HAZARDOUS SUBSTANCES RISK ASSESSMENT

HAZARDOUS SUBSTANCES RISK ASSESSMENT Plymouth City Council Health & Safety Performance Standard (HSPS 04) April 2006

CONTENTS Section Page A Introduction 2 B Who should do Hazardous Substances risk assessment? 5 C Guidance on assessment requirements & training 5 D How to get started initial inventory 6 E Recording assessments Hazardous substances risk assessment form 8 F Assessment procedure: step-by-step approach 10 Step 1: Assess the risks by process/activity 10 Step 2: Identify relevant legislation/standards/best practice 11 Step 3: Prevent or adequately control exposure 12 Step 4: Ensure that control measures are used/maintained 14 Step 5: Monitor exposure 14 Step 6: Carry out appropriate Health Surveillance 15 Step 7: Prepare plans/procedures for accidents/emergencies 15 Step 8: Inform, train & supervise staff 16 Step 9: Evaluate risk and decide what further action is needed 16 Step 10: Record and review assessments 19 G Informing others of assessment findings 20 H Monitoring health and safety performance 20 I Further information and guidance 21 Appendix 1 Inventory checklist 24 Appendix 2 Hazardous Substances Risk Assessment Form (HSRA1) 25 Appendix 3 Register of RISK Assessments Completed 27 Appendix 4 Example of generic hazardous substances risk assessment 28 Appendix 5 Risk phrases (file attached) 32 Appendix 6 Safety phrases (file attached) 36 Appendix 7 Hazard symbols (file attached) 38 Appendix 8 Dangerous Substances and Explosive Atmospheres Regulations (file attached) 41 Appendix 9 COSHH Principles of good practice (hierarchy of controls) (file attached) 46 HSPS04 April 2006 1

Hazardous Substances Risk Assessment Health & Safety Performance Standard. A. Introduction 1. Summary 1.1 Many substances or products used, stored, generated or disposed of at work can present risks to the health and safety of employees, non-employees and the environment. Therefore, Plymouth City Council workplaces where substances are used or stored should have an up-to-date inventory of all potentially hazardous substances on site (or used by staff), and hazardous substances risk assessment records describing the risks and control measures for safe working (this is more than just a safety data sheet). 1.2 Hazardous substances include: substances used directly in work activities (eg adhesives, paints, cleaning agents); substances generated during work activities (eg wood dust and fumes from soldering/welding); naturally occurring substances (eg grain/flour dust); biological agents (such as bacteria and fungi or moulds). 1.3 The types of substances covered by health and safety requirements of the Control of Substances Hazardous to Health (COSHH) Regulations 2002 (as amended), are: Substances or mixtures of substances classified as dangerous to health under the Chemicals (Hazard Information and Packaging for Supply) Regulations 2002 (CHIP). These can be identified by their warning label and the supplier must provide a safety data sheet for them. Many commonly used dangerous substances are listed in the HSE publication Approved Supply List. Information approved for the classification and labeling of substances and preparations dangerous for supply, as part of the CHIP package. Suppliers must decide if preparations and substances that are not in the Approved Supply List are dangerous, and if so, label them accordingly as very toxic, toxic, harmful, corrosive or irritant. Substances with workplace exposure limits are listed in the HSE publication EH40/2005 Workplace exposure limits. Biological agents (bacteria and other microorganisms), if they are directly connected with the work, such as with farming, sewage treatment, or healthcare, or if the exposure is incidental to the work (eg exposure to bacteria from an air conditioning system that is not properly maintained). Any kind of dust if its average concentration in the air exceeds the levels specified in the COSHH Regulations. Any other substance which creates a risk to health, but which for technical reasons may not be specifically covered by CHIP including: asphyxiants (ie gases which can cause suffocation such as argon and helium, which, while not dangerous in themselves, can endanger life by reducing the amount of oxygen available to breathe), pesticides, medicines, cosmetics or substances produced in chemical processes. Note Hazardous substances include those with chronic or delayed effects eg substances that are carcinogenic (cancer causing), mutagenic (can cause mutations in genetic material which may be heritable) or teratogenic (can cause non-heritable genetic mutation or malformation in a developing foetus), allergens (can cause asthma HSPS04 April 2006 2

or skin reactions such as dermatitis), mixtures of compounds, and by-products or contaminants of processes. 1.4 The COSHH Regulations apply to virtually all substances hazardous to health except: asbestos and lead, which have their own regulations; substances which are hazardous only because they are: - radioactive; - at high pressure; - at extreme temperatures; or - have explosive or flammable properties (other regulations apply to these risks); biological agents that are outside the employer s control, eg catching an infection from a workmate. (If in doubt, please contact H&S Team or Occupational Health for advice.) For the vast majority of commercial chemicals, the presence (or not) of a warning label will indicate whether COSHH is relevant. For example, there is no warning label on ordinary household washing-up liquid, so if it s used at work you do not have to worry about COSHH; but there is a warning label on bleach, so COSHH does apply to its use in the workplace. 1.5 Using chemicals or other hazardous substances at work can put people s health at risk, so the law requires employers to control exposure to hazardous substances to prevent ill health. They have to protect employees, and others who may be exposed, by complying with health and safety legislation. Examples of the effects of hazardous substances include: skin irritation or dermatitis from skin contact; asthma from contact with allergens or sensitisers; loss of consciousness from breathing toxic or asphyxiant fumes or gases; infection by micro-organisms; and burns from fires or explosions. 1.6 The legislation requiring specific actions to be taken to work safely with hazardous substances includes: Control of Substances Hazardous to Health Regulations 2002 (COSHH), Chemicals (Hazard Information and Packaging for Supply) Regulations 2002 (CHIP), Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR), Control of Lead at Work Regulations 2002 (CLAW) Control of Asbestos at Work Regulations 2002 (CAWR) The Control of Major Accident Hazards Regulations 1999 (COMAH) Regulatory Reform (Fire Safety) Order 2006 Confined Spaces Regulations 1997 Control of Pesticides Regulations 1996 The Special Waste Regulations 1996 The Health and Safety (First aid) Regulations 1981 Ionising Radiations Regulations 1999 2. Health & Safety Performance Standard for Hazardous Substances Risk Assessment (HSPS 04) 2.1 For the sake of simplicity this guidance document will use the same general term Hazardous Substances Risk Assessment for all risks related to the use of hazardous substances at work (except asbestos and radiation), regardless of whether or not those risks are covered specifically by the COSHH Regulations or other legislation. HSPS04 April 2006 3

2.2 To conduct a Hazardous Substances Risk Assessment you need to follow these ten steps: Step 1 Step 2 Step 3 Step 4 Step 5 Step 6 Step 7 Step 8 Step 9 Step 10 Assess the risks Identify relevant legislation, standards, and best practice Prevent or adequately control exposure Ensure that control measures are used and maintained Assess the risks to health and safety from hazardous substances used in or created by your work activities You must not carry out work which could expose employees or others to hazardous substances without first considering the risks and the necessary precautions, and what else you need to do to comply with the law. You must prevent employees and others from being exposed to hazardous substances. Where preventing exposure is not reasonably practicable, then you must adequately control exposure. The advice in this guidance will help you to make correct assessments and to put the appropriate controls into place. Ensure that control measures are used and maintained properly and that safety procedures are followed. (Classify places where explosive atmospheres may occur into zones, and mark the zones where necessary.) Monitor the exposure Monitor the exposure of employees to hazardous substances, if necessary. Carry out appropriate health surveillance Prepare plans and procedures to deal with accidents, incidents and emergencies Ensure employees are properly informed, instructed, trained and supervised Decide what further action is needed Record and review assessments Carry out appropriate health surveillance where your assessment has shown that this is necessary or where Regulations make specific requirements. Prepare plans and procedures to deal with accidents, incidents and emergencies involving hazardous substances, and provide equipment where necessary. You should provide employees (and nonemployees where appropriate) with suitable and sufficient information, instruction and training, to work safely and without risk to health. Identify further actions to reduce risk so far as is reasonably practicable (for carcinogens and biological agents the controls must prevent exposure risk so far as is reasonably practicable). Record significant findings of the assessment process and amend as knowledge and experience improve. Review assessments regularly and revise as necessary. Page 10 Page 11 Page 12 Page 14 Page 14 Page 15 Page 15 Page 16 Page 16 Page 19 HSPS04 April 2006 4

B. Who should do Hazardous Substances Risk Assessment? Legal responsibility for all types of risk assessment rests with the employer, but it is common for most of the work involved in doing risk assessments to be devolved down the line management chain to staff in service units. Except in very simple cases, whoever carries out the hazardous substances risk assessment will need to: have access to, and understand, the COSHH Regulations and other legislation/codes of practice/guidance, or to someone else who does; be able to get all the necessary information and have the knowledge and experience to make correct decisions about the risks and the actions needed; understand their own limitations, and know where to get help. Employees often have the most knowledge of what really happens in the workplace, and in groups can often contribute much of the information needed for hazardous substances risk assessment. This knowledge should be used before deciding whether outside help is required. If there is insufficient expertise available to assess more complex risks, competent assistance should be sought from a Trade Association, or professionally qualified Health and Safety Adviser, or Occupational Hygienist. Employees, their elected safety representatives and safety committees must be informed of the results of hazardous substances risk assessments, and should be consulted during the process. Heads of service and Head teachers may wish to appoint one or more staff to co-ordinate or specialise in hazardous substances risk assessment. Specific training courses are available from the Corporate Health & Safety Team for these risk assessments see the next Section. C. Guidance on risk assessment requirements and training In addition to the general requirement for risk assessment under the Management of Health and Safety at Work Regulations 1999, risk assessment of specific hazards is often required to be carried out in a specific way indeed, risk assessment is now a common theme of all new health and safety legislation. To make the Hazardous Substances Risk Assessment process easier, the Corporate Health & Safety Team have designed specific hazardous substances risk assessment forms and checklists (see appendices 1 and 2; all forms are available on the Health, Safety and Wellbeing Document Library on the Council Intranet). However, hazardous substances are seldom used in isolation, and a hazardous substances assessment may be required as just part of a wider reaching activity risk assessment so, the two assessment records will need to be cross-referenced. Council health and safety guidance and Performance Standards have been produced for some of the hazards that relate to the work of the Council, and additional guidance is continually being developed. Also, within Departments, local or national guidance may be available on specific risks and activities such as School Science and Design & HSPS04 April 2006 5

Technology (D&T) safety guidance from the CLEAPSS School Science Service. In Schools this guidance should be followed for science and design & technology teaching activities, and Council guidance should be applied to all other teaching activities using hazardous substances (eg art), and non-teaching activities, e.g. cleaning, caretaking, grounds keeping, volunteer work, off-site activities, etc. Before embarking on a risk assessment you should check what guidance exists, and familiarise yourself with legal requirements and relevant standards. The Corporate Health, Safety & Wellbeing Team provide an annual programme of training, including courses on how to carry out both general risk assessments and hazardous substances risk assessments. A full list of courses can be found in the current edition of the Councils Programme of Scheduled Training Courses, available from the Corporate Learning & Development Team (Human Resources) and the Council s intranet. Alternatively, please contact the Health, Safety & Wellbeing Team. D. How to get started Initial inventory i. Start by involving all staff who use (or regularly come into contact with) substances in the course of their work and use existing lists/inventories of substances/products/materials that might be hazardous. Then walk around the premises looking for other substances that may not be recorded (especially stored and unused substances, and those brought in unofficially). ii. iii. iv. Create comprehensive inventories, listing substances/materials by - product name, supplier name, total amount held, location(s), date of delivery, etc (see example in appendix 1). Ensure that up-to-date safety data sheets (or CLEAPSS HAZCARDS for science/d&t substances in schools) are available for all substances on the premises. If you do not have them, contact the suppliers and request new ones. If substances are old and the supplier is no longer in business, gather information about products/ingredients from product labels, chemistry texts or web sites, or ask the Health, Safety and Wellbeing Team (in schools ask the science staff for help). If you cannot get hold of adequate safety information, then the substance cannot be used or stored, and will have to be disposed of via a specialist hazardous waste disposal contractor. v. Identify and list all the processes/activities that use or produce hazardous substances, and arrange for appropriate disposal of all hazardous substances that are no longer used or should not be used/stored on the premises. vi. Now you can begin hazardous substances risk assessment of processes/activities (not just single substances, unless they are used alone), and storage areas. HSPS04 April 2006 6

PREDICTIVE OR DYNAMIC HAZARDOUS SUBSTANCES RISK ASSESSMENT? All employers are required by law to carry out risk assessments for substances that can harm their staff and any other people who might be affected, so when visiting other work premises, staff should ask for any hazardous substances risk assessment information for substances that might affect them. (Council staff must tell other people who might be affected, when they take hazardous substances onto other premises in the course of their work). Where Council staff regularly have to visit small business or domestic premises in the course of their work, and they can anticipate (through experience) whether they might be exposed to hazardous substances, they will need to make predictive hazardous substances risk assessments for such circumstances. If they can predict in advance, the general types of substance that they are likely to encounter, they can prepare appropriate control measures. Where staff cannot predict in advance what hazardous substances they might be exposed to they will need sufficient information, instruction and training to carry out dynamic hazardous substances risk assessment on the spot. They should know whether they are at any increased risk from particular substances due to health issues, and be prepared to take avoiding action if they cannot prevent exposure. Significant risks identified in this way should be recorded after the event as a record and for future planning. GENERIC OR SPECIFIC HAZARDOUS SUBSTANCES RISK ASSESSMENT? The HSC s Advisory Committee on Toxic Substances has developed COSHH essentials as a generic risk assessment scheme for a wide range of hazardous substances covered by CHIP and COSHH. It leads users to appropriate control advice for a range of common tasks, eg mixing, weighing, spray painting. COSHH essentials is available both in printed and electronic (web-based: www.coshh-essentials.org.uk/) formats, and can be used as a basis for the recording of the COSHH risk assessment. While COSHH essentials has been designed to ensure that a precautionary approach is taken towards control, it is a generic guide and cannot guarantee that in all circumstances it will lead to full compliance with the Regulations assessment and control requirements. Model risk assessments are used in School science and D&T activities, eg CLEAPSS Hazcards; Recipe Cards; the CLEAPSS Laboratory Handbook; Model risk assessments for Design and Technology; Primary Classroom Hazard Cards; and the DfES Safety in Science Education are standard publications of assessments made for a number of workplaces where similar activities are undertaken. Heads of Science or D&T/local managers are expected to review the model risk assessments in these publications and to consider if adaptation is necessary for local conditions. They should normally give references to the Model Risk Assessment, and to any adaptation, and be recorded on texts in daily use, with appropriate warnings. (They should also follow the guidance set out in section A3 of CLEAPSS guide L196 Managing Risk Assessments in Science for special risk assessments and non-curriculum activities in secondary/college science, and the How to use model or general risk assessments - summary section of the D&T model risk assessments.) Specific risk assessments are more appropriate where a more detailed assessment of a person, activity, event or piece of equipment is needed, and the risks involved are not HSPS04 April 2006 7

sufficiently covered by generic assessments. The hazardous substances risk assessment should determine whether there are any substances hazardous to health (including biological agents) at the workplace to which people are liable to be exposed, and in a form in which the substance can be inhaled, ingested or absorbed through the skin. Particular consideration should be given to: Activities that can give rise to the highest exposures, eg cleaning of equipment, work in confined spaces, transporting hazardous substances for work or non-routine or end-ofshift tasks. Any work activity that may expose people to more than one substance hazardous to health, where the possible enhanced harmful effects of combined or sequential exposures must be considered. Biological agents, where the assessment should reflect the ability they may have to replicate and infect (see appendix 7). Substances that are known or suspected carcinogens, where there is a more compelling reason for every effort to be made to substitute a non-carcinogenic alternative (see appendix 6). Particular groups of people who may be at increased risk, eg inexperienced trainees and young persons aged under 18; pregnant (or potentially pregnant) workers; disabled workers; and anyone known to be susceptible to certain illnesses such as dermatitis, asthma, or other diseases which may be caused or exacerbated by exposure to hazardous substances. E. Recording assessments Hazardous Substances Risk Assessment Forms It is important to have a means of easily and logically recording the relevant information from your hazardous substances risk assessments, and the format used must meet the requirements of the law. You are legally obliged to carry out a hazardous substances risk assessment, before use/possession of any hazardous substance at work, and record the significant findings of each assessment. While the legislation does not prescribe how hazardous substances risk assessments should be recorded, there are specific requirements about what should be recorded. You should use the forms designed by the Corporate Health, Safety and Wellbeing (HSW) Team that are included in this guide (see appendix 2). With the exception of CLEAPSS Hazcards in schools and HSE s COSHH essentials, if you wish to use different forms, you must discuss this with staff in the Corporate HSW Team who will advise you whether your forms are suitable. Records of hazardous substances risk assessments can be kept electronically, but they must be easily retrievable for use by staff, managers, auditors and external agencies, when required, such as the HSE or insurance assessors. I. HAZARDOUS SUBSTANCES RISK ASSESSMENT FORM (HSRA1) The Revised Council Hazardous Substances Risk Assessment Form (HSRA1) is included in appendix 2. A step-by-step explanation of how this form should be completed is given in the next section. This form is also available from the Health, Safety & Wellbeing section of the Document Library on the Council Intranet. An example of a completed hazardous substances risk assessment form is included in appendix 4. HSPS04 April 2006 8

II. REGISTER OF RISK ASSESSMENTS To keep a record of the activities, projects or work areas that have been assessed, when risk assessments need to be reviewed, and to facilitate auditing a Register of Risk Assessments Completed (see appendix 3) should be kept by each Service Unit or School, and a copy provided to the Corporate HSW Team. You do not need to send copies of every hazardous substances risk assessment record to the Corporate HSW Team, but we will provide feedback on any that you produce. III. KEEPING RECORDS Service Units and Schools should keep hazardous substances risk assessment records for as long as the process or activity, to which the assessment refers, is carried out (or as long as the substances involved are held on the premises), and for 3 years afterwards. As civil claims for injury can be made up to 3 years after an incident occurs, it will still be necessary to demonstrate, retrospectively, that the risks were properly assessed and controlled. Significant accidents or incidents where children are exposed to hazardous substances, can potentially result in personal injury claims up to 3 years after the child reaches the age of 18. So, all records associated with incidents affecting children should be retained until the child is 21. Health surveillance records resulting from hazardous substances risk assessment control and monitoring procedures, must be retained for 40 years. Therefore, it is logical to retain all copies of the associated hazardous substances risk assessment records for that length of time as well. F. The Hazardous Substances Risk Assessment Process: A Step-by-Step Approach When you have compiled your initial inventory (see Section D and appendix 1), and decided: what needs to be assessed; who is going to do it; how you will record assessments; and, ensured that the people involved are competent to do COSHH risk assessment; then you are ready to begin. Who should do the assessment? The employer has legal responsibility for the assessment, but others can do some or even most of the work of preparing it. Except in very simple cases, whoever carries out the assessment will need to: Have adequate knowledge, training and expertise in understanding hazard and risk; Know how the work activity uses or produces substances hazardous to health; Have the ability and the authority to collate all the necessary, relevant information; and Have the knowledge, skills and experience to make the right decisions about the risks and precautions that are needed. The person who carries out the assessment does not always have to be fully familiar with the requirements of the COSHH Regulations and the Approved Code of Practice, and other HSPS04 April 2006 9

relevant legislation and guidance. However, that person should have access to someone who has a firm grasp of those requirements (eg Corporate HSW Team). This pooling of knowledge would allow, for example, a supervisor s experience of a process to be combined with technical specialists, and Council health and safety advisers. See the following web sites for further information: HSE COSHH information for various industries and work activities - www.hse.gov.uk/coshh/index.htm Some useful HSE leaflets: COSHH A brief guide to the Regulations - www.hse.gov.uk/pubns/indg136.pdf Why do I need a safety data sheet? www.hse.gov.uk/pubns/indg353.pdf Read the label - how to find out if chemicals are dangerous www.hse.gov.uk/pubns/indg352.pdf Idiots guide to CHIP - www.hse.gov.uk/pubns/indg350.pdf Fire and explosion - How safe is your workplace? A short guide to DSEAR www.hse.gov.uk/pubns/indg370.pdf The Hazardous Substances Risk Assessment Form (HSRA1), in appendix 2, takes you through these questions in a logical sequence to enable appropriate control measures to be identified. Step 1: Assess the risks by processes/activity You should have decided which of the risks from your inventory can be covered by generic assessments and where specific assessments will be needed instead. Where exposure to a number of different hazardous substances pose little or no risk to the health of staff or others, then the significant findings of assessments for those substances may be grouped together on a single record. The significant findings for similar substances of low risk, eg lubricants or detergents, may also be grouped together on a single record. 6 You must: identify the hazardous substances present in your workplace; and consider the risks these substances present to people s health. Identify the hazardous substances present in your workplace Remember to think about substances which have been supplied to you; those produced by your work activity, eg fumes, vapours, aerosols, final products and waste materials; and those naturally or incidentally present in your workplace, eg infectious agents carried by farm animals. Using labels and safety data sheets - list all the substances and their hazards and risk phrases etc. in section 1 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. Consider the risks these substances present to people s health Assessing the risk involves making a judgment on how likely it is that a hazardous substance will affect someone s health. You need to ask yourself the following questions - How much of the substance is in use or produced by the work activity and how could people be exposed to it? HSPS04 April 2006 10

List this information in section 2 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. For supplied substances HSE has developed a generic risk assessment guide to help. It uses information on hazard, amount used and simple definitions of dustiness for solids or volatility for liquids. The guide is called COSHH essentials: Easy steps to control chemicals. The guide also helps you with the next two steps deciding what action you need to take to control risks and controlling exposure. As well as the published version, COSHH essentials can be found free on the Internet at: www.coshh-essentials.org.uk, where you can follow the steps quickly and easily online. Who could be exposed to the substance and how often? You must remember to include all groups of people who could come into contact with the substance, ie contractors, visitors and members of the public, as well as your employees. Do not forget those involved in cleaning and maintenance tasks high exposures can occur during this type of work - list these in section 2 of the hazardous substances risk assessment form HSRA1 in appendix 2. Also, certain groups of people could suffer more from exposure than others, eg pregnant women, individuals with a suppressed immune system - list these in section 6.2 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. Is there a possibility of substances being absorbed through the skin or swallowed (eg as a result of a substance getting into the mouth from contaminated hands during eating or smoking)? List these risks under routes of exposure in section 3 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. Are there risks to your employees at other locations if they work away from your main workplace? See the HSE guidance Working alone in safety for solitary workers away from their home base this may require a separate hazardous substances risk assessment to describe the additional requirements needed for lone worker safety, unless lone worker use of hazardous substances is prohibited. Step 2: Identify relevant legislation/standards/best practice Find out whether there is any relevant documented best practice, standards or legal requirements, which should be followed for the substance(s)/process/activity being assessed. Examples include Council Policies, guidance or Approved Codes of Practice, British or European Standards, or trade or professional guidance. (Relevant standards/best practice should be listed in section 6.1 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2). For example, if you are assessing the risks from woodworking you should refer to www.hse.gov.uk/pubns/woodindx.htm for Woodworking Information Sheets No s 1,6,12,14,19,23,24,25,,26,29,30,32, as appropriate. Managers and supervisors are expected to know about the hazardous substances in their workplaces, and the main legal requirements, policies and standards relating to their work (even if only in outline). If you do not know, you must find out. Some additional sources of information are listed below: Health and Safety Executive web sites: www.hse.gov.uk/coshh/index.htm and www.coshhessentials.org.uk Legislation and supporting Guidance available from HSE Books www.hsebooks.com/books/ (The Corporate HSW Team has access to electronic copies of HSE documents, and many more in a web-based library, but is unable to supply copies to other Council staff for reasons of cost.) HSPS04 April 2006 11

There are many chemistry texts available which contain COSHH and DSEAR information, such as Croner s: Substances Hazardous to Health, Dangerous Substances, and Emergency Spillage Guides; and, Bretherick s Handbook of Reactive Chemical Hazards. There may be British/European Standards available from the British Standards Institute (HSW Team does not have access to these, but other departments may have e.g. Building Control, Asset Management). Product safety data sheets, and additional instructions for safe use, from manufacturers and suppliers. Guidance from Council departments e.g. Cleaning/Caretaking safety guidance from the Asset Management Section of Corporate Resources. Guidance from Trade Associations, industry or professional bodies, and Trades Unions. CLEAPSS School Science and D&T Service www.cleapss.org.uk Do not forget to consult those actually doing the work, as they are often the experts. Step 3: Prevent or adequately control exposure The overriding duty and first priority is to consider how to prevent people from being exposed to substances hazardous to health by all routes. Prevent exposure The COSHH Regulations require you to prevent exposure to substances hazardous to health, if it is reasonably practicable* to do so. You might: change the process or activity so that the hazardous substance is not needed or generated; replace it with a safer alternative; use it in a safer form, eg pellets instead of powder. (The HSE guidance booklet Seven steps to successful substitution of hazardous substances advises on how to replace hazardous substances with safer alternatives.) * So far as is reasonably practicable Balancing the degree of risk against the time, trouble, cost and physical difficulty of the measures needed to avoid or reduce it. The greater the risk, the more likely that it is reasonable to go to substantial expense trouble and intervention to reduce it. However if the risk is small, it would not be considered reasonable to go to great expense. Ultimately, the judgement is an objective one based on the health risks and not the size or financial position of the employer. Adequately control exposure If prevention is not reasonably practicable, you must adequately control exposure. You should consider and put in place measures appropriate to the activity and consistent with the risk assessment, including, in order of priority, one or more of the following: use appropriate work processes, systems and engineering controls, and provide suitable work equipment and materials eg use processes which minimise the amount of material used or produced, or equipment which totally encloses the process; control exposure at source (eg local exhaust ventilation), and reduce the number of employees exposed to a minimum, the level and duration of their exposure, and the quantity of hazardous substances used or produced in the workplace; HSPS04 April 2006 12

provide personal protective equipment (eg face masks, respirators, protective clothing), but only as a last resort and never as a replacement for other control measures which are required. List your existing control measures (such as ventilation, training, using small amounts or PPE etc.) in section 5 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. The Hazard warning label and Safety phrases on the Manufacturers/Suppliers Safety Data Sheet may be useful in deciding what control measures are needed see appendices 6 and 7 for details). The COSHH Essentials: Easy steps to control chemicals guide and website www.coshhessentials.org.uk give advice on adequate control measures for supplied chemicals and a number of common industrial operations. For supplied chemicals it is important that you work through the risk assessment process it outlines, to arrive at the right measures for your chemicals and tasks. Meaning of adequate control Under the COSHH Regulations, adequate control of exposure to a substance hazardous to health means: applying the eight principles of good practice set out in detail in appendix 9; not exceeding the workplace exposure limit (WEL listed on safety data sheets and copied into section 1 of the HSRA1 form) for the substance (if there is one); and, if the substance causes cancer, heritable genetic damage or asthma, reducing exposure to as low a level as is reasonably practicable; if the substance is flammable or explosive, complying with the requirements of DSEAR (see details in appendix 8). The HSC has established 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 are listed in EH40 Workplace exposure limits and should be available on up-to-date safety data sheets. Correctly applying the principles of good practice will mean exposures are controlled below the WEL. Advice on applying the principles can be found in the COSHH Regulations ACOP and this guidance (see appendix 9). Adequate control of carcinogens, mutagens and asthmagens COSHH acknowledges the particular hazards of substances which cause cancer, heritable genetic damage or asthma by requiring that exposure to these is reduced to as low a level as is reasonably practicable. The HSE website contains guidance on suitable controls. For carcinogens (substances which may cause cancer) or mutagens (substances which may cause heritable genetic damage) special requirements apply - contact the HSW Team for further advice and information. Skin absorption Some substances can damage the skin itself while others can readily penetrate it, become absorbed into the body and cause harm, so you must consider the need to protect skin when deciding on control measures. The guide COSHH essentials: Easy steps to control chemicals, contains useful advice on skin protection. HSPS04 April 2006 13

Step 4: Ensure that control measures are used/maintained Using the controls COSHH requires users to make proper use of control measures and to report defects. It is your responsibility to take all reasonable steps to ensure that they do so. This is why you must give your employees suitable training, information and appropriate supervision (see Step 8 for a more detailed explanation). Any safety training, supervision and instruction given should be listed as part of the control measures in section 5 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. Maintain controls COSHH places specific duties on you to ensure that exposure controls are maintained. The objective being to ensure that every element of the control measure continues to perform as originally intended. This applies to items of equipment such as local exhaust ventilation and to systems of work, which will have to be regularly checked to make sure that they are still effective. Respiratory protective equipment should also be examined and, where appropriate, tested at suitable intervals. COSHH sets specific intervals between examinations for local exhaust ventilation equipment, and you must retain records of examinations and tests carried out (or a summary of them) for at least five years. Inspection, testing, and maintenance arrangements for control measures should be referred to in section 5 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. Step 5: Monitor exposure Under COSHH, you have to measure the concentration of hazardous substances in the air breathed in by workers where your assessment concludes that: there could be serious risks to health if control measures failed or deteriorated; exposure limits might be exceeded; or control measures might not be working properly. List any existing monitoring arrangements in section 3 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. However, you do not need to do this if you can show by another method of evaluation that you are preventing or adequately controlling employees exposure to hazardous substances, eg a system which automatically sounds an alarm if it detects hazardous substances. The COSHH Regulations ACOP provides examples of other alternative methods of evaluation. Air monitoring must be carried out when employees are exposed to certain substances and processes specified in the COSHH Regulations. Where it is appropriate to carry out personal air monitoring, the air to be sampled is the space around the worker s face from where the breath is taken, ie the breathing zone. You should keep and maintain a record of any exposure monitoring you carry out for at least five years. Where an employee has a health record (required where they are under health surveillance, see Step 6), any monitoring results relevant to them as an individual must be kept with their health record. They should be allowed access to their personal monitoring record. You can find more information on monitoring in the HSE guidance Monitoring strategies for toxic substances. HSPS04 April 2006 14

Step 6: Carry out appropriate Health Surveillance COSHH requires you to carry out health surveillance in the following circumstances: where an employee is exposed to one of the substances listed in the COSHH Regulations and is working in one of the related processes, eg manufacture of certain compounds of benzene, and there is a reasonable likelihood that an - identifiable disease or adverse health effect will result from that exposure; where employees are exposed to a substance linked to a particular disease or adverse health effect and there is a reasonable likelihood, under the conditions of the work, of that disease or effect occurring and it is possible to detect the disease or health effect. Health surveillance might involve examination by a doctor or trained nurse. In some cases trained supervisors could, for example, check employees skin for dermatitis, or ask questions about breathing difficulties where work involves substances known to cause asthma (see the questionnaire in the HSE publication Preventing asthma at work. How to control respiratory sensitisers). You must keep a simple record (a health record ) of any health surveillance carried out. Exposure to substances for which health surveillance might be appropriate, include: skin or respiratory sensitisers, eg epoxy resins, isocyanates, styrene, metal working fluids; toxins, eg lead (dust or vapour), mercury or compounds (vapour or dust), organophosphorus compounds; carcinogens or mutagens, eg vinyl chloride. List any existing health surveillance arrangements in section 3 of the Hazardous Substances Risk Assessment form HSRA1 appendix 2. For further information you can refer to the HSE guidance Health surveillance under COSHH: guidance for employers. Biological monitoring can also have a role in health surveillance. You can find further information on setting up a biological monitoring programme in the HSE publication Biological monitoring in the workplace: a guide to its practical application to chemical exposure. Step 7: Prepare plans/procedures for accidents/emergencies This will apply where the work activity or storage arrangement gives rise to a risk of an accident, incident or emergency involving exposure to a hazardous substance, which goes well beyond the risks associated with normal day-to-day work. In such circumstances, you must plan your response to an emergency involving hazardous substances before it happens. That means preparing procedures and setting up warning and communication systems to enable an appropriate response immediately any incident occurs, and ensuring that information on your emergency arrangements is available to those who need to see it, including the emergency services. It also requires these safety drills to be practiced at regular intervals. List all emergency actions (for first aid, spillage, fire and explosion as appropriate) and waste disposal arrangements in section 4 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. If any accident, incident or emergency occurs you must ensure that immediate steps are taken to minimise the harmful effects, restore the situation to normal and inform employees and others who may be affected. Only those staff necessary to deal with the incident may remain in the area and they must be provided with appropriate safety equipment. However, you do not have to introduce these emergency procedures if: HSPS04 April 2006 15

the quantities of substances hazardous to health present in your workplace are such that they present only a slight risk to your employees health; and, the measures you have put in place under Step 3 are sufficient to control that risk; but, the requirements described in Step 7 must be complied with in full where either carcinogens, mutagens or biological agents are used. Step 8: Inform, train and supervise staff COSHH requires you to provide your employees with suitable and sufficient information, instruction and training for controlling risks to health and safety, which should include: the names of the substances they work with or could be exposed to and the risks created by such exposure, and access to any safety data sheets that apply to those substances; the main findings of your risk assessment; the precautions they should take to protect themselves and other employees; how to use personal protective equipment and clothing provided; results of any exposure monitoring and health surveillance (without giving individual employees names); emergency procedures which need to be followed. You should update and adapt the information, instruction and training to take account of significant changes in the type of work carried out or work methods used. You should also ensure that you provide information, instruction and training that is appropriate to the level of risk identified by the assessment and in a manner and form in which it will be understood by employees. These requirements are vital. You must ensure your employees understand the risks from the hazardous substances they could be exposed to. Your control measures will not be fully effective if your employees do not know their purpose, how to use them properly, or the importance of reporting faults. (These arrangements should be referred to in section 5 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2). Step 9: Evaluate risk and decide what further action is needed Once you have identified all the control measures that are already in place, you need to assess the level of remaining risk of exposure to hazardous substances arising from the activity or process that you are assessing. This is where knowing how your current arrangements compare with best practice and legislative requirements is important, as is reviewing your incident and ill health history, and talking to staff about continuing risks. Evaluating current risk levels is not always easy, and can be very subjective. Assessments can vary considerably, from one person to another, between high and low. Greater objectivity can be introduced into the process if a common system of evaluation is used by all hazardous substances risk assessors, which takes into consideration the factors that contribute to risk level, including: The severity (S) of the harm that exposure to a hazardous substance can cause; The probability (P) of exposure happening in your circumstances. You can then do a simple calculation to produce a risk rating, which corresponds to a risk level of low, medium, high or very high. Simply decide on the severity (S) of the hazardous substance in question, using the categories and examples in Table 1 below, and the probability or likelihood of exposure to the hazardous substance in question (P) using Table 2. Multiply the scores together to HSPS04 April 2006 16

produce a risk rating (R). On the Hazardous Substances Risk Assessment Form HSRA1 in appendix 2, space is provided in section 5 to record these scores. Table 1: Risk Severity (S) If the substance has a risk phrase, a severity score has been allocated in appendix 5. Category Example Score MINOR SERIOUS MAJOR FATAL Substances not included on the Approved Supply List. Superficial injuries - mild skin irritation, nausea requiring first aid only. Minor property damage from fire/explosion. More serious ill-health/injuries requiring time off work, school, or a hospital visit, e.g. minor burns, nausea and vomiting, diarrhoea. Moderate property damage from fire/explosion. Acute illness/injury requiring medical treatment. Loss of consciousness or loss of sight. Major property damage from fire/explosion. Exposure which leads to death either at the time or soon after the incident, or eventually, as in the case of certain occupational diseases such as asbestos-related cancers. Chronic illness. Mutagenic, teratogenic and carcinogenic effects. Death resulting from fire/explosion. 1 2 3 4 Table 2. Risk Probability (P) - the likelihood of the hazard causing harm. Category Example (for guidance only - some or all may apply for each category) VERY UNLIKELY UNLIKELY POSSIBLE LIKELY Good control measures are in place. Controls do not rely on a person using them (i.e. personal compliance). Controls are very unlikely to break down. People are very rarely in this area or very rarely engage in this activity. Under DSEAR - not classified as a place in which an explosive atmosphere is likely to occur. Reasonable control measures are in place but they do rely on a person using them (some room for human error). Controls are unlikely to breakdown. People are not often in this area / do not often engage in this activity / this situation is unlikely. DSEAR classification Zone 2 or 22. Inadequate controls are in place, or likely to breakdown if not maintained. Controls rely on personal compliance. People are sometimes in this area or sometimes engage in this activity / this situation sometimes arises. DSEAR classification Zone 1 or 21. Poor or no controls are in place. Heavy reliance on personal compliance (lots of room for human error). People are often in this area / engage in this activity on a regular basis / this situation often arises. DSEAR classification Zone 0 or 20. Score 1 2 3 4 The scores can be represented in a matrix, shown as in Table 4 below. Risk scores correspond to a risk level very high, high, medium, low. Table 3. Risk Score Matrix RISK SCORE = S X P P R SEVERITY OF OUTCOME (S) Minor Serious Major Fatal Very Unlikely 1 2 3 4 Risk Level Low HSPS04 April 2006 17

O B A B I L I T Y (P) Unlikely 2 4 6 8 Possible 3 6 9 12 Likely 4 8 12 16 Medium High Very High What about the number of people at risk? Another risk factor that should be considered when evaluating the level of risk is the actual number of people at risk at any one time (sometimes known as the extent of risk). In general, for risks at a similar level, a higher priority should be given to actions that reduce risks affecting a greater number of people. Why use a quantitative (numerical) system of categorising risks? Expressing risk levels as scores can be very useful when making decisions about prioritising action and allocating resources. Scores derived using a common method will enable comparisons to be made between one activity or part of the organisation, and another. Deciding what further action is required to reduce risk If you discover that the existing risk control measures are not adequate to prevent or sufficiently reduce exposure to hazardous substances, for whatever reason, you must establish what further action is needed to reduce risks so far as is reasonably practicable (and list these in section 5 of the hazardous substances risk assessment form HSRA1 in appendix 2), and by when this should be done. If action can be taken immediately to improve risk controls, then this should be done without delay (and recorded in section 7 of the Hazardous Substances Risk Assessment Form HSRA1 in appendix 2). When considering what further control measures should be adopted, you should always follow the hierarchy of risk controls (detailed in appendix 9). Priority should be given to collective protective measures, over individual protective measures. The use of PPE should only be a last resort, in combination with other control measures, if there is no other way of reducing exposure risks to a reasonable level. Using the same technique as that outlined in Step 9, you should estimate the reduced risk level that will be achieved when any further improvements identified have been implemented. This can be used to demonstrate the cost benefits of investment in new controls. You should obviously aim to reduce all risks to the lowest level reasonably achievable (this does not necessarily require the elimination of all hazards remember the difference between hazard and risk). The values for Severity (S), Probability (P) and Risk (R) that you anticipate will be achieved by the additional controls should be entered into section 5 of the HSRA1 in form in appendix 2 in the columns headed Reduced Risk. Action plans implementing risk controls HSPS04 April 2006 18

If further action is required you should draw up a health and safety action plan to ensure that improvements needed are prioritised according to the level or risk identified. This should be recorded in Section 7 of the HSRA1 form in appendix 2. Remember to include realistic time scales in your action plan and identify who will be responsible for checking that the objectives of the plan have been met. It is up to you to decide on appropriate time scales for action, but some typical timescales, according to risk are given as a guide in Table 4. Table 4: Scores and Typical Action Plan Time Scales SCORE RISK LEVEL TYPICAL TIME SCALES FOR ACTION REQUIRED 1 Insignificant No further action needed 2 3 Low Action within 12 months if improvements are reasonably practicable 4 6 Medium Action within 6 months based on reasonable practicability 8 10 High Action within 1 month to reduce risk (immediate action may be needed in some circumstances) 12 16 Very high Immediate action required work should stop / not commence until risk has been reduced to acceptable levels Step 10: Record and review assessments Recording The Council s Hazardous Substances Risk Assessment form HSRA1, in appendix 2, should be used for recording the significant findings of risk assessments (a Manufacturer s/suppliers Safety Data Sheet does not constitute a hazardous substances or COSHH risk assessment), and these should then be listed on the Register of Risk Assessments Completed for each Service Unit/School (see appendix 3). Review Hazardous substances risk assessments should be reviewed regularly and amended or annotated as necessary. They should not be a once-and-only record to be filed away somewhere for bureaucratic purposes, but a living document that evolves with experience and forms a useful part of the work process. They do not need to be re-written every year, but they should at least be checked for accuracy and re-dated and signed. Assessments should be reviewed: When significant changes are made to workplaces, work activities, control measures, substances or equipment, to the degree that the original assessment is no longer valid; When new/amended legislation/guidance/codes of practice or national standards are introduced; Following monitoring/test results, incidents or ill health which highlight deficiencies in existing control measures or previously unidentified risks; When new or temporary (eg agency, or work experience) members of staff are employed who may be at increased risk due to inexperience, age or physical/mental health conditions and disabilities. In these circumstances a personal Hazardous Substances Risk Assessment may be required; HSPS04 April 2006 19