www.alcumusgroup.com

COSHH Compliance:Recent changes and common failings

Mike Harris - CMS Operations ManagerAlcumus Sypol

What are we going to talk

about…

• The most recent statistics

• COSHH overview

• Common failings in COSHH management

• Recent changes in COSHH management

Ill health in the UK

3*refers to “Health and safety at work, summary statistics for Great Britain 2018” - HSE

144Fatal injuries to workers in 2017/18Source: RIDDOR

9.7Annual costs of new cases of work-related ill health in 2016/17,excluding long latency illness suchas cancerSource: Estimates base onHSE Costs to Britain Model

billion30.7

Working days lost due to work-relatedill health and non-fatal workplaceinjuries in 2017/18Source: Estimates based on self-reports fromThe Labour Force Survey

million

2595Mesothelioma deaths in 2016, with aSimilar number of lung cancer deathslinked to past exposures to asbestosSource: Death certificates

1.4Work-related ill health cases(new or long-standing) in 2017/18Source: Estimates based on self-reportsFrom the Labour Force Survey, peopleWho worked in the last 12 months

million

Ill health in the UK

4

35%Injury

Cost to Britain of workplace injuries and new cases

of work-related ill health in 2015/2016 by:

Type of incident Cost bearer

65%Ill health

£3 billionGovernment

£3.4

billionEmployers

£8.6

billionIndividuals

*refers to “Health and safety at work, summary statistics for Great Britain 2018” - HSE

Ill health in the UK

Lung diseases contributing to

estimated current annual deaths

32%ChronicObstructivePulmonaryDisease(COPD)

22%Non-asbestos

Related lung cancer

20%Mesothelioma

20%Asbestos-related

Lung cancer

5%Other disease

*refers to “Health and safety at work, summary statistics for Great Britain 2018” - HSE

Ill health in the UK

6

Occupational asthma; causal agents

most commonly reported by chest

physicians during 2012-2016

Isocyanates

Flour/Grain

Cleaning Products

Wood dust

Enzymes, Amylase

2% 4% 6% 8% 10% 12%0%

*refers to “Health and safety at work, summary statistics for Great Britain 2017” - HSE

What are the primary set of regulations looking to address this?

The Control of Substances Hazardous to Health Regulations

2002 (as amended)

7

The important COSHH regulations…

• Have a written assessment in place for every anticipated workplace

exposure (Regulation 6)

• Prevent exposure or implement suitable measures to control exposure to

those substances through all routes of entry (Regulation 7)

• Use all control measures provided and maintain them to ensure their

ongoing performance (Regulations 8 + 9)

• Where there is concern exposure is not adequately controlled, conduct

monitoring and health surveillance to ensure the protection of employees

(Regulations 10 + 11)

• Inform employees about all areas of the assessment (Regulation 12)

• Make plans for in the event of spillage, first-aid or fire (Regulation 13)

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Elimination &

Substitution (Reg.7)

Formal Assessment

(Reg.6)

Implement Controls

(Reg. 7&8)

Inform, Instruct and Train (Reg

12&13)

Inspect and Maintain (Reg. 9)

Exposure monitoring

(Reg. 10)

Health Surveillance

(Reg. 11)

The COSHH Cycle

9

Common Failings

Common failings with manual COSHH management

• Expertise• Very few people have a true understanding of COSHH hazards and risks.

• Ability to scrutinise supplier information against current ECHA classifications.

• Speed• When compiled manually COSHH assessments can take 30+ mins.

• Quality• Are you sure everything that is legally required is present?

• Is your assessment up-to-date with current enforcement requirements?

• Who checks your checkers?

• Standardisation• There is no agreed template for COSHH assessments.

• Visibility• Can everyone access their most recent COSHH assessment when they need it at or near the

point of risk?

• How can you be sure people have read the assessment?

Common failings with COSHH management generally

• Assessing a substance not an exposure

• Failure to consider process emissions

• Failure to consider biological agents

• Uncontrolled copies

• Lack of workforce awareness

Assessing a substance not an exposure

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• The COSHH regulations require a COSHH assessment to be produced for all

exposure to hazardous substances.

• Not only must the assessment consider the hazardous nature of the product but

also;

• Quantity in use

• The activity type

• Area of use

• Duration of work

• Frequency of use

• Failure to do this will lead to your COSHH assessments being little more than a

glorified Safety Data Sheet

Failure to Consider Process Emissions

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• Process emissions are one of the most widely overlooked forms of hazardous

substance.

• These are the emissions such as fumes, dusts and vapours given off during a task

and include common substances such as:

• Welding fumes

• Wood dust

• Exhaust fumes

• Many of these emissions have serious ill health effects associated with them.

COSHH assessments are required for these in the same way as a purchased paint

or adhesive.

Failure to Consider Biological Agents

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• A micro-organism, cell culture,

or human endoparasite,

whether or not genetically

modified, which may cause

infection, allergy, toxicity or

otherwise creates a hazard to

human health

• Example, Legionella

Uncontrolled copies of assessments

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• Uncontrolled (printed) copies of assessments, while practical for site,

are potentially out of date the moment they are printed or created.

• Alcumus Sypol update over 200 assessments everyday, with potential

changes to:

• Hazard classification

• Emergency procedures

• Occupational hygiene/health

• Control measures

• Failure to keep uncontrolled copies up to date can leave operatives

vulnerable on site.

Lack of workforce awareness

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• The biggest failure witnessed across all sites is the lack of awareness

by the workforce.

• Even when assessments are in place, operatives are often unaware of

where to source them or how to interpret them.

• Instruction and training on COSHH is a requirement.

• If assessments are in place, but operative don’t use them, it is simply a

box ticking exercise and will protect employees to the required level.

Lack of workforce awareness

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• “This is the way we’ve always done it”

• “Why was it safe to do yesterday and its

not today?”

• The culture and perception of health and

safety in general is and needs to change.

• This can be very difficult with topics like

COSHH, which can be seen as “niche”.

Recent changes

EH40 updates

EH40/2005 Workplace Exposure Limit Changes

• Introduces the new limits listed in Directive 2017/164/EU, the fourth

Indicative Occupational Exposure Limit Values (IOELV) Directive.

• Came into effect on the 21st August 2018.

• New entries for 14 substances – common substances such as acetic

acid, nitrogen dioxide, nitrogen monoxide, sulphur dioxide, cyanide

compounds.

• Reduction in WELS for 11 substances – including acrolein, carbon

monoxide, dichloromethane, bisphenol A.

EH40/2005 Workplace Exposure Limit Changes

• New skin notations for 4 substances – tetrachloroethylene, methyl

formate, glycerol trinitrate, 1,4-dichlorobenzene.

• HSE consulted on a lower STEL for glycerol trinitrate but reverted back to

IOELV.

• Transitional arrangements for underground mining and tunnelling for

WELS for nitrogen monoxide, nitrogen dioxide and carbon monoxide until

2023.

What does this mean for me?

• If you use, or come into contact with any of the chemicals which have a

new / amended WEL or a new annotation (i.e. sk) action is required.

Changes to Welding controls

Welding and COSHH

• What COSHH covers:

• Purchased products (e.g. paints, adhesives)

• Process emissions (e.g. dusts, welding fume)

• Biological material (e.g. pigeon droppings, blood)

• Contaminants (e.g. used engine oils)

• While bulk metal is regarded as an article and therefore exempt from

COSHH. Hot work releases extremely hazardous fumes.

• Many people believe they protect against welding hazards, though all they

are considering is temperature and light exposure.

Recent HSE guidance

• February 2019.

• STSU1 – 2019 – Change in enforcement expectations for mild steel

welding fume.

• Targeted for all worker, employers, self-employed, contractors and any

others who undertake welding activities including mild steel in any

industry.

• With immediate effect, there is a strengthening of HSE’s enforcement

expectation for all welding fume, including mild steel welding; because

general ventilation does not achieve the necessary control.

Why was it needed?

• The International Agency for Research

on Cancer (IARC).

• While the main focus was on

carcinogenicity resulting from UV light

exposure during welding.

• Causal links were apparent between

inhalation of welding fume and

increased levels of lung and kidney

cancer.

Why was it needed?

• This is aimed at Mild and Carbon Steel.

• The Institute of Occupational Safety and Health (IOSH) reported on

January 21st that the HSE would enforce enhanced control measures for

welding in the UK.

What has changed?

• The enhanced enforcements:

• Indoor welding tasks require the use of LEV. If LEV is unable to

control fume capture, then Respiratory Protective Equipment (RPE)

is also required.

• Outdoor welding requires use of RPE.

• Enforcement of the raised control standards is with immediate

effect under COSHH Regulation 7.

What has changed?

• Regardless of duration, HSE will no longer accept any welding undertaken

without any suitable exposure control measures in place, as there is no

known level of safe exposure.

• This means that even with exposure monitoring data inhalation controls

will be required in all cases.

• No transition or implementation period was specified by the HSE.

Any questions?

Mike Harris – CMS Operations Manager

Alcumus Sypol

mike.harris@alcumusgroup.com