A Comprehensive Guide to COSHH Management

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Ryan Lloyd-Davies is CEO and Technical Director of ORBIS Environmental Ltd and the company’s Principal DSEAR Consultant. With around 20 years’ experience in health, safety and compliance, Ryan specialises in DSEAR, ATEX, hazardous area classification, fire and explosion risk, flammable substances and combustible dusts. He has worked across MOD, aviation, fuel, chemical, NHS, prison, manufacturing and emergency response environments. His approach is practical, technically robust and commercially aware, helping clients achieve proportionate compliance that genuinely fits their site and resources.

In any workplace, protecting employees from exposure to hazardous substances is a fundamental responsibility of employers. Whether it’s dust, fumes, chemicals, or biological agents, employers must adhere to regulations such as the Control of Substances Hazardous to Health Regulations 2002 (COSHH) to ensure a safe working environment.

Orbis Environmental are able to provide bespoke support and assistance with the important journey of COSHH Management. We excel in providing not only detailed workplace assessments, but in being able to identify and address risks in order to enhance and ensure the safety of your employees while working with these substances. In this, as well as in so many other areas, we are looking to be your partner, and a resource for anyone seeking to establish and improve upon safer and healthier environments for their teams.

Specifically, we have a recent project where we:

  • Completed all COSHH Assessments
  • Created task specific COSHH Assessments for higher risk substances, in this case liquid Nitrogen handling and Use
  • Assessed the existing arrangements and created an action plan for improvements.
  • Helped the client implement these control measures including sourcing the appropriate gloves, aprons and footwear, smoke testing the LEV system to prove its efficiency, Installing flow indicators to help operators see the LEV extraction is working.
  • Delivered training to all operators and line managers.
  • Completed a follow up inspection and coaching session to support the process being implemented.

The outcome of this project was greatly appreciated by the client as we took carte of everything, and we also find these projects extremely valuable as we feel part of the team.

In this blog, we look to explain just how we achieve this.

Understanding COSHH Regulations Requirements

Under COSHH regulations, employers are obligated to control exposure to hazardous substances to levels as low as reasonably practicable (ALARP), especially for substances classified as carcinogens, mutagens, etc. Exposure can occur through various routes, including inhalation, skin contact, injection, or ingestion.

Workplace exposure limits (WELs) are crucial in maintaining workers’ health, as they set concentrations of hazardous substances in the air over a specified time period. These limits are outlined in the EH40 Workplace Exposure Limits publication, a legally binding document under COSHH.

Highlighting Specific Risks: Exposure to Toxic Chemicals

In addition to the established risks, exposure to toxic chemicals in the workplace poses severe threats, leading to various injuries and illnesses.

These include: Brain damage, Burns, Rashes and other skin irritations, Throat or lung injuries, Nerve and neurological injuries, Allergic reactions and skin rashes, Itching and inflamed skin, Lung cancer, Mesothelioma

These risks underscore the importance of comprehensive workplace assessments to identify and address potential dangers, ensuring the well-being of employees.

Monitoring and Compliance

Monitoring is a key aspect of ensuring compliance with Workplace Exposure Limits. Employers can engage consultants such as ourselves to measure substances in the air during specific tasks, providing a valuable indicator of the effectiveness of control measures. This process helps ensure that exposure levels remain below the established WELs.

Orbis Environmental specialises in workplace assessments to identify and mitigate risks associated with hazardous substances. Our knowledgeable and experienced consultants provide monitoring services in a variety of settings, using a range of techniques:

  • Air Sampling:
    Active Sampling: Using pumps to actively draw air through a collection device.
    Passive Sampling: Allowing substances to be collected without using a pump.
  • Surface Sampling: Collecting samples from surfaces, equipment, or tools to assess contamination levels.
  • Personal Sampling: Monitoring the exposure of individual workers to hazardous substances during their work activities.
  • Direct-Reading Instruments: Using on-the-spot instruments to measure concentrations of hazardous substances in real-time.
  • Biological Monitoring: Analysing biological samples such as blood or urine to assess the internal exposure of workers to hazardous substances.
  • Bulk Sampling: Collecting samples of bulk materials (e.g., powders, liquids) for laboratory analysis.
  • Soil Sampling: Assessing the presence of hazardous substances in the soil within and around the workplace.
  • Wipe Sampling: Using wipes to collect samples from surfaces for analysis, often for assessing the presence of contaminants.
  • Noise Monitoring: Measuring the levels of noise within a workplace to ensure compliance with safety standards.
  • Vapor Monitoring: Detecting and measuring the concentration of vapors in the air, especially relevant in environments with volatile substances.

Ongoing Controls: Management Systems and Health Surveillance

There are many ongoing controls measures that are required to be implemented under COSHH, those falling under the heading of ‘Management Systems’ and those we refer to as ‘Monitoring and Health Surveillance’.

Management Systems

An effective COSHH Management System should be recorded, regularly reviewed and updated, and remain accessible enough to be shared with all relevant employees. It will include the following elements:

  • Risk Assessment – either based on all substances used within a workplace, or undertaken on a task based approach to ensure that all risks associated with the substances are captured thoroughly.
  • Control Measures – all relevant control measures should be considered, and while not all will be achievable or practical it is important to record this consideration. They might be substitution, or where not possible, the introduction of engineering controls such as ventilation systems, enclosed processes, or isolation of hazardous substances.
  • Safe Systems of Work – development and implementation of safe operating procedures for all elements including handling, storage, use and disposal.
  • Training and Information – ensuring adequate training and information is provided, and this is recorded, to all employees on hazards associated with specific substances, the proper use of control measures and emergency procedures.
  • Emergency Planning – developed in case of spills, leaked, or other incidents involving hazardous substances. These plans should be communicated with, and tested by all personnel involved with the processes.
  • Storage and Handling – all hazardous substances must be stored and handled appropriately, in accordance with their MSDS information and with the avoidance of incompatible substances being stored or handled together.
  • Maintaining, Reviewing and Recording – all of the above elements must be maintained regularly, reviewed and recorded appropriately to ensure the ongoing effectiveness of the COSHH Management System that has been implemented. This should take into account new substances introduced before they are brought in, as well as being updated when substances are removed from processes.

Monitoring and Health Surveillance

Along with the initial monitoring and sampling exercises identified previously in this article, it is important to ensure regular review is built into your company’s processes. We recommend undertaking sampling in the workplace on a three yearly basis, or more frequently if significant changes are made. Health Surveillance should similarly be undertaken on a regular basis – with initial thorough assessments being made of new starters, as well as existing employees to ensure baseline figures are established. Carried out on a regular basis will ensure that potential health issues are captured as early as possible, as well as ensuring training, use of PPE, safe systems of work and other control measures are not only being adhered to but are also remaining effective.

Case Study: Safety Representative Spots Bakers Asthma

A poignant case study highlights the importance of proactive health and safety measures, in a substance not necessarily considered to be obvious as ‘hazardous to health’. A 51-year-old maintenance fitter, working in a bakery for two decades, developed respiratory issues over time. Their trade union representative suspected occupational asthma, leading to an HSE investigation.

Tests revealed a flour dust allergy, prompting management to take swift action. The fitter was relocated to less dusty areas, and improvements were made in dust extraction. He was provided with suitable respiratory protective equipment (RPE). While he continues to work using RPE and medication, his respiratory health is compromised due to chronic asthma.

Further investigations uncovered two more cases of flour dust allergy. While these workers have better health outcomes due to early detection, they still require medication and are likely to face breathing problems for the rest of their lives.

This case underscores the importance of thorough workplace exposure assessments, such as those conducted by Orbis Environmental, in identifying and mitigating risks promptly. Employers must prioritise the health and safety of their workforce to prevent long-term health issues associated with occupational exposure. Orbis Environmental expertise in workplace exposure assessments plays a crucial role in achieving this goal, ensuring that workplaces remain safe and compliant with health and safety regulations.