Control of Substances Hazardous to Health (COSHH) Code of Practice 3.8

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1 Control of Substances Hazardous to Health (COSHH) Code of Practice 3.8 Distribution: To be brought to the attention of all Heads of Service, Headteachers, Managers, Supervisors, employees and trade union representative involved in using hazardous substances or undertaking work processes that generate or may result in exposure to hazardous substances. Introduction This code of practice has been developed to provide guidance about work with substances that are hazardous to health and identifies what is required of Managers to ensure compliance with the requirements of the Control of Substances Hazardous to Health Regulations 2002 (amended). Contents What are substances hazardous to health? Page 1 Risk Assessments Page 2 Prevention and control of exposure Page 3 Maintenance and records of control measures Page 4 Health Surveillance Page 6 Information, Instruction & Training. Page 6 Appendix 1 Schedule 2 of the COSHH Regulations Page 7 Appendix 2 Example CARQ Form Page 8 Appendix 3 Example COSHH Assessment Page 9 Appendix 4 Medical Surveillance requirements Page 10 What are substances hazardous to health? The COSHH regulations apply to a very wide range of substances and preparations mixtures of two or more substances with the potential to cause harm if they are inhaled, ingested or come in contact with or are absorbed through the skin, for example, *Solids *Dusts *Vapours *Fumes *Liquids *Fibres *Gases *Mist *Smoke These include individual chemical substances or preparations such as paint, cleaning materials, pesticides and insecticides. Substances hazardous to health can occur in many forms. Under the Chemicals (Hazard Information and Packaging for Supply) Regulations 2002, chemicals may be classified as very toxic, toxic harmful, corrosive, irritant, sensitising, carcinogenic, mutagenic or toxic to reproduction. Sunderland City Council 1

2 Dust of any kind can also become a substance hazardous to health when it is present in concentrations in the air equal to or greater than 10mg/m 3 time weighted average over an 8hour period of inhalable dust or 4mg/m 3 of respirable dust, time weighted average over an 8hour period. Further advice is available from the Corporate Health & Safety Team. Dust is produced by many Council processes, including material removal, e.g. grinding, sanding, abrasive cutting and blasting, buffing and polishing; and also in school woodworking shops. Any Biological Agents which include bacteria, viruses, fungi and parasites are classified as substances hazardous to health as is any substance for which a workplace exposure limit has been set. Schedule 2 of the regulations prohibits the use of certain substances for particular purposes see Appendix 1. COSHH Risk Assessments The purpose of a COSHH risk assessment is to enable Managers to make an informed decision about the measures necessary to prevent or adequately control the exposure of their employees to substances hazardous to health arising from work activities. The Council subscribe to the Sypol Chemical Management System. This system provides Managers with electronic COSHH Assessments for a wide range of chemical substances and preparations, dusts, gases and fumes, which meet the requirements of the regulations and incorporates the use of pictograms which are easy to understand. The system is managed by the Corporate Health & Safety Team. Managers in each Directorate must identify all substances used that have the potential to be hazardous to health. A COSHH Assessment Request Form (CARQ) see Appendix 2 should then be completed and forwarded to the Health & Safety Assistant in the Corporate Health & Safety Team together with a recent material safety data sheet for the product. The CARQ form is available from the Health & Safety Team and on the Intranet (under E-Forms, Forms and Templates on page 3 titled 'COSHH Assessment Request Form') The material safety data sheet should be supplied with the product from Central Purchasing or the manufacturer and should not be over 5 years old. The CARQ form requires information regarding how the product will be used or how the process will be carried out the quantity used in one working day, employee exposure time, how and where the product is used, work practice information and any existing control measures in place. Based on this information a COSHH assessment will be generated. Accurate, complete and correct information is essential as over-classification of a substance might lead to unnecessarily stringent controls, while under-classification may result in risks to employees' health. An assessment cannot be carried out without all of this information. Sunderland City Council 2

3 Once this information has been put through the Sypol system an assessment is produced. The assessment details the risks to health from the product, exposure limits and emergency details. It also details any necessary control measures and indicates any other areas, such as health surveillance, that managers should give further consideration to. There is an example of a COSHH assessment in Appendix 3. As with all risk assessments they should be reviewed annually, or when a procedure or product changes or after an accident or incident. They should also be reviewed immediately if there is evidence to suggest they may not be valid from results of monitoring exposure or health surveillance. The Health & Safety Team also receives updates from Sypol of any significant changes to products which will automatically be sent to all managers. Prevention & Control of Exposure The regulations require that the exposure of employees to substances hazardous to health is either prevented or where this is not reasonably possible, adequately controlled. Prevention Managers should first consider eliminating the use or production of substances hazardous to health in the workplace by: a) Changing or modifying the method of work so that exposure is no longer necessary b) Substituting with a non hazardous substance which prevents no risk to health. However this is not always operationally possible and therefore managers should consider how to reduce exposure by: - using an alternative substance the Council requires that where possible solvent based products such as paints, cleaning and degreasing agents, adhesives, inks and ink removers should be replaced with solvent free alternative. The Council also prohibit the use of bleach in its premises and Managers are advised to replace it with a chemical less harmful. - A different form of the same substance e.g. using a solid form rather than a powder form. - Using a different process e.g. dipping instead of spraying. Control Adequate control of exposure should be achieved with measures other than the use of Personal Protective Equipment, which should be used as a last resort and then in addition to other control measures. Managers may have to consider any combination of the following control measures. 1. Totally enclosed processes and handling systems Consider if the process can be carried out away from people or in automatic spraying, mixing, dispensing units. 2. General and Local Exhaust Ventilation Sunderland City Council 3

4 3. Reducing the minimum required for the work in terms of employees exposed, level and duration of exposure and the quantities produced. 4. Good Housekeeping regular cleaning and decontamination of walls and surfaces and the provision of safe storage and disposal of substances hazardous to health. 5. Hygiene measures adequate facilities for washing, changing and storage of clothing and personal protective equipment and where appropriate prohibiting employees from eating drinking and smoking in contaminated areas which may result in the ingestion of hazardous substances. Workplace Exposure Limits The Health & Safety Commission has established Workplace Exposure Limits (WELs) for a number of substances hazardous to health. These are intended to prevent excessive exposure to specified hazardous substances by containing exposure below a set limit. A WEL is the maximum concentration of an airborne substance averaged over a reference period, to which employees may be exposed by inhalation. WELs should not be considered a hard and fast line between safe and unsafe. The principles require the degree to which exposure is reduced below the WEL to be proportionate to the health risk. If managers apply the principles of good practice for the control of substances hazardous to health correctly, exposure should be below any relevant WEL. Further advice can be obtained from the Corporate Health & safety Team and a list of approved workplace exposure limits is available on the HSE website If the risk assessment shows these limits are likely to be exceeded then managers must take steps to reduce employee exposure below the limits. Maintenance of Control Measures Managers and supervisors must ensure that any control measure identified in the risk assessments are properly used, applied and maintained. All employees have a duty to make full and proper use of any control measure provided. Personal Protective Equipment (PPE) Where PPE and RPE (respiratory protective equipment) has been identified as necessary in the risk assessment Managers should refer to the Councils Personal Protective Equipment Code of Practice for guidance in selection, use, maintenance and storage. Local Exhaust Ventilation (LEV) All Local Exhaust Ventilation systems should be visually checked at least once a week to ensure all visible items are functioning correctly and in accordance with the manufacturer s recommendations. It is also a legal requirement that LEV has a thorough examination by a competent person at least once every 14 months. Contractors carrying out such examination and tests must have adequate knowledge, training and expertise in examination methods and techniques and should provide a suitable record of examination Sunderland City Council 4

5 which should be retained on site for examination. All such records should be kept for at least 5 years. Sunderland City Council 5

6 Health Surveillance The objectives of health surveillance are to protect the health of employees by detecting as early as possible adverse changes which may be caused by exposure to substances hazardous to health and to help evaluate whether the control measures in place are appropriate. Appendix 3 gives examples where health surveillance is appropriate under the criteria in the COSHH Regulations. There are a number of Health Surveillance techniques and procedures that can be used and the most suitable one chosen will depend on the particular workplace circumstance. The Occupational Health Unit will give advice to managers and carry out Health Surveillance procedures when necessary. Information Instruction & Training Information It is a requirement of the COSHH regulations that employers who undertake work that is liable to expose an employee to a substance hazardous to health shall provide suitable information, instruction and training. The information they need to be aware of is detailed on the COSHH assessment and should be brought to the attention of all staff via team meetings or tool box talks. Those staff working off site should be given a personal copy of the COSHH assessment to refer to. Instruction & Training Managers must ensure that employees receive adequate Instruction and training to ensure that they do not put themselves or others at risk through exposure to substances hazardous to health. They must be made aware of how and when to use the control measures identified in the COSHH assessment, any defined methods of work, how to use PPE correctly, cleaning, storage and disposal procedures and emergency procedures to follow. Further Information and Advice Is available from the Corporate Health and Safety Team, Corporate Personnel Services, Telephone or Sunderland City Council 6

7 Appendix 1 - Prohibition of certain substances hazardous to health for certain purposes. This list is not exhaustive and only contains those substances that may be used in Council processes. The full table can be found in Schedule 2 of the Control of Substances Hazardous to Health Regulations Regulation 4(1) Description of substance Purpose for which the substance is prohibited Sand or other substance containing free silica. A substance - (a) Containing compounds of silicon calculated as silica to the extent of more than 3 per cent by weight of dry material, other than natural sand, zirconium silicate (zircon), calcined china clay, calcined aluminous fireclay, sillimanite, calcined or fused alumina, olivine; or Use as an abrasive for blasting articles in any blasting apparatus. Use as a parting material in connection with the making of metal castings. (b) Composed of or containing dust or other matter deposited from a fettling or blasting process. Oils other than white oil, or oil of Entirely animal or vegetable origin or entirely of mixed animal and vegetable origin. Use for oiling the spindles of self-acting mules. Hydrogen cyanide. Use in fumigation except when - (a) released from an inert material in which hydrogen cyanide is absorbed; (b) generated from a gassing powder; or (c) applied from a cylinder through suitable piping and applicators other than for fumigation in the open air to control or kill mammal pests. Cement and cement-containing preparations which contain, when hydrated, more than % soluble chromium (VI) of the total dry weight of the cement. Purpose for which the substance is prohibited Supply and use for all purposes except for controlled, closed and totally automated processes in which cement and cementcontaining preparations are handled solely by machines and in which there is no possibility of contact with the skin. Sunderland City Council 7

8 Appendix 2 Sunderland City Council 8

9 Sunderland City Council 9

10 Appendix 4 - Medical surveillance Regulation 11(2)(a) and (5) This list is not exhaustive and only contains those substances that may be used in Council processes. The full table can be found in the in Schedule 6 of the Control of Substances Hazardous to Health Regulations Substances for which medical surveillance is appropriate Vinyl chloride monomer (VCM). (Used to produce PVC) Ortho-tolidine and its salts. Dianisidine and its salts. Dichlorobenzidine and its salts. (a chemical re agent used to test the total chlorine level in pool/spa water) Carbon disulphide. Disulphur dichloride. Benzene, including benzol. Carbon tetrachloride. Trichloroethylene. (Used in fumigants) Pitch. Process In manufacture, production, reclamation, storage, discharge, transport, use or polymerisation. In manufacture, formation or use of these substances. Processes in which these substances are used, or given off as vapour, in the manufacture of indiarubber or of articles or goods made wholly or partially of indiarubber. In manufacture of blocks of fuel consisting of coal, coal dust, coke or slurry with pitch as a binding substance. Sunderland City Council 10

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