Nigel Bryson discusses the control systems developed in response to the Control of Substances Hazardous to Health Regulations, focusing on COSHH Essentials. .
In the early 1990s, occupational hygienists in the pharmaceutical industry were developing generic control systems in response to the Control of Substances Hazardous to Health Regulations. Around the same period, the Health and Safety Executive (HSE) was reviewing the use of chemicals at work. The HSE surveyed a number of businesses to identify how they dealt with controlling chemicals in practice. It was realised that small- to medium-sized enterprises (SMEs) were having most difficulties in using information to identify and control hazardous chemicals.
The HSE established a working group within its Advisory Committee on Toxic Substances (ACTS) with a remit to develop a tool that could help SMEs deal with chemical hazards. It was agreed that such a tool would have to be simple, transparent and make best use of the available hazard information on chemicals.
In 1999, the paper edition of COSHH Essentials was published. Building on the control systems work done by the pharmaceutical industry, COSHH Essentials linked risk phrases from Safety Data Sheets (SDSs) into five hazard bands — A to E — and devised a matrix for estimating exposure to identify generic control measures for a range of common tasks, eg mixing powders and filling containers, for example. An additional aim was to encourage industry groups to develop generic control measures within the COSHH Essentials framework and in 2000, the first process-specific control sheets were published covering the print sector.
In 2002, the HSE went live with an Internet-based version of COSHH Essentials and the risk assessment framework was unchanged from the 1999 paper version. By this time, the HSE had recognised some limitations in this approach with the following being the main ones identified.
Applying the COSHH Essentials process tended to identify over-precautionary control measures in some instances.
It was unsuitable for gases/process emissions, etc.
It referred higher risks to expert advice, such as those from chemical carcinogens.
Skin exposure was poorly addressed.
Having got the first phase of the e-COSHH Essentials up and running, the HSE then looked to address these weaknesses. In 2003, the second phase came online with the following additions.
Process generated dusts and fumes were added, including rubber dust and fume, foundry work and wood dust.
The top three substances causing asthma were added including isocyanates in motor vehicle repair and flour dust.
Service and retail control sheets were added.
Information on health surveillance was included.
In total, 70 new control sheets were added and it went live in October 2003.
This development over 18 years has led to an extensive range of generic control sheets that have been rigorously reviewed. The HSE website states: “HSE is therefore confident that in the vast majority of situations, implementing the advice given by COSHH Essentials will lead to adequate controls of the risks.”
Employers need to ensure that the COSHH Risks Assessment is suitable and sufficient. As COSHH Essentials provides generic control measures, employers need to ensure that their specific circumstances are covered. This may need additional analysis. However, as the HSE points out, the use of COSHH Essentials is a good pointer to control measures in the tasks/processes covered.
How does COSHH Essentials work?
The starting point for COSHH Essentials is the Risk Phrases given on the SDSs that must be supplied with chemicals. These have been “banded” into five groups — A to E. There is also a band covering skin hazards, denoted “S”. The next thing to consider is the exposure potential. Dustiness or volatility is again banded and the scale of use of the chemical is determined. From this combination of the health hazard and the potential exposure factors, the required level of control can then be determined. The final step is identifying the specific approach needed to achieve adequate control. The control sheets themselves are clearly laid out and easy to follow.
In a telephone survey of 500 purchasers of COSHH Essentials published in 2002:
79% had actually used it to carry out or review risk assessments, provide information or train workers
89% confirmed that they had been able to easily use it
94% said they would recommend it to other businesses.
This early survey indicated to the HSE that the COSHH Essentials package is a valuable tool for SMEs to develop appropriate controls for hazardous chemical operations. The printed materials also offer very useful resource materials for training courses and help identify the common health and safety risks associated with chemical use.
The HSE has published an explanation of how the COSHH Essentials package works and has made it freely available. This can be used by specialists to adapt the scheme or develop guidance specific to their own processes. Indeed, as the HSE prefers people to use its website, all the COSHH Essentials sheets are available and these can be downloaded free of charge.
The Government has stressed the need for health and safety information to be simple for businesses to use, especially SMEs. The development of COSHH Essentials is a good example of a large range of stakeholders — trade associations, industry specialists, HSE, local authorities, trades unions and professional organisations — working to develop an authoritative tool to help business.
The development of an Internet version and continual expansion of generic control sheets means that COSHH Essentials is relevant to a large range of tasks, processes and sectors that use chemicals. Information that can be freely downloaded covers:
offshore oil and gas
motor vehicle repair
While chemical hazards involving carcinogens, reproductive hazards, etc need more detailed assessments, there is no doubt that COSHH Essentials is not only still relevant but offers a simple-to-apply method for assisting in risk assessments for many chemical uses. The availability of the Internet version means that it is flexible and is more easily updated.
The HSE estimates that around 4000 people a year die from chronic obstructive pulmonary diseases due to past exposure to gases, dust and fumes at work. Around 35,000 people a year report they have breathing/lung problems that are caused or made worse by work. Around 40,000 new cases of dermatitis are reported to GPs each year. These figures do not include the estimated 12,000 people a year that die from occupationally related cancers.
The use of chemicals can be complex because of the numbers of chemicals available and the different uses they can be put to by industry. The long latency period between exposure and the development of symptoms has made cause and effect more difficult to recognise. The advantage of COSHH Essentials is that it uses information that employers should have and can take them through a few steps that can then identify control measures that should help protect workers where they work. As indicated by the HSE, it is a tried and tested way of helping identify appropriate control measures that employers should have confidence in.
It is quite clear that there is still an occupational health issue on the handling of chemicals that needs to be addressed. While COSHH Essentials does not provide all the answers to every chemical hazard, it does adequately address a lot of common ones.
Last reviewed 14 November 2013