No one’s too small to COSHH: how small businesses can ensure compliance

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The Control of Substances Hazardous to Health Regulations 2002 (COSHH) sometimes seem so complex they must surely be applicable only to big business. This is not so: COSHH applies to all organisations.

COSHH does not relate only to large concerns such as big chemical plants. Almost every business uses chemicals — even if just for cleaning — and the requirements of COSHH need to be considered. It is not just a matter of compliance. Expensive and unnecessary issues can arise if COSHH risk assessments and controls are not put in place; and even small quantities of chemicals can lead to ill health or injury. This article will not attempt to go through the legal requirements of COSHH in detail. Rather, it will point out areas for risk assessment and control which a small or medium-sized enterprise (SME) can then consider for its business operations before researching the legalities further.

Aware of the risk?

Perhaps the main issue for SMEs concerning COSHH is simply being aware of the risk. For example, the Health and Safety Executive’s (HSE) “Bad Hand Day” initiative points out that nearly 70% of hairdressers experience some kind of skin damage in their working life. This will typically arise from “wet work” and contact with chemicals such as shampoos, dyes and other hair care products. These are chemicals, and some are relatively dangerous ones, albeit in small quantities. Sometimes they are not being adequately controlled.

Similarly, with the cleaning and horticultural sectors, “familiar” chemicals — some of which we may have in our homes — can have serious consequences if they are not used with adequate controls. They can all constitute substances hazardous to health. This, in turn, means that risk assessment is not merely for legal compliance but ensures the business is not exposed to unnecessary risk, such as the loss of key people due to injury.

Risk assessment in COSHH is not just about reading the Materials Safety Data Sheet (MSDS). This is a misunderstanding common among some SMEs. The MSDS (also known as the Product Safety Data Sheet, among other names) is an important document as it gives essential information, for occupational use, about the chemical, its health effects, toxicity, first aid, how it would react with other substances, storage, disposal, relevant personal protective equipment and spill-handling procedures.

This is all vital information. However, it is not a risk assessment. Whether the chemical is a hair dye or an insecticide, it is necessary to look at the process involved, how the chemical will be used with other substances and any reaction that might happen. There is then the human element; how the frequency of use, as well as the training and awareness of those who will be exposed to the substance, will impact on the risk. These are all things that an MSDS will not tell you.

In control

The outcome of the risk assessment will normally lead either to the removal of certain elements of the risk or to putting controls in place. Controls need careful consideration. Small construction or cleaning companies may be involved in operations at a number of different client sites. This can create the need for careful selection of working methods and substances used, e.g. having to store or use chemicals in areas difficult to access can make the risk greater than in other locations. COSHH controls, like all those relating to other health and safety aspects, need to be specific to individual projects. Generic approaches to risk controls can be beneficial for awareness and training but they do not replace the need to look at the specific.

There is a COSHH requirement that relates to the need to have arrangements in place for possible accidents, incidents and emergencies involving hazardous substances. This does not just mean first aid, although it is always worth checking that proper provision has been made for this: are there trained first aiders using proper equipment? It also includes reference to how spillages would be dealt with, e.g. are there at least some staff trained to deal with spillages? Do they have the correct personal protective equipment? Do they have the correct materials or methods to clean up the spillage? How would the contaminated materials be disposed of legally? These are all questions that need to be considered before the event; it is essential to act in an organised, effective way to avoid unnecessary safety and legal issues.

What type of COSHH controls?

This article looks at some of the key issues to consider for COSHH risk assessments. Decisions about risk controls should be based on a number of factors and individual circumstances — not just what it says on the MSDS. The following examples relate to specific sectors, although many of these apply to SMEs generally.

To the uninitiated, horticulture and landscaping seem bucolic. This is certainly not the case in commercial applications and the industry faces a number of health and safety risks. One of the main issues regarding COSHH is the storage, decanting and use of multiple types of horticultural chemicals, e.g. insecticides and fertilisers. This can also influence fire risk. Some locations may be accessible to the public and so it will be necessary to determine how incidents such as spills can be dealt with promptly and safely. Occupational health is equally important, especially for any de-skilled activities. COSHH needs to be carefully considered for individuals involved in these, whether permanent or contract staff. Occupational skin diseases and other serious consequences can stem from unnecessary contact with chemicals, and it can never be assumed that individuals will already be aware of this.

Biohazards are just one aspect of cleaning operations that come under COSHH. These may, for example, be human or other animal bodily fluids. There need to be clear training and protocols on what to do where biohazards are present. These may include different protective clothing and agreed disposal methods for the substances concerned — the controls in place for other cleaning activities are not likely to be adequate or acceptable.

Builders face multiple hazards depending on the type of work they undertake, often related to the location and, sometimes, diversity of jobs undertaken. If pressurised gases such as propane are used, then their safe operation and storage needs to be considered. Where sub-contractors are employed on a job, their COSHH risk assessments should also be in place and verified by the principal contractor as being adequate.

Hairdressers may not consider the chemicals they use to be risky but they can be. Poor storage is frequently an issue: for example, aerosols can explode near heat sources. Staff should be required to wear non-latex gloves when applying hair products such as dyes and shampoos. The key point is to conduct an adequate risk assessment, keep it under review and ensure that all staff understand the importance of these issues from day one.

Conclusion

COSHH compliance requires thought. It is not just about reading an MSDS. The fact that that an SME has not experienced any health or safety incidents in the past is almost certainly just down to chance and not because of effective risk controls. The lives of principals and staff, as well as the long-term financial security of an SME, should not be riding on luck. This is especially true when relatively straightforward risk assessments and controls can reduce unnecessary risk. They might even contribute to a more cost-effective way of doing things.

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