COSHH RISK ASSESSMENT GUIDE July 2004

Transcription

1 COSHH RISK ASSESSMENT GUIDE July 2004 Introduction This document is meant to give an overview of the COSHH risk assessment process within the Royal Free and complements the trust s Code of Practice for the safe use of substances hazardous to health. It is based on the Royal Free proforma. Use of this proforma is not compulsory, but every assessment must, as a minimum, address the issues contained in it. It does not purport to be a training guide or to address all the issues that may present themselves. Assessors are expected to have attended a suitable training course. The risk assessment process There are four fundamental principles behind the Royal Free COSHH risk assessment process: 1. It is the activity, and not just the substance, that is the basis for the risk assessment. This is because exposure is greatly influenced by the way the work is carried out and the control measures in use. Hence a substance cannot be assessed in isolation from the process in which it is being used. 2. Assessment means a critical examination of the existing process, work practices and controls to make sure that they are satisfactory; it is not sufficient to merely collect data and then assume that, because the process is running, it must be alright. 3. The assessment task should be broken down into chunks or small enough units to be managed. The next step is to break down each activity into discrete sub-activities or job steps and then to assess the risk from each step. 4. To use proformas to ensure that the same questions are asked every time and that no point is overlooked. This enables even the simpler assessments to be recorded; this is desirable because it enables records to be kept and displays the reasoning at the time. The HSE has published guides to risk assessment in which it identified 5 steps in the process: Step 1: look for the hazards Step 2: decide who might be harmed and how Step 3: evaluate the risks and decide whether existing precautions are adequate, or whether more work needs to be done Step 4: record the findings Step 5: review the assessment and revise if necessary. It should be noted that the steps are not all of the same length or degree of difficulty. The HSE model assumes that the assessor already has a clear idea of what is to be assessed. This is not always the case and so we suggest there is a preliminary step, COSHHRAguide Page 1 of 1

2 called Step 0 here, which is to clearly identify the activity that is being assessed and all the component job steps that make up that activity. Guidance on completing the proforma Notes 1. Every section must be completed. This is to show that every question has been addressed and answered. 2. The first page contains administration information. Experience has shown that it is helpful to have the review dates and the summary of additional actions on the front sheet because it is much easier to check on progress, especially if a number of assessments are being dealt with. 3. To use the proforma as an on-line form, assessors need to lock the form. (From the menu bar select: View Toolbars Forms, then click on the padlock symbol). The yes/no boxes can then be checked/unchecked using the x key on the keyboard; pressing the tab key will move the cursor forward to the next section; shift+tab moves it back to the previous section. Step 0 activity (PAGE 1) Identify the activity and all the ancillary job-steps. For example: Activity: disinfection of a microbiological cabinet with formalin. Job step 1: handling the formalin solution. Where is it stored, where is it poured out etc Job step 2: preparing the cabinet sealing apertures etc Job step 3: disinfection Job step 4: evacuation of the formaldehyde from the cabinet If the activity is complex, with a large number of job steps, it may be easier to use a separate assessment form for each job step. This is particularly the case where there is significant risk arising from one or more job steps. Step 1 hazards (PAGE 2) Substances State the substances involved in each job step. Note the word involved ; it is important to keep in mind any hazardous substances that might be formed or altered during the activity. Note that there are additional requirements under COSHH for asthmagens, carcinogens and biological agents. The additional precautions should be documented on a separate sheet and attached to the assessment. Hazards The hazardous properties of the substances should be recorded. The manufacturers have a duty under the CHIP 1 regulations to provide this information. You should have a material safety data sheet; the relevant Risk and Safety phrases should also be on the 1 Chemicals (Hazard Information and Packaging for Supply) Regulations 2002 COSHHRAguide Page 2 of 5

3 label of the container. These may only be given as a reference number and may require looking up. Blood and blood products should always be regarded as potentially contaminated. Three of the hazard classifications for substances carcinogen, mutagen, toxic for reproduction, are subdivided into 3 categories which are numbered 1, 2, or 3. Category 1 is the most hazardous and category 3 is the least hazardous. This contrasts with the four hazard groups used for categorising biological agents, where hazard group 1 is the least hazardous and hazard group 4 is the most hazardous. Exposure limits (OES/MEL) The HSE has set exposure limits for some airborne substances; these are either an Occupational Exposure Standard (OES) or a Maximum Exposure Limit (MEL). Exposure to a substance with an OES should not exceed the OES value. Exposure to a substance with an MEL must be kept below the set value and be as low as is reasonably practicable. Exposure limits may be found in HSE guidance EH40, which is updated every year. Some substances are also given an Sk notation where skin exposure may give rise to significant uptake of the substance into the body. Routes of entry This is the term used to denote how the substance enters the body. Recognition of the routes of entry is important because the control measures needed will be different for each of the routes. It should be noted that the routes of entry may not be the same for every job step. The routes of entry in a given situation are affected by the physical, chemical and biological properties of the substance and the way the substance is being used. For example a liquid with a low boiling point is likely to create more vapour than one with a high boiling point. Solids being weighed are more likely to spread into the air or on to the workbench because of air currents and static electricity effects if they are in the form of a fine powder rather than being coarse-grained or pellets. The main routes of entry are: Inhalation Skin absorption Injection Eye contact (from splashes) Ingestion Additional requirements COSHH requires additional precautions if any of the substances cause asthma (asthmagens) or cancer (carcinogen) or are biological agents. The additional precautions that have been taken should be recorded on a separate sheet and attached to the assessment. Other hazards It is useful to identify other non-coshh hazards here because it enables the assessor to check that the other hazards have been adequately catered for and will not create COSHHRAguide Page 3 of 5

4 additional hazards. Risk assessments relevant to the activity should be mentioned in the precautions box. Step 2 persons at risk (PAGE 2) It is necessary to consider who might be harmed and how. In addition to the people actually carrying out the activity, there may be others, such as colleagues on neighbouring benches. Cleaners form another group. Are there special groups of people who might be harmed? Two examples of such groups (both of which are described in the Management of Health and Safety at Work Regulations 1999) are New or Expectant Mothers and Young People. Step 3 existing precautions (PAGES 2 & 3) Step 3a the activity itself (PAGE 2) The precautions have been broken down into various categories. Engineering measures in laboratories are usually containment and/or ventilation in cupboards or cabinets. Other forms of local exhaust ventilation (LEV) are more common in non-laboratory situations. General ventilation relies on a good flow of air into the room to dilute any contaminants to a safe level; it is only suitable for low-hazard substances. The need for health surveillance should be mentioned in the safety data sheet. The Occupational Health Department should be consulted if health surveillance is required, or if there is any doubt. There may be occasions when the air in the room needs to be analysed to check on the concentration of an air-borne substance. Advice should be sought from the Safety Office. It should be remembered that personal protective equipment (PPE) should be the last resort. The type and grade of PPE in use should be recorded. This is important because most PPE is available in various grades and they may not all be suitable (eg respiratory protection disposable masks are available in 3 grades, each offering a different degree of protection. In addition, fit-testing is required to make sure the mask fits the person.) There is liable to be splashing if liquid is being transferred from one vessel to another (including by pipette), and so the eyes will usually need protecting, especially in laboratories. Blood splashes to the eye are common and so eye protection is called for in most activities involving transfer of blood. Step 3b emergencies (PAGE 3) first aid We need to consider if there is any special treatment needed as part of first aid, or later (for example skin contact with hydrofluoric acid requires the repeated application of a special gel). spillage How is a spillage to be treated? What quantity is liable to be spilled? Note - this may be considerably more than the quantity declared in step 1. For example the process may only require 25ml of a liquid, but it may be taken from a 2.5litre Winchester bottle. Are break-resistant bottles used? If not, why not? COSHHRAguide Page 4 of 5

5 Step 3c disposal (PAGE 3) How are the substances disposed of? Does this also apply to any spilled material? Step 3d assessment (PAGE 3) This is probably the most difficult step. The previous steps have been gathering data. Here, we have to decide if the precautions, emergency procedures and disposal practices are suitable. It they are not, what more should we be doing? Each of the hazards should be considered against the existing precautions for that hazard and the expected route of entry to make sure they match (for example, gloves will not give protection if inhalation is the only route of entry.) It will probably be necessary to continue on a separate page. Where the situation is not clear-cut, the assessor should record the options, concerns, etc along with an analysis of why a particular option was selected. This will be of great help in the future; both at the next review, and also if there are queries from interested parties, for example the HSE. Step 3e further actions (PAGE 1) The previous step should have shown where the deficiencies are and what further actions are needed. The actions are recorded on the front page because it is much easier to check on progress in the future. Similarly, it is very helpful to know who is responsible for taking the actions and the target date for its completion. The final column allows for the recording of the actual completion date. This is very important because it helps the person who is monitoring the actions to keep a check on progress. It also helps during the review process. Step 4 record We take step 4 as we complete the form. The total number of pages making up the assessment should be recorded in the appropriate box on page 1. Step 5 review (PAGE 1) The assessment should be reviewed if changes are made to the activity. Failing that, there should be a review every year to make sure that changes have not crept in unnoticed. If changes have been made, the assessment should be revised. COSHHRAguide Page 5 of 5