control of substances hazardous to health (coshh) procedure

Policy Owner Head of Health, Safety and Resilience

Approval Body Pobl H&S Forum

Review Frequency 3 years Last Approved March 2020

Next Review date

March 2023

Control of

Substances

Hazardous to

Health (COSHH)

Procedure

Pobl Group

Contents Page

1. Introduction ......................................................................................................................... 3

2. Scope ........................................................................................................................ 3

3. Definitions .................................................................................................................. 3

4. Legislation ................................................................................................................. 3

5. Related policies and procedures ................................................................................ 4

6. Roles and Responsibilities ......................................................................................... 4

7. Selection of Substance / Product ............................................................................... 4

8. COSHH Assessment ................................................................................................. 5

9. The Use, Maintenance, Examination, and Test of Control Measures ......................... 6

10. Health Surveillance .................................................................................................... 6

11. Information, Instruction and Training for Employees .................................................. 7

12. Provision of Personal Protection ................................................................................ 8

13. Arrangements for dealing with Accidents, Incidents and Emergencies....................... 8

14. Records ..................................................................................................................... 9

15. Annex A – COSHH Assessment .............................................................................. 10

16. Annex B – COSHH Guidance .................................................................................. 12

1. Introduction

Pobl Group accepts that some work activities may involve the use of some hazardous

substances which have the potential for harming health. This procedure will outline the

steps required to reduce the risks as far as possible, and where the risks cannot be

reduced and/or controlled provide information on a safe system of work.

This procedure relates to the Control of Substances Hazardous to Health (COSHH)

and supports the Pobl Group Health and Safety Policy.

The following definitions are used to assist those involved in the process:

• The definition of Substances Hazardous to Health is given in Control of Substances Hazardous to Health (Amendment) Regulations

• Covers virtually all substances capable of causing adverse health effects or disease, arising from work activities

2. Scope

All staff, individuals we support and volunteers who will come into contact with

chemicals or substances as defined below.

3. Definitions

A substance that is hazardous to health is simply any substance or mixture of

substances (a preparation) which can cause, or has the potential to cause, damage to

health.

There are five identified categories, which summarised, are as follows:

• Chemicals that are very toxic, toxic, harmful, corrosive, irritant, sensitising, carcinogenic, mutagenic or toxic to reproduction;

• Substances for which the Health and Safety has assigned a Workplace Exposure Level (WEL);

• A biological agent which includes micro-organisms, parasites and microscopic infectious forms of larger parasites;

• Any dust at a substantial concentration in the air; and

• Any substance present in the workplace creates a risk to health.

The key words are hazardous to health – and there will be chemicals and substances

in use that are not significantly hazardous e.g. washing up liquid, soap and general

domestic products.

4. Legislation

This procedure is written with reference to The Control of Substances Hazardous to

Health 2002 (COSHH). The Management of Health and Safety at work Regulations

1999 also requires suitable and sufficient risk assessment of substances hazardous to

health. GDPR and Data Protection Act 201 also applies when dealing with personal

and special data in terms of occupational health screening.

5. Related policies and procedures

• Pobl Group H&S policy

• Pobl Group Risk assessment Procedure

• Pobl Group COSHH assessment form

6. Roles and Responsibilities

Line managers shall ensure that:

• They complete a COSHH assessment form for any substance and communicate it to all team members;

• No work is carried out that is liable to expose employees to substances hazardous to health unless a suitable and sufficient risk assessment is in place;

• Carry out the steps needed to meet the requirements of the COSHH regulations;

• Identify any hazardous substances which staff and others may be exposed to;

• Identify the route by which the substances might enter the body and identify the resulting effects;

• Examine the working processes, practices and procedures which involve hazardous substances;

• Estimate the current exposure levels and those which might result from a planned or an unplanned event, such as an increase in levels of work or an accidental release; and

• Deliver adequate information, instruction and training on COSHH to teams through team meetings and toolbox talks.

Employees, including agency staff and sessional workers shall:

• Follow instructions and guidance set out within the COSHH assessment and relevant material safety data sheet;

• Cooperate with their line manager and any provisions that have been put in place are to be maintained for the protection to health of staff, service users and any other relevant person;

• Wear personal protective equipment that has been provided for their protection; and

• Report any health issues or changes in health that may be attributed to their role or substance being used, including any sensitisation that may occur.

7. Selection of Substance / Product

Within services and offices, hazardous substances may be used as part of normal

work activities e.g. cleaning materials, photocopier toner etc. An inventory must be

kept in each site containing each type (not necessarily quantities) of substances used

or handled.

If possible Pobl employees must try to reduce the amount of chemicals used in each

workplace i.e. make use of “multi-purpose” cleaning agents as much as possible.

It is recommended to keep an approved list of chemicals to be purchased. This stops

staff and individuals over buying and creating stockpiles of different substances.

Only approved products should be used in Pobl locations that have been sourced

through a dedicated tender and procurement process. All employees must:

• Ensure that all requests for any hazardous substance such as cleaning materials etc need to be made via Procurement and follow the relevant internal procedures;

• Ensure that no product / substance is to be purchased outside of this procedure; and

• Line managers can request for items to be placed on the approved list subject to a COSHH review by the HSR team.

Unauthorised products found on Pobl premises without a dedicated COSHH

assessment and MSDS sheet will be removed for safety reasons.

8. COSHH Assessment

Each hazardous substance identified should be subject to a Hazardous Substance

Risk Assessment (Annex A) and must not be used where there is no assessment in

place. The central HSR team will compile a master list of core COSHH products and

ensure a COSHH assessment is in place for these. Managers purchasing non-core

products from approved suppliers MUST ensure they have completed a COSHH

assessment for the products and communicated this to their teams.

Hazardous substances must where feasible be kept in a lockable facility where there is

the potential risk of an individual or member of staff being harmed by such substances.

Staff must be aware that certain substances do not mix well with others and can create

a dangerous situation - directions must be followed for each substance in use.

If there are no or insignificant risks i.e. limited domestic products in small quantities

used safely- there may be no need for a detailed risk assessment - advice should be

sought from the central health, safety and resilience team.

Risk assessment will include:

• Details of the Product Group: This is the generic grouping, for example, “solvent based paints” information about the product can be found on the container or from the Manufacturers Safety Data Sheets (MSDS);

• Date of Assessment: The assessment must be up-to-date and for most substances a review is required at least every year. For highly hazardous materials (that must be used) it is likely that assessments will be reviewed and revised more frequently;

• Hazard Classification: The information on the label and safety data sheet indicates whether the material is toxic, flammable or an irritant. This gives an immediate indication of the intrinsic hazard associated with the product group. The classification allocated and all the other information should be applicable to the most hazardous materials in the generic grouping;

• Health Risks: Indicate the key risks to the health of staff and workers exposed to the material. For example - a product carrying the risk phrase "Irritating to eyes" should be matched by the applicable precautions, "Avoid contact with eyes". Awareness of „concentrated‟ substances should also be highlighted – i.e. appropriate quantities/dilution etc;

• Current Control Measures: Any measures that must be in place to minimise the risk e.g. protective equipment, specific method of use, staff instruction etc.; and

• COSHH assessments will be reviewed on a regular basis

Reviews will occur if there is a change in any processes that is carried out,

advances in technology, or, some aspect that makes the COSHH assessment

invalid

Line managers must ensure accurate records of all COSHH assessments are

stored securely in their area of responsibility

All Pobl Group Core COSHH assessment and MSDS sheets are available on the

H&S page on Pobl point.

9. The Use, Maintenance, Examination, and Test of

Control Measures

Employees must make full and proper use of control measures, including personal

protective equipment (PPE), which is provided are to comply with COSHH

requirement.

Pobl has to ensure that all the control measures for products provided are to be

maintained and, in efficient working order and in good repair.

Suitable records of examinations and tests and of the repairs (engineering controls

and respiratory protective equipment) must be kept available for inspection for at least

five years.

Pobl Group and its employees must ensure that Personal Protective Equipment is

properly stored, checked at regular intervals.

Replacement or repairs if defective, or contaminated PPE must be removed before

leaving the workplace and, prevented from contaminating other items.

10. Health Surveillance

Pobl always aims to minimise, wherever possible, the risks to employees from

substances that may be hazardous to health. Materials used at work should be treated

with respect, care being taken to read warning labels on containers and any written

advice provided in assessments. Any worker who feels that the use of a material is

causing any health problems should report this to his/her manager as soon as

possible.

It may be necessary for health surveillance to be carried out by Pobl Groups

Occupational Health provider to ensure employees health and wellbeing.

• The purpose of health surveillance under COSHH is to:

Protect the health of individuals

Assist in the evaluation of exposure

Evaluate hazards to health

Assess (for micro-organisms) the immunological status of employees;

• Pobl shall ensure that employees are kept under suitable health surveillance by the Occupational Health provider;

• If an employee is liable to be exposed to a substance hazardous to health, occupational health monitoring will be based on:

Possible result of the exposure is an identifiable disease

Reasonable likelihood of the disease occurring

Disease is detectable by a low risk technique;

• Workplace air monitoring and health surveillance may be carried out only where it will provide useful information for the protection of the employee; and

• Occupational Health provider / Pobl Managers / Central HSR team / HR team will discuss the results of health surveillance with the employee(s) where required and put measures in place to reduce potential hazards.

Pobl has a legal obligation where necessary to provide employees with occupational

health surveillance. This will require the handling of personal and special data as

defined under GDPR. This information will be stored securely and for as long as

necessary. This information may be shared with 3rd party organisations, for example

Pobl groups occupational health provider, insurer etc.

11. Information, Instruction and Training for Employees

Employees exposed to substances hazardous to health must be provided with

information, instruction and training. Suitable and sufficient training for the employees

is to be designed for each to know the risks to their health created by the relevant

exposure to the substances. Employees should also be familiar with the precautions

necessary for their protection

Pobl shall ensure that staff who may be exposed to substances hazardous to health

receive the information, instruction and training on the following through the COSHH

module on the Pobl Passport, dedicated tool box talks available on Pobl point and

briefings held by managers, this will include:

• Suitable and sufficient information about the substance (e.g. storage, safe use, control and disposal);

• Suitable and sufficient information about the risks to their health created by exposure to the substance(s) and the precautions, which should be taken to control them; and

• Suitable and sufficient information about the PPE required when dealing / working with substances.

Some guidance for employees on COISHH can be found at Annex B of this procedure.

Records of training are to be held within the Learning and Development (L&D)

Department as well as locally with the line manager to monitor the need for refresher

training

12. Provision of Personal Protection

Where exposure to hazardous substances cannot be reduced, below a safe exposure

limit, staff will be provided with appropriate personal protective equipment (i.e. gloves,

masks etc.).

Protective equipment should only be provided as a last resort where there are no other

alternatives but to deal with the risk. Staff must use protective equipment specified in

the assessment when handling hazardous substances e.g. wearing gloves when using

oven cleaner.

Line managers are responsible for the provision of personal protective equipment and

maintaining suitable records of its issue and maintenance.

13. Arrangements for dealing with Accidents, Incidents

and Emergencies

Emergency procedures must be in place to protect the Employee’s health in the event

of an accident, incident or emergency involving a hazardous substance. These

procedures must include appropriate first aid facilities, relevant safety drills (practiced

at regular intervals) and a means of warning of such incidents. Information on these

emergency procedures must be available and include details of associated work

hazards, hazard identification arrangements and any specific hazards likely to arise in

the event of such an incident

In the event of an emergency involving a hazardous substance the Line manager and

the central health, safety and resilience team must take immediate steps to:

• Minimise the effects of the event;

• Return the situation to normal;

• Inform any employees who may be affected;

• Restrict access to the affected area to essential personnel only and provide them with the necessary PPE and / or specialist equipment until the situation returns to normal;

• Employees must be informed as soon as practicable of the causes and necessary remedial measures in emergencies involving biological agents capable of causing severe human disease;

• Employees must also report any such accident or incident to their Line manager and Health, safety and resilience team;

• Details of emergency procedures and associated information must be made available to internal and/or external emergency services for their emergency response plans; and

• Where appropriate they must also be displayed in the workplace and details provided to all relevant staff, visitors and service users.

14. Records

COSHH assessments will be completed by using the Pobl COSHH assessment form

(Annex A) that is available on Pobl point.

All forms as well as COSHH assessments for approved products can be found on Pobl

point or by contacting the health, safety and resilience team.

15. Annex A – COSHH Assessment

COSHH Assessment: DATE ../ ../ ....

MSDS AVAILABLE

YES / NO

Name of Site where Substance is being used:

Duration of work activity:

Describe the activity or work process. Include how long and how often this is carried out and the quantity of substance used

Location of process being carried out?

Identify the persons at risk:

Employees (including students)

Contractors Public

Name the substance involved in the process and its manufacturer. (A copy of a current safety data sheet for this substance should be attached to this assessment)

Classification (state the category of danger)

Hazard Type

Gas Vapour Mist Fume Dust Liquid Solid Other (State)

Route of Exposure

Inhalation Skin Eyes Ingestion Other (State)

Workplace Exposure Limits (WELs) please indicate n/a where not applicable

Long-term exposure level (8hrTWA):

Short-term exposure level (15 mins):

State the Risks to Health from Identified Hazards

Explosive Flammable

Gas Cylinders

Acute toxicity

Health

hazard/Hazardous to

the ozone layer

Environmental

Oxidising

Serious health

hazard

Corrosive

Control Measures: (must Include special measures for vulnerable groups, such as disabled people and pregnant workers. )

Is health surveillance or monitoring required? Yes No

Personal Protective Equipment (state type and standard) Dust mask

Visor

Respirator

Goggles

Gloves

Overalls

Footwear

Other

First Aid Measures

Storage to include (stability or reactivity of the substances)

Fire precautions : What actions should be taken in the event of fires involving this substance?

Spillage : What actions should be taken in the event of an accidental spill

Disposal of Substances & Contaminated Containers

Hazardous Waste Skip Return to Depot Return to Supplier Other (If Other Please State):

Is exposure adequately controlled?

Yes No

Risk Rating Following Control Measures

High Medium Low

16. Annex B – COSHH Guidance

This guidance note has been created in conjunction with the Control of Substances

Hazardous to Health (COSHH) Procedure and supports the Pobl Group Health and

Safety Policy.

Definitions of COSHH

COSHH stands for the Control of Substances Hazardous to Health Regulations

(2002). It exists to ensure that both employers and employees do all they can in a

workplace to minimise people’s exposure to hazardous substances and work in ways

that are safe.

This means that all hazardous substances need to be identified and precautions need

to be taken to ensure that workers know how to use and handle them safely.

What is a hazardous substance

Simply put, a hazardous substance is any mixture or substance that are toxic, irritant,

or corrosive – whether a liquid, gas, vapour, fume, or dust.

They cause harm to the body via routes of entry:

• By coming into contact with skin or eyes;

• By being inhaled;

• By being ingested through the mouth;

• By entering the body through cuts or punctures in the skin.

Although there are certain industries that will be at greater risk, hazardous substances

could exist in any workplace. They are often used directly in work activities, produced

by work activities, or already present in workplace’s premises.

Examples of hazardous substances include:

• Chemicals, e.g. cleaning chemicals or bleach;

• Fumes, e.g. from paint or vehicles that exhaust;

• Gases, e.g. ammonia from refrigerators;

• Dusts and powder, e.g. from flour.

It’s worth noting that even seemingly innocent substances can be harmful, and that

includes natural materials like wood dust or flour.

While many hazardous substances can cause immediate harm, such as a corrosive

liquid spilling onto skin, the main danger posed by hazardous substances is the

prolonged exposure. For example, if someone is in the presence of or uses a

dangerous chemical for a long time, they could develop breathing difficulties or skin

conditions.

Examples of ill health caused by hazardous substances include:

• Occupational asthma;

• Occupational dermatitis;

• Occupational cancers;

• Skin irritation;

• Infection from bacteria;

• Injury or death as a result of exposure to toxic fumes.

Because harm caused by hazardous substances is often gradual and almost

undetectable until it’s too late, controlling the dangers is of the utmost importance.

Employers responsibilities

Under COSHH regulations, employers’ responsibilities include:

• Making a suitable and sufficient assessment of the risks posed by hazardous substances;

• Implementing control measures to protect workers from hazardous substances;

• Preventing or adequately controlling exposure to hazardous substances;

• Providing employees with suitable and sufficient information, instruction, training and appropriate protective equipment where necessary;

• Ensuring that control measures are maintained, kept in full working order and in a clean condition where appropriate;

• Drawing up plans and procedures to deal with accidents and emergencies involving hazardous substances;

• Ensuring that any employees exposed to hazardous substances whilst at work are under suitable health surveillance;

• Ensuring that substances do not exceed the Workplace Exposure Limit (WEL).

Employee’s responsibilities

Under the COSHH regulations, employees have a duty to:

• Make full and proper use of any control measures or facilities provided by their employer;

• Take all reasonable steps to ensure any equipment is returned after use and stored properly;

• Report any defects or insufficiencies in the control measures;

• Wear and store personal protective equipment (PPE) in accordance with instructions;

• Remove any protective equipment that could cause contamination before eating or drinking;

• Make proper use of facilities provided for washing, showering, or bathing;

• Maintain a high level of personal hygiene;

• Comply with any information, instruction and training that is received.

Why and when to undertake a COSHH assessment

A COSHH risk assessment is essentially the same as a standard risk assessment in

terms of the process, but your assessment of the workplace will focus solely on

hazardous substances.

The Control of Substances Hazardous to Health (COSHH) Regulations 2002 provide a

framework to protect people at work against health risks that may arise from work

activities that expose them to hazardous substances.

It is a common misconception that risk assessment is the identification of the

hazardous properties of a substance. The hazardous properties of a substance

constitute its potential to cause harm. The risk is the likelihood that it will cause harm in

the actual circumstances of use. An assessor must appreciate the difference between

these two concepts.

The purpose of a risk assessment is to ensure that a valid decision is made about the

measures to be taken to prevent or control exposure to substances hazardous to

health.

In practical terms, a risk assessment will demonstrate that a judgement has been

reached.

The essential steps that must be taken are:

• Identify hazards intrinsic to substances to be used (safety data sheets);

• Assess the risks to health arising from the use of the hazardous substances in the work activity;

• Decide what precautions and control measures are necessary to minimise the risk;

• Implement the control measures;

• Ensure control measures are used and maintained;

• Monitor exposure of users (if necessary);

• Consider whether biological monitoring and/or health surveillance is appropriate, or required;

• Ensure the users have sufficient information, instruction and training to perform the work safely and competently;

• Ensure adequate procedures are in place to deal with any emergency situation, which may foreseeably arise.

A risk assessment is required by the Regulations to be "suitable and sufficient". The

following list identifies the properties a "suitable and sufficient" risk assessment would

contain:

• An assessment of the risks to health;

• Consideration of the practicability of preventing exposure to hazardous substances;

• Any additional equipment required, for example local exhaust ventilation (LEV) to achieve adequate control of exposure where prevention is not reasonably practicable, in accordance with COSHH Regulations (Regulation 7).

The amount of detail required in a risk assessment will be determined by a number of

factors:

• The degree of risk and conclusions about the adequacy of proposed or existing control measures;

• Knowledge gained through previous experience;

• Existing records concerning the substances involved, persons exposed, their activities and previous exposure results.

There will be occasions when it will only be necessary to read suppliers’ Safety Data

Sheets to conclude that existing procedures and practices will satisfactorily control

exposure. On other occasions it will be necessary to obtain further information via

HSE guidance notes, technical/scientific papers or trade literature to estimate likely

exposure and hence to decide upon appropriate control measures. It should be borne

in mind that hazardous substances can enter and damage the body by a variety of

routes – principally by inhalation, skin absorption, ingestion or exposure of the eyes.

Where a substance has been assigned a Workplace Exposure Limit (WEL), the

assessment may include a recommendation that workplace measurement of airborne

contaminants should be carried out.

A pragmatic, common sense approach should be adopted with regard to writing

assessments. The principle behind risk assessment is that it should enable a person

undertaking an activity (whatever their expertise) to:

• Understand the hazards of the substance used in the activity;

• Appreciate the necessity to implement appropriate control measures to minimise the risk to health.

All Pobl Group Core COSHH assessment and MSDS sheets are available on the

H&S page on Pobl point.

Revision Table

Issue Revision Date Modifications Who

1.0 0 Dec 2016 Procedure Drafted Dean Barnett

2.0 1 March 2019

Procedure updated to reflect new COSHH Hazard Symbols and new Group COSHH

assessment

Nefyn Cardwell

3.0 2 March 2020 Full procedural review and inclusion of GDPR

requirements Nefyn Cardwell

control of substances hazardous to health (coshh) procedure

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