We’ve recently been taking a detailed look at COSHH (Control of Substances Harmful to Health) regulations. There are eight steps to take in order to comply with COSHH. You can read about the first two steps – ‘Risk assessment’ and ‘Decide on which precautions to take’ here, and in this article we’re looking at steps three and four: ‘Prevent or control exposure’ and ‘Ensure the controls you put in place are used and maintained’.
How to comply with COSHH Regulations: Step 3
Prevent or control exposure to hazardous substances
Having conducted a risk assessment and decided on what precautions you need to take, you then need to either prevent or control exposure of your employees – and anyone else who visits your premises – to the hazardous substances you’ve identified.
These prevention or control measures are generally to do with the equipment you use and how you use that equipment. You need to choose the right equipment along with the right way of working to create a standard operating procedure (SOP).
Not only must you write the SOP but you must also train and supervise employees who work with these procedures, ensuring that they are robust and work at all times.
What are control measures?
COSHH regulations provide a list of control measures you could take (if it is practicable to do so), and place them in order of priority with the best measure in the number one spot:
- Use a different, safer product which does the same thing as the hazardous substance you’ve identified – this is total prevention of exposure to a hazardous substance
- Use a safer version of the same product, for example a paste instead of a powder
- Change your processes so less of the substance is released
- Control exposure at the source so the substance cannot escape
- Extract any emissions
- Reduce the number of employees who are exposed to the substance
- Provide personal protective equipment (PPE) such as gloves, safety glasses, and overalls
Steps two to seven are listed under ‘adequate control’ which means that exposure cannot be completely prevented, but it can be controlled to the extent that working with the substance is manageable.
When you consider how to put in place prevention or control measures in place, you should reference the following:
- Occupational exposure standards (OES) – substances conforming to an OES standard are not likely to cause health damage from exposure by inhalation over a prolonged period of time. You should comply with the OES related to the substance you are using, if it has one.
- Maximum exposure limits (MEL) – substances with a maximum exposure limit are ones which cause the most serious health effects, such as cancer and occupational asthma, and are too hazardous to be classified with an occupational exposure standard. You must reduce exposure as much as possible and so it is below the maximum exposure limit.
- Dermal absorption – some substances can damage skin or easily penetrate it to become absorbed into the body. You must put control measures in place that protect the skin.
There are many different types of control equipment. It can include:
- Ventilation to extract dust, mist and fume
- Spray booths
- Fume cupboards
- Using water to reduce dust
- Disinfecting systems
You will also need the user manual for each item of control equipment you have. Use this so you know how and when to check the equipment, how to maintain it, and how and where to get spare parts. If your equipment has defects, make sure they are fixed quickly and efficiently. It’s also best-practice to keep a record of any checks you make to your equipment as well as any actions you need to take from these checks.
How to comply with COSHH Regulations: Step 4
Ensure the controls you put in place are used and maintained
You must ensure that your employees use the control measures you put in place, and you must also ensure they are kept in good working order.
Using control measures
It is the responsibility of the employer to make certain that employees use control measures properly and report any defects. You should take all reasonable steps to ensure that this is done, including providing compulsory training, information, and supervision to employees at risk of being exposed.
Maintaining control measures
Once your control measures are in place, you or someone with the appropriate knowledge and skills that you nominate must make sure they are maintained as originally intended. This applies to both equipment and processes. Regular checks should take place, and equipment such as personal protective wear should be examined and tested to ensure they are still effective. You must also keep records of all examinations and tests you conduct for a minimum of five years.
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