Working with hazardous substances is a reality for many businesses across the UK. From cleaning products and paints to chemicals used in manufacturing, these substances can pose significant risks if not properly managed. This is where the Control of Substances Hazardous to Health (CoSHH) Regulations come into play, requiring employers to assess and control exposure to hazardous substances.
What is CoSHH?
The Control of Substances Hazardous to Health (CoSHH) Regulations 2002 (as amended) are UK regulations that require employers to protect workers from the risks of hazardous substances. These regulations apply to nearly all workplaces and cover substances that are:
- Chemicals
- Products containing chemicals
- Fumes
- Dusts
- Vapours
- Mists
- Nanotechnology
- Gases and asphyxiating gases
- Biological agents (such as bacteria and viruses)
CoSHH doesn’t cover lead, asbestos, or radioactive substances, as these are covered by separate regulations.
Why is a CoSHH Risk Assessment Important?
A CoSHH risk assessment is not just a legal requirement—it’s a crucial part of ensuring workplace safety. It helps you:
- Identify hazardous substances in your workplace
- Determine how these substances might harm employees and others
- Decide what precautions are needed
- Prevent or adequately control exposure
- Ensure control measures are used and maintained properly
- Monitor exposure
- Carry out appropriate health surveillance
- Inform and train employees about the risks and precautions
Key Elements of a CoSHH Risk Assessment
To help you better understand a CoSHH risk assessment, here are the key elements.
1. Identifying Hazardous Substances
The first step is to identify all hazardous substances used or created in your workplace. Consider:
- Products you use (check the safety data sheet—every hazardous substance should have one)
- By-products or waste generated during processes
- Naturally occurring substances like grain dust or stone dust
- Biological hazards like bacteria or viruses
For each substance, gather information about:
- The form it takes (solid, liquid, gas, dust, fume, etc.)
- How it could enter the body (inhalation, skin contact, ingestion)
- What harm it could cause
- How it’s stored and used
2. Assessing Exposure
Once you’ve identified the substances, assess how they might cause harm:
- Who might be exposed? Consider employees, visitors, contractors, and the public
- How might they be exposed? Through breathing in, skin contact, splashes, ingestion?
- How often and for how long are they exposed?
- What are the likely routes of exposure?
- Are there any particularly vulnerable individuals?
- What current control measures are in place?
3. Evaluating Risks
Using the information gathered, evaluate the risks:
- How severe are the potential health effects?
- How likely is exposure to occur?
- Are existing control measures sufficient?
- What is the overall risk level?
Consider both acute (immediate) and chronic (long-term) health effects, as well as the risk of fire or explosion where relevant.
4. Deciding on Control Measures
The law requires you to follow a hierarchy of control:
- Elimination: Can you eliminate the use of the hazardous substance entirely?
- Substitution: Can you replace it with a less hazardous alternative?
- Engineering controls: Can you enclose the process or use local exhaust ventilation?
- Administrative controls: Can you limit the time workers are exposed or establish safe working procedures?
- Personal Protective Equipment (PPE): As a last resort, can appropriate PPE protect workers?
Your assessment should clearly describe what control measures are required, who is responsible for implementing them, and when they should be in place.
5. Recording the Assessment
Your CoSHH assessment must be documented if you have five or more employees. Good practice suggests recording it regardless of company size. Include:
- The hazardous substances present
- The risks they pose
- Who might be harmed and how
- The control measures implemented
- Monitoring procedures
- Health surveillance arrangements
- Emergency procedures
6. Implementing Controls
After documenting your assessment, you must implement the identified control measures. This might involve:
- Purchasing new equipment
- Modifying processes
- Providing training
- Establishing new procedures
- Supplying and maintaining PPE
7. Reviewing and Updating
CoSHH assessments are not one-time exercises. They should be reviewed:
- Regularly (at least every 5 years)
- When work processes change
- When new substances are introduced
- After accidents or near misses
- If health surveillance indicates a problem
- If new information becomes available about the hazards of a substance
Practical Steps to Conduct a CoSHH Assessment
Follow these steps to complete your own CoSHH risk assesment:
Step 1: Gather Information
- Collect safety data sheets for all substances
- List all processes that use or generate hazardous substances
- Observe work practices
- Talk to employees about how they use substances
- Review accident records and health surveillance results
Step 2: Complete the Assessment Form
A typical CoSHH assessment form includes:
- Substance details and hazards
- Those at risk
- Current control measures
- Assessment of whether controls are adequate
- Additional controls required
- Emergency procedures
- Monitoring requirements
- Health surveillance needs
- Name of assessor and date
- Review date
Step 3: Implement the Controls
- Prioritise controls based on risk level
- Assign responsibilities for implementation
- Set deadlines
- Provide necessary resources
- Deliver training
- Document everything
Step 4: Communicate the Findings
- Share the assessment with all affected employees
- Provide training on the hazards and control measures
- Display information at point of use where appropriate
- Ensure everyone knows what to do in an emergency
Step 5: Monitor and Review
- Check that control measures are being used correctly
- Monitor exposure levels if required
- Conduct health surveillance if necessary
- Review the assessment periodically or when circumstances change
Common Mistakes to Avoid
- Copy-pasting generic assessments: Every workplace is unique, and assessments should reflect your specific situation.
- Focusing only on the obvious: Don’t overlook substances created during processes or naturally occurring hazards.
- Relying solely on PPE: Remember the hierarchy of control—PPE should be the last resort.
- Forgetting about maintenance: Control measures like local exhaust ventilation need regular testing and maintenance.
- Not involving workers: Those who use the substances often have valuable insights into practical control measures.
- Filing and forgetting: Assessments should be living documents that are regularly reviewed and updated.
Conclusion
A thorough CoSHH risk assessment is essential for protecting your workforce from the risks of hazardous substances. By systematically identifying hazards, evaluating risks, and implementing appropriate controls, you can create a safer workplace and comply with legal requirements.
Remember that CoSHH assessments should be specific to your workplace, regularly reviewed, and communicated effectively to all employees. Done properly, they are a valuable tool for managing workplace health and safety, not just a box-ticking exercise.
By following the steps outlined in this article, you’ll be well on your way to creating comprehensive CoSHH assessments that protect your workers and comply with UK legislation.
Our accredited CoSHH Awareness Training Course will help you to take effective steps reduce the risks of exposure and to protect health of yourself and others in your workplace.
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