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Pollution control - hazardous substances


Every year exposure to hazardous substances at work affects the health of many thousands of people. The high costs of ill-health arise from loss of earnings, loss of productivity, prosecution and civil action amongst others. Common examples of such substances include:

  • lung disease – caused by conditions
  • skin irritation, dermatitis or skin cancer – due to frequent contact with oils, contact with corrosive liquids and
  • occupational asthma – caused by sensitisation when using paints or adhesives containing isocyanates

Under the Control of Substances Hazardous to Health Regulations or "COSHH" Regulations, businesses are required to:

  • carry out an assessment of the risks from using hazardous substances in the workplace
  • decide what precautions are needed to prevent or control any risks
  • ensure that control measures are used and maintained
  • inform instruct and train their employees about the risks and precautions needed and
  • monitor exposure and where necessary, undertaking health surveillance of businesses.

What are the COSHH Regulations?

These regulations:

  • provide a framework to help protect people in the workplace against health risks from hazardous substances that may be used directly in the work (eg cleaning chemicals, chemical reagents) or may arise from the work (eg dusts, fumes and waste products)
  • lay down a sensible step-by-step approach to implementing the necessary precautions and are a useful tool of good management
  • apply to virtually all substances hazardous to health with the only exceptions being asbestos and lead (which have their own regulations) and substances which are hazardous only because they are radioactive, asphyxiants or have explosive/flammable properties.

A COSHH Assessment is a step-by-step approach and involves:

  • Hazard Identification - identify what hazards there are
  • Risk Assessment - evaluate the risks to people and
  • Take Further Action - for significant risks, decide on the action needed to remove or reduce the risks to insignificant levels.

Assessment is the responsibility of the business and those persons preparing the assessment will need to:

  • have access to, and understand, COSHH and other related legislation, Approved Codes of Practice and published guidance;
  • be competent to carry through the work of assessment;
  • consult widely within the workforce and inform them of results accordingly; and
  • consider peripatetic workers (who work for you on other premises).

Businesses must inform, instruct and train their employees regarding the substances and their associated risks. Sufficient information and instruction should be given on control measures, personal protective equipment, the results of any exposure monitoring or health surveillance and what procedures are to be taken in an emergency.

What is a hazard?

A hazard is the potential to cause harm and substances hazardous to health include:

  • substances classified as dangerous to health under the Chemicals (Hazard Information and Packing for Supply) Regulations 2002, usually known as "CHIP3"
  • substances with occupational exposure limits (these are specified in HSE Guidance Note EH40 which is revised annually)
  • biological agents and
  • dusts of any kind in substantial concentrations.

Identification of hazardous substances can be sought from:

  • hazard data sheets, labels etc from suppliers (who are required to provide them by law) from which businesses must draw conclusions on how the substance is used in the workplace
  • knowledge from within industry sectors such trade literature
  • published guidance / documents and
  • part V of the Approved Supply List published by the Health & Safety Executive.

What is a risk assessment?

A risk is the likelihood that a hazard will actually cause in the actual circumstances of its use and a risk assessment involves looking at:

  • the use, handling, generation, release etc. of hazardous substance
  • those who might be affected and their likely exposure level
  • the nature of exposure (breathing in, swallowing, skin absorption etc)
  • the current measures to prevent or control exposure and their effectiveness and use
  • the effect of accidental leakage, spillage or release and
  • all cleaning and maintenance operations.

The risk will depend on a number of factors, such as the hazard presented by the substance, how it is used, how exposure is controlled, the degree and extent of exposure.

What further action is required?

If there is no likelihood or insignificant risk, no further action until review of assessment. However, if risks have been identified, businesses will need to ensure appropriate control measures, in the following order of priority:

  • Removal - change the process or activity so that the hazardous substance is not required or generated
  • Substitution - replace with safer alternative (see HS(G)110 in References section) or use it in safer form
  • Reduce exposure – by reducing contact time or through the use of local controls.

Controls may include any of the following:

  • total enclosure of the process
  • partial enclosure and extraction equipment 
  • using systems of work and handling procedures which minimise chances of spills, leaks etc. or exposure to the substance(s) and
  • personal protective equipment (eg respirators, protective clothing) only as a last resort when you cannot adequately control exposure by any combination of the measures above.

Employees are required to make proper use of control measures and to report any defects and businesses are required to keep controls in efficient working order and good repair.

Engineering controls and respiratory protective equipment have to be examined and, where appropriate, tested at suitable intervals with suitable records of all such actions being kept.

Monitoring exposure is required in certain circumstances - eg where there could be serious risks to health if control measures were to fail or deteriorate or where you cannot be sure that exposure limits are not being exceeded – all records of monitoring should be kept.

When is health surveillance required?

Health surveillance is required:

  • where an employee is engaged in one of the processes listed in Schedule 5 of COSHH and is likely to receive significant exposure to the substance involved and
  • where employees are exposed to a substance linked to a particular disease or adverse health effect and there is reasonable likelihood under the conditions of work of that disease or adverse health effect occurring and it is possible to detect the disease or adverse health effect and suitable records must be kept by businesses for 40 years.

References and publications

  • COSHH pages on the HSE website 
  • COSHH Essentials – basic step-by-step guidance on COSHH 
  • L5-General COSHH ACOP, Carcinogens ACOP and Biological Agents ACOP(HSE) ISBN 0 7176 1670 3
  • A Step By Step Guide To COSHH Assessment - HS(G) 97 (HSE) ISBN 0 7176 1446 8.
  • 7 Steps To Successful Substitution Of Hazardous Substances HS(G) 110 (HSE) ISBN 0 7176 0695 3.
  • Health Surveillance Under COSHH (HSE) ISBN 9 780118 854474

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