What is COSHH? The Complete Guide
COSHH stands for the ‘Control of Substances Hazardous to Health’ and outlines how employers must control hazardous substances in the workplace. It is vital that every organisation is aware of these regulations, as it includes everything from petrol to household bleach. In this post, we’ll detail everything you need to know about COSHH and the COSHH regulations, so you know how to protect yourself and other members of your organisation from the risks hazardous substances pose.
What is COSHH?
COSHH, or the ‘Control of Substances Hazardous to Health’, is a 2002 UK Government regulation which requires organisations and employers to provide their workers with adequate protection against hazardous substances. The regulations were put in place to protect workers, as many substances, from paints to cleaning sprays, can cause ill health. In some cases, this can lead to cancer or lung disease, impacting the rest of a worker’s life. Ignoring regulations can not only cause these illnesses and accidents, but can also lead to fines and imprisonment, as well as significant damage to an organisation’s reputation.
The core requirement of COSHH is to protect employees from the potential harm substances can cause. This includes controlling the level of exposure workers have to such substances. Though this sounds simple, there are many steps to take if you are to effectively protect employees with safety measures. The first step to take in this process is identifying the hazard. When dealing with hazardous substances specifically, this involves identifying the substance and the risk it poses.
More specific requirements differ by industry and can be found here: https://www.hse.gov.uk/coshh/essentials/direct-advice/index.htm
COSHH Courses with Phoenix
Phoenix offers a range of COSHH related courses to help you fulfil these legal requirements and protect workers from hazardous substances.
Our COSHH Awareness Training course delivers a compact and effective training experience suitable for workers who regularly handle hazardous substances. Its content includes identifying hazardous substance symbols and how to use PPE effectively.
For managers, supervisors and those who need to conduct COSHH Risk Assessments we have our COSHH Risk Assessment course. It delivers all the knowledge and skills delegates need to conduct effective COSHH Risk Assessments, so they can help implement effective safety measures in the workplace.
Those with health and safety responsibilities would find the NEBOSH General Certificate most beneficial, as the course covers not only COSHH content, but all the foundational knowledge needed for a health and safety role. Having someone in a dedicated safety role can help your organisation embrace a positive safety culture and prioritise safety in the workplace.
Understanding COSHH Symbols and their Meanings
Before we look at the symbols which identify hazardous substances, we first need to determine what types of substances we’re looking for. The COSHH regulations cover any of the following substances which have the potential to cause harm:
Chemicals
Products containing chemicals
Fumes
Dusts
Vapours
Mists
Nanotechnology
Gases and asphyxiating gases
Biological agents
Germs which cause diseases or those that are used in laboratories
Notably, it does not cover radioactive substances, lead, or asbestos, all of which are covered under their own regulations.
The type of harm one of these substances can do may be identified based on the warning symbol present on its packaging.
Flammable- Substances which, under a range of conditions, could ignite and start fires.
Corrosive - A symbol for substances which can corrode organic material. These can be exceptionally dangerous if they come into contact with the skin, eyes or are inhaled.
Compressed Gas- The symbol signifying pressurised gas. If it is heated or handled poorly this can lead it to explode.
Toxic- Substances that can be fatal, even in low doses if swallowed or inhaled.
Harmful- Indicates a substance which is harmful to health should it be inhaled, swallowed, or come into contact with skin.
Environmental Hazard- Substances which, when disposed of incorrectly or poorly, can cause significant damage to the environment.
Health hazard- Contact with substances labelled as such can cause long term ill health. This includes asthma, breathing difficulties, and other issues which can take years to develop.
Oxidising- this sign indicates a substance which can cause an exothermic reaction if it comes into contact with other substances, leading to fires and explosions.
Explosive- Under certain conditions, whether it be to do with temperature, pressure or contact with other reactants, the substance has the potential to explode.
It’s also important to keep in mind that workplace activity may produce hazardous substances, including dust and gasses, none of which will be neatly identifiable by the labels above. Many of these substances may have WELs (Workplace Exposure Limits) too, meaning the amount of exposure a worker has to them must be monitored and limited to safe levels. Just because they aren’t packaged with warnings, it doesn’t change the fact they may pose a risk to individuals in the workplace. They need to be included in risk assessments, just like other labelled substances.
COSHH Risk Assessment
Now that we know what substances to look for and the risks they pose, a COSHH risk assessment can be conducted. This is a step-by-step process through which hazards are identified, the risks they pose assessed, and effective safety measures put in place to reduce the level of risk. A COSHH risk assessment is one of the most effective ways to reduce the risk hazardous substances pose to workers. Recording them is a statutory requirement in line with COSHH regulations, though is also an excellent way of evidencing your organisation’s commitment to health and safety.
Identify the Hazards
As we’ve already covered, the first step in conducting a risk assessment is identifying the hazards which pose a risk. Many can be identified from the labels you’ve already seen, though others will be produced by workplace processes, or otherwise occur in or around the workplace. Whatever the source, if a substance poses a threat to workers, then it is a hazard and should be recorded in the assessment, even if the risk it poses is minimal.
Another key part of identifying hazards when working with hazardous substances is to identify each substance specifically. This is important because the level and severity of harm they could cause will often differ from substance to substance. They may also have different WELs under law, meaning they must be controlled in different ways and to different extents. A toxic gas produced by chemical reactions would need an intricate ventilation system in place, for example, whereas strong cleaning products just need to be kept in a secure cabinet.
Assessing the risks
Now that you’ve identified the hazards and the substances within your workplace, you can assess the risks they pose. To do this you need to know:
Who could be harmed (workers, visitors, the public)
How the substance could harm people and how exposure could occur (would the substance be inhaled, spilt on to skin, swallowed, etc)
How long individuals spend around the substance
What WELs, if any, there are on the substance
If you have any existing control measures in place to mitigate the risk a substance poses
Given the array of hazardous substances, it’s unlikely you’ll know all of this information if you haven’t conducted a COSHH risk assessment before. Fortunately, there are several resources you can use to help your assessment. These include a list of substances with WELs-https://www.hse.gov.uk/pubns/books/eh40.htm and the COSHH E-tool, which can help you determine what harm a substance could cause, as well as how exposure could occur.
Once you’ve established this information for each of your identified substances, you can move on to the next step.
Controlling the Risks
Now that you know what substances could cause harm and how that harm could occur, you can determine how an incident can be prevented. There are many types of measures you can use to reduce risk, and we’ll break each of the advised methods down, so you can determine which options are effective and practical for your workplace.
Eliminating the risk
The first control measure we’ll discuss is often the most effective at reducing risk, as it involves removing the hazard completely. By removing the hazard from the workplace, whether it be by outsourcing or conducting a process in an isolated area, you eliminate the risk it would pose to workers.
Substituting the Substance
For organisations that utilise hazardous substances as part of their operations, simply getting rid of a substance or removing it from use might prove difficult. A frequent strategy is instead replacing the substance with a less harmful alternative which produces the same result. For example, for products of workplace practice such as dust from cutting wood, you could replace the wood with a type which does not produce dust, eliminating the hazard. In chemical processes you could use a less potent chemical, reducing the harm a spill would cause, should one occur.
Changing the process
Another option is changing workplace processes to reduce risk. Taking our existing examples, you could buy pre-chopped wood, avoiding the issue of dust even being produced in the workplace. Or you could change the amount of pressure or volume of substance used in a chemical process, reducing the chance it could react poorly and cause harm.
Containment
Storing hazardous substances properly is vital for reducing the risk they pose to workers. Separate legislation exists for the specific storing of hazardous substances, though it is still worth noting that storing them in the following ways is often advisable:
Substances should be kept in secured containers, in isolated areas, away from other substances if necessary
If hazardous substances are transferred across the workplace, a closed system should be used. This means the substance is kept in a system, such as pipework, at all times and does not need to be handled directly by workers.
Substances should be stored in areas with proper ventilation, which will prevent the build-up of gases if there is an incident
As we will touch on shortly, measures such as these should be checked regularly in order to make sure containers and systems are operational and undamaged. If issues go ignored, the chance of a risk causing harm through an incident only grows greater.
Safe Systems of Work
An SSOW (Safe System of Work) is another effective safety measure which can be used to reduce the risk of accident or injury and can often be used in combination with a range of other measures. Often designed by managers or supervisors in collaboration with health and safety officers, SSOWs are guides for employees, providing them with a step-by-step breakdown of how to conduct a task safely. They are especially useful for training new employees on correct procedure, as well as conducting reviews of processes, as they give managers and supervisors a point of comparison with which to contrast the work. It is also advised that you consult with workers when creating an SSOW, as they can often offer insights into the process which other members of the organisation won’t consider.
PPE
The final measure we’ll discuss is PPE (Personal Protective Equipment), a term which you are likely familiar with. PPE can include gloves, goggles, masks, full body hazmat suits and many other specialised items, all of which can be used to reduce the risk of a hazard causing harm to a worker. In workplaces which often deal with hazardous substances, much of the equipment we’ve just mentioned will see some use, as many hazardous substances can cause significant harm if they make contact with the body. However, it’s important to note that PPE should be a last resort in terms of safety measures. It still requires workers to interact with the substance, exposing them to it regularly, even if they are protected. Removing the hazard or changing the process would be far better, as this will reduce the amount of interaction with the hazard, reducing the risk more than PPE would.
Regardless of which control measure you select, it’s important to regularly repeat the risk assessment process, re-assessing the risks posed by hazardous substances. Doing so will let you determine if the measures have worked well and if they need changing or improving. It also gives you an opportunity to identify any new hazards which may have appeared, and review equipment and any infrastructure to make sure there is no damage.
COSHH Management
The guidelines and legal responsibilities set out by COSHH must be followed by all organisations, as almost all will handle hazardous substances of some kind, even if it’s just cleaning products.
Employers are responsible for making sure all employees are aware of the COSHH regulations and best practices regarding hazardous substances. In addition to this, they must put suitable control measures in place, provide PPE as necessary, as well as training on how to use said PPE and handle hazardous substances safely. Much of this is often delegated to supervisors and managers, but it is still ultimately the responsibility of the employer should the regulations be breached. The employer should also work with their health and safety officer to create emergency procedures to be used in case of an incident, which should be shared with all members of the organisation and practised to make sure they work effectively.
In turn, employees should make efforts to be aware of regulations and their individual COSHH responsibilities. This includes obeying Safe Systems of Work, health & safety policy, and listening to any guidance provided. Fostering a positive health and safety culture in your workplace can help employees take an interest in the safety of themselves and others, so it’s worth considering steps to develop this if your organisation doesn’t currently prioritise safety. Such steps can be holding regular safety meetings, asking for employee input on change and policy, and investing in proper safety training for all members of your organisation.
Legal Compliance and Enforcement
The main piece of COSHH legislation is the Control of Substances Hazardous to Health Regulations 2002 (amended in 2004), though other key pieces of legislation which cover relevant areas of safety are the Health and Safety at Work Act (HSWA) 1974, the Management of Health and Safety at Work Regulations 1999, and the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013. We outlined the main responsibilities of employers, employees, and competent persons under these legislations earlier, however it’s important you understand how this legislation is enforced, as well as other legal information specific to COSHH.
As with most safety legislation, organisations who breach it can face a range of penalties depending on the severity of the breach and any accident which has occurred as a result. The legislation is enforced by the HSE (Health and Safety Executive) and penalties include fines, prison sentences for organisation leaders, and bans for those in leadership positions, preventing them from taking up similar positions for a set period. Other consequences could be damage to your brand and reputation as an organisation, damage to the trust your employees have in you, as well as the poor financial performance which this could results in. Suffice to say, following health and safety legislation is vital to both the health of your employees and your business.
Other requirements for COSHH include reporting serious accidents and substance leaks to HSE, which is required under RIDDOR (the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013). Reports must be submitted in the event of any serious injury, disease outbreak, or dangerous occurrences such as hazardous substance leak. The person to submit a report to the HSE must be the employer or the individual in control of the premises at the time, and the report should be made as soon as possible, within 10 days of the incident.
Additionally, organisations should keep a record of all incidents, both for reporting purposes and to track where and how safety measures have failed in the past.
Disposing of Hazardous Substances
The last major requirement for COSHH we’ll touch on is the disposal of hazardous substances. Such substances can often cause serious harm to individuals or the environment if they are not disposed of properly, and so it’s the responsibility of the employer to ensure this is done correctly.
Hazardous waste, the term given to substances being disposed of, falls into one of three categories.
Always Hazardous
Never Hazardous
May or may not be Hazardous and requires assessment
Having a list of which substances you use and which categories they fit into is important for proper disposal, and information on whether the substance is a fire hazard should be included. Organisations must then follow proper disposal procedures for each individual substance, making sure each is contained and will not cause harm due to mixing, leaks, fires, or any other form of incident.
COSHH Training and Awareness
Although the management of hazardous substances can at first be overwhelming, much of the difficulty can be eliminated by providing the proper training to employees. This includes getting everyone up to speed on COSHH legislation and best practice so hazardous substances are handled safely. Not only does training give employees all the knowledge they need on COSHH, but it also shows that their employer has an interest in keeping the workplace safe for everyone.
Phoenix’s COSHH Awareness Training course is ideal for any employees who have to frequently deal with hazardous substances of any kind. In this online, 40-minute course, employees will gain an understanding of the COSHH regulations, hazardous substance symbols and best practice regarding handling said substances.
For managers and supervisors, or anyone who needs to conduct COSHH risk assessments, we also offer the COSHH Risk Assessment course. It builds on the COSHH awareness course, covering what risks are associated with hazardous substances, how to conduct an effective COSHH risk assessment, and what safety measures can be used to reduce COSHH related risk. The course can be studied in just one day at your workplace, eliminating the need for further travel as one of our expert trainers will come to you.
The NEBOSH General Certificate also covers COSHH across its 9 days of content, as well as a range of other key health and safety knowledge. We recommend this course for anyone in your organisation with health and safety responsibilities, as it covers all the legislation and skills, they need to reduce the risk hazardous substances and other hazards pose in your workplace.
Got a question about one of our courses? Unsure if your team has all the safety training it needs? Contact our team today.