Health & Safety

Code of Practice - Control of Substances Hazardous to Health (COSHH)

The COSHH Regulations require employers to assess the risk to their employees, and to prevent or adequately control those risks.

Introduction

Most businesses either use or process hazardous substances, in one form or another, including the University.

The way these hazardous substances are purchased, stored and used is governed by legislation.

The two main pieces of legislation that apply to the University are:

  • Control of Substances Hazardous to Health (COSHH) Regulations and
  • Dangerous Substances and Explosive Atmospheres (DSEAR) Regulations

These place a duty on the employer, (the University), to protect its employees, and others, from ill health caused by these substances.

This document describes the control measures appropriate for meeting legal requirements and promotes best practice for work involving the use of substances Hazardous to Health.

It aims to provide those responsible for the use of hazardous substances with information on the steps they need to take to ensure compliance with current legislation. These guidelines may, where appropriate, be incorporated into Faculty or Directorate policies and procedures.

Definition of a Hazardous Substance:

In general terms, a hazardous substance or preparation (mixture) is one with the potential to cause harm to health.

This harm could occur upon contact with the substance or if it is inhaled, ingested or absorbed into the body.

The COSHH regulations set out more specific definitions – Any substance that:

  • Is identified as very toxic, toxic, harmful, corrosive or irritant
  • Has an approved Workplace Exposure Limit (WEL) set out by the HSE *
  • Is a biological agent, disease causing germ or nanotechnology. This may include Genetically Modified Organisms (GMOs) **
  • Generates airborne dust
  • Creates a risk to health, despite not falling within the above categories, because of its chemical or toxicological properties and the way it is used or is present in the workplace.

* See document 'EH40/2005 – Workplace Exposure Limits'
** Note: A separate set of regulations are in place for 'Genetically Modified Organisms': 'Genetically Modified Organisms (Contained Use) Regulations 2014'

Risk assessments

As with many other health and safety duties, the underlying management principles of COSHH, i.e. finding out what you have and then deciding what to do, are most easily documented within a risk assessment.

Suitable and appropriate COSHH risk assessments must be carried out for any activities requiring the use of substances hazardous to health.  The depth of this COSHH risk assessment will vary depending on the complexity and degree of risk. The format of the assessment will therefore need to reflect this.

<See Checklists and Forms below for possible templates>

When completing a COSHH risk assessment, the first step is always to consider whether exposure can be prevented.

To do this you will need to understand the extent of the risk presented to staff, students, visitors and anyone else affected, giving consideration to:

  • The hazardous properties and health effects of the substance and /or the approved classification of any biological agent (e.g from labels or as described in the material safety datasheet or other trade information provided by the supplier)
  • The level, type and duration of potential exposure.
  • The circumstances of the work, including the amount of the substance(s) involved.
  • Activities such as maintenance, where there is potential for a higher level of exposure.
  • Any relevant workplace exposure limits (WEL)
  • The results of relevant health surveillance or exposure monitoring
  • Where the work involves exposure to more than one hazardous substance, the risk presented by such substances in combination

If you are not able to prevent exposure, you need to control it adequately by applying the eight basic principles of good practice.

The 8 principles of good practice are:

  • Minimise emission, release and spread; Design and operate processes and activities to minimise emission, release and spread. Both the processes and procedures need to be considered and any sources of exposure should be reduced in number, size, emission or release rate, as much as possible.
  • Consider the routes of exposure. Exposure can occur through inhalation, skin absorption and ingestion. The physical, chemical and infectious properties of a substance, along with how it is used, can have a great bearing on which route of exposure is most important.
  • Choose control measures that are proportionate to the risk. Control measures that are adequate will take into account the nature and severity of the hazard and the magnitude, frequency and duration of exposure.
  • Choose effective control options. Choose the most effective and reliable control options for the circumstances. These should be directed at the main sources and causes of exposure, to minimise the escape and spread of substances hazardous to health.
  • Personal Protective Equipment (PPE). Where adequate control of exposure cannot be achieved by other means, provide, in combination with other control measures, suitable personal protective equipment.
  • Review the effectiveness of controls; Check and regularly review all elements of control measures for their continuing effectiveness
  • Provide Information and Training. Inform and train all employees on the hazards and risks from the substances with which they work and the use of control measures developed to minimise the risks.
  • New Measures, New Risk. Ensure that the introduction of any control measures does not increase the overall risk to health and safety.

For substances that cause occupational asthma, cancer or damage to genes that can be passed from one generation to another, exposure must be reduced as far as reasonably practicable, below the Workplace Exposure Limit (WEL). However, the principles of good practice can be applied to any substance, irrespective of whether the substance has a Workplace Exposure Limit (WEL).

Further information, on what to consider when completing a COSHH risk assessment, can be found in the Health and Safety Executive (HSE) guidance:

Additional information about specific types of COSHH risk assessment, and associated considerations, can be found as described below:

Effective Control Options

Protection measures should be appropriate to the activity and should be considered in the following order of priority:

  1. Use systems or processes that are inherently safe by design; e.g reduce the amount of hazardous substance used or produced or use equipment which totally encloses the process.
  2. Control exposure at the source by including adequate ventilation, reducing the number of employees exposed or and / or their level and duration of exposure.
  3. Use PPE, as a last resort, where adequate control cannot be provided by the other measures.

Any control measures introduced should be properly and fully used and regularly maintained to ensure they remain effective:

  • Local exhaust ventilation, including fume cupboards and biological safety cabinets, must be inspected and tested every 14 months
  • Respiratory protective equipment (except disposable masks) must be examined and tested regularly
  • Records of inspections, tests and repairs must be kept for at least five years

If, after all reasonable controls have been implemented, there is still a risk of a rare but severe exposure to one or more hazardous substances, or if the work involved carcinogens, mutagens or biological agents, you must consider arrangements to deal with any accident, incident or emergency that may involve these substances. This should include consideration for:

  • first aid facilities,
  • evacuation procedures,
  • spillage containment and
  • provision of information to the emergency services

Training

Where required, suitable training should be provided to all personnel who may use hazardous substances and / or use equipment in which hazardous substances are used, processed or produced.

The level of training should be reflective of the risk / complexity of equipment being used.

Personal protective clothing and equipment (PPE)

Where necessary, after all other precautions have been taken, appropriate personal protective equipment (PPE) such as gloves, eye protection and respirators should be provided and used. It must be ensured that any PPE provided is of the correct type and standard for the substance(s) and equipment being used.

Further guidance on selecting the correct PPE can be found on the HSE Personal Protective Equipment Microsite

Health surveillance / Exposure Monitoring

Exposure monitoring may be necessary where you suspect that current control measures are not adequately reducing the level of exposure below the WEL.

Health surveillance may be necessary if there is a disease associated with using a substance e.g cancer, dermatitis or asthma, and the conditions in the workplace mean that, after implementing all reasonable controls, personnel could still be at risk.

Surveillance is undertaken to detect adverse health effects from the use of, or exposure to, the substance(s) involved and reduce the risk of further harm.

Health surveillance is a process and may involve self-examination; Supervisor or Manager examination; or engagement with the University Occupational Health Service.

Records relating to individual health surveillance must be kept for at least 40 years.

Records of other monitoring must be kept for at least 5 years.

Environmental monitoring

Where the use of hazardous substances may lead to contamination of the air, water or ground, environmental monitoring should be considered and carried out if appropriate.

Hazardous waste disposal

Waste generated from the use of hazardous substances may need to be disposed of as hazardous waste. This waste could be residual material, intermediate substances generated by a process or paper / cloths used to clean up spillages.

For further information about the management of Hazardous Waste, please refer to the University Code of Practice for Hazardous Waste

Checklists and forms

There is no legal requirement that determines the format of a COSHH risk assessment. It is the responsibility of the COSHH assessor to determine which format is best suited to document the substance or process being assessed.

The following University templates may be considered suitable:

In addition, the HSE website has several example COSHH assessments for specific industry types, which may be used as reference documents.

Alternative formats may be used as long as they contain the relevant details described within the Risk Assessment section above

Please note, there are separate risk assessment forms for notification of Genetic Modification work.

Out of Hours and 'High Impact' Operations

Any work or process involving hazardous substances that will or may be required to operate out of hours, or are 'high impact' activities, e.g. activities in which a failure of a component or equipment can lead to fire, explosion or escape of toxic substances; requires the Estates and Facilities Directorate (EFD) to be notified, using the High Impact Activity Notification form.

This form should also be used for unattended running of apparatus outside normal hours.

High impact activities, involving flammable or explosive substances, should also be subject to a DSEAR (Dangerous Substances and Explosive Atmospheres Regulations) risk assessment, and suitable controls implemented as appropriate.

Responsibilities

The below responsibilities are to be considered alongside the general health and safety responsibilities set out in the Universities overarching Health and Safety Policy

Faculty Operating Officers and Directors of Professional Services

Are responsible for:

  • Ensuring suitable and sufficient risk assessments are carried out for all activities involving substances hazardous to health, associated with their Faculty/Directorate activities including teaching, research and support
  • Ensuring that risk assessments are conducted before the activity commences
  • Ensuring that the risk assessments are kept up-to-date, reviewed periodically (at least annually) and revised as necessary

Faculty Staff (Incl Academics, Researchers and Support Staff)

Are responsible for:

  • Ensuring that suitable and sufficient risk assessments are carried out for all activities involving substances hazardous to health being undertaken for teaching and/or research within their areas
  • Ensuring that all students for which they are responsible, who are undertaking activities involving substances hazardous to health, are made aware of and are familiar with risk assessments relevant to the work being undertaken
  • Ensuring that all risk assessments for activities under their control are reviewed annually or sooner if there is a change in personnel, equipment used, substances used, new or revised relevant legislation or an incident involving the process to which the risk assessment relates

Professional Services (Supervisory) Staff

Are responsible for:

  • Ensuring that suitable and sufficient risk assessments are carried out for all activities involving substances hazardous to health being undertaken within their areas of responsibility
  • Ensuring that all staff for which they are responsible, who are undertaking activities involving substances hazardous to health, are made aware of and are familiar with risk assessments relevant to the work being undertaken
  • Ensuring that all risk assessments for activities under their control are reviewed annually or sooner if there is a change in personnel, equipment used, substances used, new or revised relevant legislation or an incident involving the process to which the risk assessment relates

Individuals (Staff and Students)

Are responsible for:

  • Following the control measures indicated in the risk assessments associated with any activities being undertaken
  • Informing their tutor or line manager of any incidents involving substances hazardous to health and/or associated equipment which have or may have caused injury to themselves or others.

The Occupational Health Service

Is responsible for:

  • Health assessments where requested for employees reporting health or medical problems that may be adversely affected by their work with hazardous substances.
  • providing individuals with confidential advice on health or medical problems relating to the use of hazardous substances
  • liaising with the University Health & Safety Unit, Faculty Operating Officer or Director of Office and Personnel where health or medical problems have been notified.
  • referring individuals to the University's Medical Adviser as appropriate.

The Health & Safety Unit

Is responsible for:

  • Writing, reviewing and issuing Codes of Practice and guidance associated with substances hazardous to health used at the University
  • advising and assisting with the provision of suitable training of personnel involved in the use of substances hazardous to health
  • making available the information and forms referred to in this Code, either directly or through the University Health and Safety web pages.
  • liaising with Faculty Operating Officers/Directors of Professional Services and Local Safety Officers on the implementation of this Code of Practice
  • providing advice to FOOs/Directors, Occupational Health Service and Local Safety Officers on health and safety issues arising from work with substances hazardous to health
  • liaising with the Occupational Health Service, Faculty Operating Officer/Director of Office and Local Safety Officer as necessary, where health or medical problems relating to the use of, or exposure to, substances hazardous to health have been notified

The Biological and Genetic Modification Safety Committee

Is responsible for:

  • Monitoring and reviewing relevant teaching, research and support activities and advising management, staff and students on relevant health and safety aspects of work associated with genetic modification

The University Biological Safety Adviser

Is responsible for:

  • Ensuring that suitable and sufficient risk assessments are made where necessary for projects and research where biological agents are involved

Contractors

Are responsible for:

  • Providing their University of Greenwich contact with copies of their risk assessments for hazardous substances intended for use on University premises.

Suppliers

Are responsible for:

  • Providing suitable and sufficient information by way of manufacturers' safety data sheets and any other relevant information in connection with materials and substances supplied for use by University staff or students.

See also HSE resources on Labelling and Packaging of hazardous substances and provision of REACH information and Safety Datasheets

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