The Control of Substances Hazardous to Health Regulations 2002 (COSHH)
http://www.hse.gov.uk/pubns/indg136.pdf
Any work liable to expose employees to any substances
hazardous to health is prohibited unless a suitable and sufficient assessment
has been carried out. The fundamental requirement of the COSHH Regulations is
that exposure of persons to substances hazardous to health is either prevented
or, where this is not reasonably practicable, adequately controlled.
The COSHH Regulations are designed to protect persons at
work and those who may be affected by work activities from the adverse effects
of exposure to substances hazardous to health in the immediate and long term.
In offshore workplaces such substances can arise from the use of drilling
fluids, hydrocarbon processing (benzene, condensate, hydrogen sulphide to name
a few) or be the consequence of day to-day activities (painting, maintenance,
cleaning, etc).
Substances hazardous to health are defined in the
Regulations. Essentially the definition covers virtually all substances having
the potential to cause harm to health. This includes substances brought into
the work process and labelled as very toxic, toxic, harmful, corrosive or
irritant under the CHIP 3 Regulations or substances created by the work process
such as dust.
COSHH does not apply to work with lead, asbestos or
radioactive sources as these are covered by other hazard-specific regulations.
COSHH does not apply to a substance if it is hazardous to health solely by
virtue of its explosive or flammable properties or solely because it is at a
high or low temperature or high pressure. Medical or dental treatment carried
out under the direction of a qualified practitioner is also excluded.
Assessment
All activity liable to expose individuals to substances
hazardous to health must be identified, assessed and recorded. Each assessment
must be reviewed if there is reason to believe that it is no longer valid. For
instance, if the workplace exposure limit has been reduced, or if significant
changes in the work process have occurred. When determining the amount of
thought and effort needed for a COSHH assessment the main consideration should
be the way in which the substances are put to use and not just from their
intrinsic properties or hazard. In other words, the focus of the COSHH
assessment should be the work process or the task in hand.
The intention is therefore to identify and assess all work
activities involving, or potentially
involving, exposure to a substance
hazardous to health. The assessment also needs to take account of the
non-routine as well as the routine. This means that emergency procedures will
need to be subjected to COSHH assessments, particularly to exposures to spillages
or leaks.
Various guidance documents to the COSHH regulations
emphasise the point that the person carrying out the assessment must be
competent. The guidance also recommends the employment of external consultants
if the required level of expertise is not available internally. In deciding who
should carry out the assessment consideration should be given to the following
factors:
· an
understanding of the basic requirements of the regulations
· the
ability to gather relevant information about exposures to substances
· the
ability to look critically at existing control arrangements and to specify the
steps to be taken in order to ensure compliance
· an
awareness of level of expertise and at what stage the assessor should seek
further assistance
· the
ability to accurately report the findings of the assessment and the measures
necessary to prevent exposures to individuals or to reduce those exposures to
an acceptable level.
It may be that an assessment team is required comprising
people who have knowledge, skills and experience in occupational hygiene, the
work and processes, chemical engineering, mechanical engineering, ventilation,
metallurgy, medical practitioners, toxicologists and safety practitioners, etc.
Prevention and Control
The fundamental requirement of COSHH is that exposure of
persons to substances hazardous to health is either prevented or, where this is
not reasonably practicable, adequately controlled.
This requires prevention or adequate control of exposure by
methods other than the provision of personal protective equipment (PPE).
Only
when all options for prevention have been implemented should attention turn to
possible methods of control. There are many aspects of control to be considered
- for example, exposure to substances allocated exposure limits as defined by
EH40 must be reduced to a level which demonstrates the 'so far is reasonably
practicable' premise.
Some engineering controls such as HVAC fixed local exhaust
ventilation systems (LEV) and showers, etc, form part of the installation and
are therefore 'provided' in terms of the regulations by the installation owner.
On the other hand, implementing control measures such as limiting the periods
of work exposure, ensuring personal hygiene regimes, providing PPE and the
provision of some portable local extraction systems might effectively be
carried out by contractors.
Under the terms of COSHH it is the duty of every employer to
ensure, so far as is reasonably practicable, the prevention or adequate control
of exposure to substances hazardous to health is secured by adequate and
suitable means.
COSHH obliges all employers/installation operators to take a
structured approach to identify, evaluate and put in place measures to prevent
exposure to substances hazardous to health and, where this is not reasonably
practicable, to provide adequate control for the safety of all personnel on the
installation. There are specific legal duties to:
- carry
out assessments
- prevent
or control exposure
- use effective
control measures
- maintain,
examine and test control measures
- monitor
exposure
- provide
health surveillance
- provide
information, instruction and training.