9 Steps to COSHH Risk

Assessment Competence

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Contents

Page 2. Why we need an assessment

Page 3. Type of Assessment and COSHH RA Process

Page 4. Information Gathering

Page 5. Evaluating the Risk to Health

Page 7. Appropriate Control

Page 9. Recording

Page 10. Review

Page 11. Competence

Page 12. Reasonably Practicable

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COSHH Risk Assessment Step 1

Why we need to do an assessment

Without stating the obvious I suppose the best place to start is understanding why we
need to undertake COSHH Risk Assessments at all. COSHH Risk Assessment Report #1
starts off with the legal requirements surrounding the COSHH Assessment.

The Control of Substances Hazardous to Health Regulations 2002 (as amended)

Regulation 6 - Assessment of the risk to health created by work involving substances

hazardous to health

Employers must not carry out any work which can expose any of their employees to any
substance hazardous to health until:

• A suitable risk assessment is done

• The steps needed to comply with the regulations have been identified and
•Those steps have been put into operation

Regulation 7 - Prevention or control of exposure to substances hazardous to health

Every employer shall ensure that the exposure of his employees to substances hazardous
to health is either prevented or, where this is not practicable, adequately controlled

So, we are governed by state law and thus we must do it if you have potentially hazardous
substances on site. If you do not have a sufficient assessment you are in effect breaking the
law.

What is the purpose of the COSHH Assessment?

With specific reference to potential risk from exposure to hazardous substances the
COSHH Assessment should fulfil two objectives. Identify the current situation and then
decide on what to do about it. The aim is to then produce reliable conclusions based upon
informed judgement.

COSHH is set out to ensure things are done to reduce pain and suffering caused by
ill health. A poor assessment that merely collects information will undoubtedly result
in excessive, unwanted and useless amounts of paperwork. On the flip side a good
assessment can be a very effective tool.

Before you do anything the first thing to ask yourself is ‘’Are hazardous substances likely to
be present in the workplace?’’

NO - No further action required.

YES - Assessment required

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COSHH Risk Assessment Step 2

Type of assessment & COSHH RA process

Let’s discuss the type of assessment we are making.

Over the many years in this industry I have seen so many people spending significant
amounts of their time with reams of paper trying to write up hundreds of substance based
assessments that then sit in a file, away from the eye of the end user making the document
produced a wonderful ornament. I have seen this many times.

You need to decide early. ‘’Is your assessment going to be substance based or
process based?’’

For many, and this may include you, have a huge volume of substances in use in the same
process yet there are people who do an actual assessment based on a single substance
and regurgitate the same old information over and over. The recommended action to
take would be a task or process based assessment covering all the substances in one
manageable document. If we think about it why would we carry out many risk assessments
for one process?

There are serious benefits for the process or task based assessment.

There is the obvious time benefit as you will now be doing assessments based upon the
number of processes you have as opposed to the number of substances you have. Then
there is the effective management of this as you can inform and instruct those individuals
involved in that process only with an amount of information that is easier to comprehend.

Most employees will then only have to be aware of one or several assessments and not
many individual assessments that say the same thing.

An effective assessment as we described in Report #1 is one that reduces pain and

suffering against the effects of workplace hazardous substances. No matter how good your
assessment is, if it is not communicated and fully understood by the end user then you
have a wonderfully useless assessment.

Let us also not misunderstand, if you have substance based assessments it is fine, the
point I wish to make is that if you have many substances you are adding complication to a
subject that doesn’t readily come easy to the majority.

Now we have decided which assessment we are doing let us look at how we do it.

The Risk Assessment Process

There are 5 stages to the COSHH Risk Assessment:

1. Information Gathering – Substance, process, working practices

2. Evaluate the risks to health – Find potential problems
3. Deciding on the most appropriate control – Comply with Regulations 7 to 13
4. Recording the assessment – How to effectively document allowing you to communicate
5. Review – What frequency do you think is appropriate

The next reports will focus in more detail each of the steps required in an effective COSHH
Risk Assessment process.

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COSHH Risk Assessment Step 3

Information gathering
Gather information about the substances, the process and the working practices. The more
data you gather the easier it is to record!

Decide who will carry out the assessment

• The smaller the organisation, the less significant the risk the lesser need for outside expertise
• As situations become more complex, such as in larger organisations a requirement to
involve more people will be essential
• Use the employee, involve them in the process
• Seek guidance from trained expertise

Identify the substances present

• Vapours, gases, mists, liquids, fumes, dusts, solids and a mixture of all mentioned
• Does the undertaking of the process introduce further substances to consider.
• Does the maintenance or cleaning process impact on the assessment

How to identify hazardous substances

Knowledge of the process, HSE guidance, Scientific and technical literature, Engage an
occupational hygienist, health advisor or toxicology expert. Are the substances listed in
EH40, Are they carcinogens or mutagens? What classification (toxic,very toxic, harmful,
sensitising, irritant corrosive, etc.)? Do the substances cause occupational asthma?

Examples of Processes and Substances

• Office – Printing substances such as toner, ink, ozone. Cleaning substances such as
bleach, polish, etc.
• Paint Spraying – Solvents or Volatile Organic Compounds, Isocyanate, Lead
• Fabrication – Dusts including metals, gases from welding and cutting
• Plastic Extrusion – Hydrogen Chloride, Styrene and other Volatile Organic Compounds,
Formaldehyde, Acrolein
• Routes of exposure – How substances can be hazardous
• Ingestion – smoking/eating/drinking/contaminated clothing
• Inhalation – exposure to any type of airborne substances
• Absorption – skin contact (solvents, acids), eye contact
• Injection – High pressure equipment and sharp objects (needles)

Health effects
Based upon the identification of substances and the possible routes of entry it is important
to understand the potential health effects to apply appropriate control
• Exposure to metals can result in severe respiratory issues and fever type symptoms
• Exposure to solvents via inhalation can cause dizziness, drowsiness, dullness, headache & sore throat
• Exposure to solvent on the skin may cause defatting of the skins natural oils leading to
dermatitis type symptoms

Who is exposed and how?

• Production employees
• Support employees such as maintenance and cleaning personnel
• Contractors
• Visitors
• Supervisors and managers

You are now equipped to gather the data you need to accumulate in order to produce a
suitable and sufficient assessment.

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COSHH Risk Assessment Step 4

Evaluate the risk to health

Either on an individual employee basis or on a group basis:

FIND OUT
• the chance of exposure occurring (likelihood)
• how often exposure is likely to occur (frequency)
• what level of exposure could happen and for how long (severity and duration)

CONCLUDE
• Either existing and potential exposure pose no significant risk
• or existing and/or potential exposure pose significant risk

FIND OUT - LIKELIHOOD OF EXPOSURE

• Are people directly exposed?
• Are they close to the substance during use, transport, packaged, stored, etc.?
• Are they in the vicinity of a potential release or spillage?
• Is the area enclosed?
• Could the substance be disturbed in other ways? (cleaning, maintenance, etc.)
• Are surrounding surfaces contaminated?
• Previously contaminated clothing?
• Do other people pose a risk of contamination?

FIND OUT - FREQUENCY OF EXPOSURE

• Use your experience of the process
• Gather information from the operator
• Consider long term exposure mainly around frequent and continuous activities (daily exposure)
• Consider non-routine work (maintenance, repairs, spills)

Exposure frequency is also linked to:

• The training the employee has had and the information they have received
• The suitability of the control measure. The training around that
• Routine maintenance schedules of the control measure

FIND OUT - SEVERITY AND DURATION

Let’s be clear at this point that not everything needs to be measured. Good observation
at times will indicate whether control is likely to be adequate or not. A trained H&S
practitioner should be able to judge the potential severity and duration through the skill of
observation. However, if particularly hazardous substances are in use it is strongly advised
to measure for accuracy. The more knowledge you accumulate the better off you will be
when dealing with any situation.

Always and without exception air on the side of caution. If ever in doubt seek professional
competent advice.

There are occasions when the accumulation of precise concentrations and times of
exposure are
needed:
• When exposure occurs frequently
• When a high level of exposure can be foreseen at any time
• When a substance or substances has a Workplace Exposure Limit assigned to it
• When a substance or substances has the potential to cause cancer, asthma or respiratory
sensitisation

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CONCLUDE – NO RISK
As stated there are times that even without measurement there are reasonable grounds for
reaching the conclusion of no risk. But how do you do that? Use the following:

• The quantities or rate of use of the substance do not constitute a risk even if the control
measures break down
• Full detailed standard operating procedures are in place and fully understood by users
with the assurance that the process when in use properly will not give rise to any risks to
health
• You have previous measurements of the specific process, which cover a worst-case
scenario situation which confirms there is no risk and you can prove the process has not
changed

It is important to note that whilst day to day routine exposure may not cause risk you need
toreview the potential risk in the however unlikely event of breakdown or failure. What is
your plan B for short term control until you have rectified the situation?

Never dismiss a risk as negligible unless you have full certified and valid evidence

CONCLUDE – POTENTIAL RISK

Unacceptable risks to health exist if exposure is known or found to be:

• Occurring in situations where it is reasonably practicable for it to be prevented

• Inadequately controlled in relation to the priorities set out in COSHH Regulation 7.
(Substances that cause hereditable damage such as mutagens and carcinogens must be
controlled by a more stringent effective control measures)
In either of the above 2 situations, immediate corrective action is required

Immediate indicators that exposure may be likely to cause risk:

• Evidence of dust deposits on people or surfaces
• Visible airborne particulate dispersions
• Broken, badly maintained or clearly defective control measures
• Visible poor working practice. (probably a result of lack of information and training)
• Employee complaints
• Symptoms of ill health

You now know:

1. Why you need an assessment

2. The process and the type of the appropriate assessment
3. How to gather the right information to undertake the best assessment
4. How to effectively evaluate the potential risk

Next I will demonstrate how to apply appropriate control.

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COSHH Risk Assessment Step 5

Appropriate control
So far you are fully equipped with the information to know what problems you have.
You now need to decide on what to do about those problems. It is not possible to solve
everything immediately so you will need to prioritise. To do that effectively you will need to
follow the below:

• What are the most serious risks to health?

• What are the risks that are likely to occur soonest?
• What are the risks that can be dealt with soonest?

Obviously the most important one is the seriousness of the risk. Less important matters
should not assume greater priority merely because of time and ease.

You now need to select the appropriate measures to prevent or control exposure. This
report will provide a taste of the control measures available. More specific controls will
require more in depth investigation.

Decide what needs to be done in terms of:

Controlling or preventing exposure

If exposure cannot be prevented by avoiding the use of a substance or substituting the
substance for one less harmful then control must be applied.

‘’There is a hierarchy of control within COSHH and over the years I have seen many slight
variations. Many years ago, I was told to follow ERIC P. Elimination, Reduction, Isolation,
Control and finally PPE. It has always helped me remember you may have your own
version’’

Whatever you decide to do must be realistic and appropriate. So far as is ‘reasonable

practicable’ is the phrase we hear the most. This is simply an analysis of risk against cost.

Maintaining controls
Subsequent maintenance commitments should also influence your choice of methods. Do
not select controls if you do not have the resource or expertise to maintain them. Seek
help in the decision-making process from control experts. Never forget that PPE and RPE
is a control measure and should also be fully maintained. The initial choice in selecting
personal protection is also a huge decision. It must be fit for purpose. You are required to
undertake Face Fit Testing on all RPE

Using controls
Regulation 8 of COSHH has a legal requirement for both employees and employers.
You must provide adequate control and if you do you must provide adequate training and
instruction ensuring that it is used properly. Once you have done this the employee has a
legal responsibility to utilise the control provided. Have you:

• Made arrangements ensuring control measures are properly utilised?

• Ensured there are periodic checks to ensure defects are reported?
• Made arrangements for the necessary maintenance to be undertaken?
• Got updated maintenance records (they should be stored on file readily available for 5 years)?

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Plan for emergencies
It is feasible that the chemical and/or process would not cause issue in typical every day
circumstance. (If this is not the case then you must improve control) If there is a
chance that an accident or a unique situation may cause issue that simply cannot be
controlled then a procedure with detailed clear arrangements must be drawn up.

The purpose of this procedure is to mitigate the risk and return to normal working
conditions as fast as is possible.

(If you need further information on this please contact EEUK)

Monitoring exposure
Although monitoring is not required in every instance (your assessment of the risk will
determine if it is necessary) it is necessary to measure actual employee exposure especially
to substances that have a Workplace Exposure Limit. Personal sampling is always the
recommended type as opposed to background or static sampling. Your main priority is
what people are breathing in rather than what is in the atmosphere. Monitoring where
appropriate is a requirement of Regulation 10 of COSHH

Health surveillance
Health surveillance is required in certain cases. (Refer to Regulation 11 of COSHH for
further details). The primary criterion for the need to undertake surveillance is a reasonable
likelihood that an identifiable disease or ill-health effect associated with a specific
substance is likely to occur.

Surveillance can take different forms from record keeping and questionnaires to the full
participation of doctors. The greater the risk the more detailed surveillance is required

Information, instruction and training

The most important part of the COSHH Regulations. You can implement as much as you
like but unless you have provided the right information to the right people the system is
flawed from the outset. A properly informed and instructed workforce is a huge positive in
your company for several reasons.

By law the employee must know:

• Names of substances and potential risk they pose

• The actual exposure limit
• The content of the safety data sheet
• Significant findings of the COSHH assessment
• Precautions to take when working with the substance(s)
• Results of any monitoring
• Results of health surveillance

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COSHH Risk Assessment Step 6

Recording the Assessment

If you have 5 or more employees, you must record the significant findings of your
assessment. If you have less than 5 this is not a legal requirement although it is strongly
advised.

Record sufficient information to include at least the appropriate actions from the list
provided in the COSHH ACOP.

The risk assessment shall include consideration of –

(a) the hazardous properties of the substance;
(b) information on health effects provided by the supplier, including information contained
in any relevant safety data sheet;
(c) the level, type and duration of exposure;
(d) the circumstances of the work, including the amount of the substance involved;
(e) activities, such as maintenance, where there is the potential for a high level of exposure;
(f) any relevant workplace exposure limit or similar occupational exposure limit;
(g) the effect of preventive and control measures which have been or will be taken in
accordance with regulation 7;
(h) the results of relevant health surveillance;
(i) the results of monitoring of exposure in accordance with regulation 10;
(j) in circumstances where the work will involve exposure to more than one substance
hazardous to health, the risk presented by exposure to such substances in combination;
(k) the approved classification of any biological agent; and
(l) such additional information as the employer may need in order to complete the risk
assessment.

Important:
1. Your assessment should reflect the detail with which the assessment has been
carried out.
2. Your assessment should be useful and meaningful to those who will need it now and
in the future

When to record the assessment

The recording of the assessment should be made immediately after the assessment is
undertaken. It is understandable that not all information can be immediately input (e.g.
when awaiting monitoring results) but this must be updated as soon as is possible.

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COSHH Risk Assessment Step 7

Review
The assessment in any case must be reviewed at regular intervals and immediately if:

• There is any reason to suppose that the original assessment is no longer valid. For
example, there is evidence from the results of examining and testing engineering
controls or reports from qualified onsite personnel about any defects in the control
systems; or

• Any of the circumstances of the work should change significantly and especially if
that change has had an impact on employee exposure

There is a requirement to review. Let us be clear, review does not mean start all over again
and redo it means to see if the existing assessment is still suitable and sufficient. If it is sign
and date as reviewed.

Timelines in the review process are always unclear. The review process should happen
regularly in accordance with HSE guidance. It is up to you to decide on your review
frequency. This is my opinion but for best working practice it should never really exceed 2
years, even if nothing has changed.

‘’After all what is the harm in reviewing the process and discussing again with the
employees. The key to learning is repetition’’

The review interval is not specified in the COSHH Regulations but the Approved Code of
Practice states that the date of the first review and the length of time between successive
reviews will depend on the extent of the risk, the work and the employer’s judgement on
the likelihood of changes

Examples of changes that make a review necessary:

• Has the volume of production changed?

• Has the plant or equipment changed?
• Are you using different materials?
• Has a process changed?
• Are new improved controls available?

Reactive reviews are also required when:

• Work related ill health is reported;

• There is new evidence about the hazard of a substance
• Monitoring or health surveillance results show any loss or control

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COSHH Risk Assessment Step 8

Competence
The series so far has discussed how but this section of the series is all about ‘Who’

COSHH does not aim to transform employers and their staff into world class occupational
hygienists. It is true that many assessments require a very specific skill set to achieve what
is needed when dealing with a complex process or mix of chemicals. It is also true that
assessment can be done in house, after all who knows the process better.

Regulation 12(4) states that;

Any person who does any work in connection with the employer’s duties under COSHH
must have the necessary information, instruction and training.

The possession of qualifications in occupational hygiene is an important indicator of

competence but it is not a guarantee. Practical experience is a must. Both is obviously the
perfect situation.

People who are carrying out assessments must be provided with the facility and authority
to undertake the assessment competently. These facilities must include:

• Enough time to gather the data

• The opportunity to talk with the right personnel
• Time and access to previous documentation
• Appropriate reporting arrangements so findings can be quickly documented

The basic skills required for choosing the appropriate person

The appropriate person must understand the principles of the COSHH Regulations. The
person is also required to possess the ability to:

• Observe and fully understand the significance of what is going on

• Predict potential issues
• Ask relevant questions to different levels of the team
• Identify and review the relevant technical literature
• Bring to an adequate conclusion all data that has been accumulated in a way that
identifies potential likelihoods and consequences

The person engaged in this process must be aware of their limitations, they must form an
adequate report and they must engage professional help if there is any doubt as to the
quality of the assessment.

If using professional consultants make sure the consultants know what is expected and
what they are being employed to do. Wok with the consultants as it will aid.

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COSHH Risk Assessment Step 9

Reasonably practicable
‘’So long as it is reasonably practicable’’

We hear that a lot in our world, don’t we? Well what does reasonably practicable mean?

Reasonably practicable is a matter of balancing the degree of risk against the time,
trouble, cost and physical difficulty of the measures necessary to avoid it.

Clearly the greater the risk the more reasonable it is to do something about it. It is
important to remember that the judgement is driven by the risk and not the size or
financial position of the employer concerned.

Finding the balance is a matter of judgement. It fits well with assessment, which is above all
a matter of informed judgement. Where decisions for compliance with COSHH are subject
to reasonable practicability, then the assessment should indicate why a decision has been
made.

There are various sources of information and indicators to aid decisions on reasonable
practicability:

• HSE codes and industry guidance;

• accepted good practice (but this may not necessarily be the same as usual practice);
• identification of what can be done (ie what is practicable) can be a useful starting point in
deciding what is reasonably practicable;
• the recommendations of manufacturers and suppliers;
• the hazardous nature of the substance involved and the risk it presents, both of which will
be clear if the earlier stages of assessment are suitable and sufficient.

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Services Provided:
Workplace Air Monitoring
COSHH Risk Assessment
Indoor Air Quality
LEV (Local Exhaust Ventilation) Testing & Examination
Legionella Risk Management
Legionella Maintenance
Workplace Noise Monitoring
Environmental Noise
Hand Arm Vibration
Whole Body Vibration
Breathing Air Line Tests
Face Fit Testing
Ergonomics
Lighting
Heat Stress Study
Training (in all the above)
Stack Emissions
Health and Safety Advice and Assessments
Electromagnetic fields (EMF)

Environmental Essentials (UK) Ltd

Ebenezer House
Ryecroft
Newcastle under Lyme
Staffordshire
ST5 2BE

0845 077 7761

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