Company took the introduction of COSHH very seriously. We all knew what was coming and what was needed. Businesses were looking for an efficient way to implement regulations – particularly around risk assessment, training and record keeping.

“Risk assessment has been a cornerstone of COSHH from the start, but we have built on the work already done.”

Looking at the key developments in the COSHH regime over the past 25 years, a frequently highlighted change is the introduction of control tapes - a technique used to guide the assessment and management of risks in the workplace.

In 1998, BOHS published a series of articles that were central to the early development of the control band approachThe annals of industrial hygiene; Of course, control banding is becoming widespread in the COSHH Essentials regime today, as are other control banding approaches used around the world.

Commenting on the approach, Mr Gillies says: “In the early days of COSHH, people were overwhelmed by the sheer volume of substances. With the advent of control striping, people realized that substance labeling could be a manageable way to deal with many different substances.

“Today we see the use of security tapes in a variety of settings including the pharmaceutical, fine chemical and specialty chemical industries. It can be very useful, although it can also be misused, so care should be taken when using it.”

Carcinogens Directive

Another welcome development, as far as many occupational hygienists are concerned, relates to the changes made to COSHH to implement theUK Carcinogens Directive.

In particular, the current list of known carcinogens in COSHH Schedule 1 has proved invaluable in clarifying the status of certain substances as dangerous carcinogens and thereby improving the control of carcinogen exposure under the COSHH regime.

Other important changes were the replacement of maximum exposure limits and occupational exposure limits with occupational exposure limits and the introduction of principles of good practice as set out in Annex 2A. Both changes were included in the 2002 COSHH Regulations, as amended, which came into force in 2005.

The shift in focus achieved by the appearance of Appendix 2A for COSHH in the list of eight principles of good control practice was important in terms of assessing controls rather than just emphasizing exposure limits, Ms Junge notes.
"In a practical workplace situation, it's easier for inspectors to see if people are following the eight principles of good inspection practice than to focus on air sampling levels," she says. "The changes have also helped to list exactly what good control should look like."

This view is supported by Mr Stear, who says he often refers employers to the eight principles of good control practice when proposing changes to workplaces, rather than just focusing on exposure limits.

When asked what COSHH has achieved over the past 25 years, a spokesman for the Health and Safety Executive (HSE) replied: “HSE statistics show that cases of work-related ill health have generally declined over the past 25 years. 10 years, although given the high numbers, more can and must be done to make further improvements.”

Gillies says of the legislation:

“COSHH has been an important factor in improving health standards in the workplace. If it weren't for COSHH, there would be far less incentive to make improvements.”

Along the same lines, Mrs Boyle believes that COSHH has raised awareness of hazardous substances in the workplace, although she still believes there is still work to be done. "Before COSHH, people were more focused on highly hazardous substances like asbestos and lead, and it was quite difficult to enforce controls for other hazardous substances," she says.

“The HSWA was all implicit and the good thing about COSHH is that the regulations make the control of hazardous substances explicit. It also covered all hazardous substances and not specific ones like lead, asbestos and so on. It's really got people thinking about what they wear to work or their business."

Despite these advances, many occupational hygienists believe there is still a gap between small and large companies, which COSHH has achieved. Large companies have been doing good work in risk management of hazardous substances for 25 years.

However, there are concerns that smaller businesses will need to deal with hazardous substances, which is why initiatives such as the HSE's COSHH Essentials guide and personalized COSHH support on the HSE website are very welcome for smaller businesses such as hairdressers, beauticians, caterers and bakeries.

Gillies warns: “Even now, 25 years later, some companies are still unfamiliar with COSHH and lack an understanding of the fundamentals – like risk assessments. Businesses may think they need to do a lot of paperwork instead of focusing on making the risk assessment practical and relevant.”

After a quarter of a century, one would expect the COSHH regime to be running smoothly. However, occupational hygienists continue to report a lack of understanding of their core principles and emphasize the ongoing need for better mastery of the regulations.

Niall Evans, Managing Director of Epsilon Training and Consultancy Ltd and former HSE Lead Expert Inspector, says: “Many people and companies struggle to understand the requirements of the regulations and see them as an exercise in simply registering the substances used. They usually contain chemicals that are not harmful to health and some that do not pose other hazards such as flammability. For most, deciding the level of risk and appropriate controls is a headache. Many, of course, rely too much on personal protective equipment.”

Woman. Boyle, another former HSE inspector, would like to see something explicit in COSHH in the future mandating the use of qualified occupational hygienists for situations that require such expertise.

"Sometimes you see bad advice from people who aren't competent," she says. “The employer then spends a lot of money based on this advice, for example to build a specific local exhaust system that will never work. I have seen hundreds of thousands of dollars spent on systems that do not control exposure and shocking reports from people who are not competent to advise on industrial hygiene issues.”

BOHS President Mike Slater believes there is an urgent need for better enforcement of COSHH legislation going forward, arguing that research has shown compliance with some elements of COSHH makes shocking reading.

"In the research of Dr. Lesley Rushton, compliance for workplace silica exposure was estimated at just 33%,” he concludes.

"The COSHH regime can only be as strong as its weakest link, and we believe robust enforcement to improve employer compliance is critical to the future success of COSHH."