Introduction

This document details Buckinghamshire Council’s policy and procedures for the implementation of The Control of Substances Hazardous to Health (COSHH) Regulations 2002 (as amended). 

The COSHH Regulations aim to reduce levels of occupational ill health caused by exposure to harmful substances, by requiring employers to assess the risks to health and safety from hazardous substances and prevent or adequately control exposure as far as is reasonably practicable.

2.1 Headteachers and Managers Must:

• Identify all hazardous substances used, stored, handled or generated in their area of work and compile an inventory.
• Decide whether each substance is still required or whether it can be replaced by a safer alternative. Minimise the number of hazardous substances in use at the premises.
• Consider the practicality of preventing exposure to hazardous substances.
• Ensure risk assessments are carried out for all hazardous substances.
• Check risk assessments cover the work activities concerned and are signed and dated.
• The risk assessments need to be brought to the attention of the employees who use the substances. They must also receive adequate information, instruction and training with records kept of the training.
• Ensure all hazardous substances are securely and appropriately stored.
• Ensure that all control measures, for example, local exhaust ventilation (LEV) such as fume cupboards, dust and fume extraction systems etc. are functioning adequately and that test records are up to date. LEV needs to be thoroughly examined and tested at least every 14 months by a competent person.
• Ensure appropriate Personal Protective Equipment (PPE) as identified in the risk assessment is available and that procedures for the care, maintenance and inspection of PPE are in place.
• Ensure Safety Data Sheets (SDS) and COSHH risk assessments are in place for new hazardous substances prior to purchase.
• Monitor compliance with COSHH risk assessments and re-assess when necessary (section 4.2)
• Ensure appropriate emergency procedures are in place for managing any uncontrolled release of a hazardous substance e.g. spillages.
• When disposing of hazardous substances follow the instructions in the safety data sheet data. If disposal by a licensed waste operator is required ensure that the appropriate waste transfer documentation is competed and retained. 
• Be aware of any activity by contractors/visitors involving hazards substances which may affect employees or members of the public.

2.2     Employees Must:

• Read the label on the product and refer to the SDS. Only products that are hazardous will have a label in place and require a COSHH risk assessment to be carried out.
• Read, and ensure they understand any COSHH risk assessment relating to any hazardous substances to which they or members of the public are exposed.
• Use control measures correctly when required as identified by the COSHH risk assessment.
• Report promptly to their Line Manager if they discover control measures are not in place or effective, are no longer working efficiently, or any hazardous substances for which there is no adequate assessment in place.

2.3     Contractors Working on Council Sites (including Schools) Must:

• Obtain safety data sheets for hazardous substances which they bring to site.
• Carry out COSHH risk assessments for any work activities involving hazardous substances on site.
• Prepare and follow written safe systems of work for the tasks carried out.
• Store hazardous substances securely when not in use.

This information should be available for inspection at the time the contract is arranged and copies kept in suitable places (e.g. cleaner’s storeroom/managers office).  Managers should ensure this is the case at local level as there is a potential risk to clients and employees from uncontrolled use of hazardous substances.

Hazardous substances can cause serious harm to people if use is not adequately controlled.

• a single exposure to a high concentration of a toxic substance (acute effects); or
• many exposures over a long period of time to low concentrations (chronic effects)

Hazardous substances may enter the body by

• Absorption through the skin and eyes
• Inhalation (breathing in)
• Ingestion (swallowing)
• Injection

The following steps are required to ensure the risks from hazardous substances are adequately controlled.

• Compile and maintain an inventory of substances
• Eliminate/substitute wherever possible
• Dispose of unwanted substances safely
• Obtain material safety data sheets
• Carry out/obtain COSHH risk assessment where required
• Implement the findings of the risk assessment
• Dispose of unwanted substances safely.

3.1    Inventory

An inventory should be kept of all hazardous substances present to which employees or non-employees may be exposed, the record form in Appendix 1 should be used. Separate inventories for different work areas may be needed if large numbers of substances are in use.

A copy of the inventory should be kept readily available for employees and the emergency services to consult.

3.2     Elimination/Substitution of Hazardous Substances

As a general principle, COSHH requires the elimination of hazardous substances from the workplace wherever possible.  The hazardous substances inventory should be reviewed regularly to ensure it is up to date and that the substances listed are still needed or whether there is a less hazardous alternative which can be used.

3.3     Disposal of Unwanted Substances

All substance should be disposed of in a responsible manner. Check the material safety data sheet for the manufacturer's recommendations. Chemicals for disposal should be clearly labelled and placed in a secure, designated area until ready for collection. Do not mix chemicals for disposal.

A record must be kept of any substances sent for disposal. Waste transfer notes should be obtained and kept for a period of 2 years from the date of disposal and hazardous waste consignment notes for 3 years from the date of disposal.

3.4     Product Information - Material Safety Data Sheets

Safety data sheets are provided by the manufacturer or supplier of the substance at the time of purchase.  All the information required to conduct a COSHH risk assessment is outlined within the SDS and should be transcribed to the COSHH risk assessment form.

Suppliers must provide safety data sheets for classified substances to the recipient under UK REACH. Many suppliers/manufacturers provide safety data sheets on their website or can be contacted to supply the most recent copy.

The SDS is not an assessment. It describes the hazards the substance presents and helps assess the risk associated with those hazards.

3.5     Risk Assessment

The COSHH regulations only cover the use of hazardous substances in the workplace. Lead, asbestos and radioactive substances have their own specific regulations and are not covered by COSHH.

For the majority of commercial chemicals, the presence of a warning label will indicate whether COSHH is relevant.  Common substances used in a domestic setting, such as washing up liquid and hand soap will also require a COSHH assessment if they display a warning label, are used within the workplace, and are a significant risk.

For hazardous substances used, stored, generated or encountered a risk assessment must be written. This can be achieved in a number of ways –

• Incorporation into a job or activity risk assessment.
• Adopting a generic assessment from a trade or professional body or similar source.
• Carrying out a separate COSHH Assessment.

Or by a combination of these as appropriate.

3.5.1   COSHH Risk Assessment

Where the risk from hazardous substances is to employees, it should be incorporated into the employees’ job-based risk assessment.

Where this is not possible a separate more detailed hazardous substance risk assessment is required.

3.5.2   Trade and Professional Organisation Assessments

A number of trade and professional organisations produce generic COSHH assessments for their members or specific groups, for example, CLEAPSS School Science Service produce generic COSHH assessments for school Science teaching activities (CLEAPSS Hazcards), and school Design and Technology and Art and Design activities; (CLEAPSS Model Risk Assessments).

4.1        New or Revised Assessments

When the COSHH assessment has been received or completed:

• Check that it adequately covers the proposed uses and amend, if necessary. This will be needed where more than one substance is involved in an activity or where a substance is used in a number of different ways, for example, diluting, spraying and hand applying.
• Sign and date the assessment.
• Ensure employees are informed about the contents of the risk assessment, understand and follow the control measures as outlined within that assessment.

4.2        Reviewing COSHH Assessments

The responsible person will ensure risk assessments are undertaken, and the assessments are kept up to date and reviewed:

• When there has been a change in work procedure.
• If the substance is used for a different task.
• If a substance has changed, e.g. new safety data sheet received.
• Upon HSE direction.
• Following any adverse incident involving the substance or task.
• Annually if there has been no change.

The SDS should be checked for updates when the risk assessment is reviewed.  COSHH Risk Assessments should be kept for three years and must be available for inspection as part of annual inspections and audits.

This section gives additional information which will assist in the assessment and control of hazardous substances.  The term ‘hazardous substance’ describes a wide range of substances with the potential to cause harm if they are inhaled, ingested, injected or absorbed through the skin/eyes or released into the environment.  Common substances such as cleaning materials, herbicides and pesticides can be hazardous and/or harmful to the environment.

5.1     Control Measures

Where it is not reasonably practicable to prevent exposure to a hazardous substance, control measures will be stated in the COSHH risk assessment to ensure the risk is adequately controlled.

Examples of control measures include, the use of equipment and systems of work which minimise the production of, or suppress and contain spills, leaks, dusts, fumes and vapours.

For example, the use of:

• fume cupboards
• dust extraction
• spray booths
• welding fume hoods
• personal protective equipment

Limiting the quantities of hazardous substances stored at the establishment and ensuring safe storage, handling and disposal will also help to reduce the risk. For example, the use of:

• a secure cupboard for hazardous chemicals
• a purpose-built flammable store or lockable metal cabinet
• appropriate equipment for transporting containers of substances such as bottle carriers
• limiting the number of people who might be exposed to a hazardous substance
• prohibiting eating, drinking and smoking in areas in which hazardous substances are used or stored
• adequate cleaning of walls and floors and high-level cleaning, for example, in areas such as workshops, pottery studios, etc. which are prone to the accumulation of dusts
• personal washing and drying facilities e.g. where there is a risk of infection or dermatitis
• appropriate hazard warning signs on cabinets and cupboards where hazardous substances are stored. If labelling an external store may increase the risk of vandalism use a Hazchem type sign

5.2     Maintenance of Control Measures

Engineering control measures such as fume cupboards, dust and fume extraction, spray booths etc. must be regularly inspected and maintained by a competent person.

All engineering controls must be visually inspected weekly. In addition, all local exhaust ventilation required for health and safety reasons must be regularly inspected tested at least once every 14 months by a competent person, (this will usually be carried out annually by a competent contractor) records of the tests must be kept for a period of 5 years.

5.3     Personal Protective Equipment

Personal Protective Equipment (PPE) includes:

• eye and face protection, for example, goggles and face visors
• protective clothing, for example, laboratory coats, overalls and aprons
• protective gloves and gauntlets, for example, made of rubber, PVC, nitrile, etc.
• respiratory protective equipment (RPE), for example, dust masks, half and full-face respirators

The need for PPE must be identified from the COSHH risk assessment.  However, the use of engineering and other control measures must always take precedence over the use of PPE.  This is because it protects a larger number of persons than PPE which only protects the wearer.  In some instances, both the use of engineering control measures, and PPE will be necessary.

Should the COSHH risk assessment identify that PPE is required then the assessment must include details of the PPE needed to ensure it protects against that particular risk e.g. the types of eye protection needed to protect against chemical splashes, impact from flying objects, radiant heat or light are all very different and it is not sufficient in the risk assessment to say ‘wear eye protection’.

Employees must wear personal protective equipment if specified within the risk assessment.

All PPE must be appropriately stored, regularly inspected, cleaned and maintained and/or be replaced when necessary.

5.4     Other Specialist Training

Training may be required before hazardous substances are used for example, dealing with spillages or other uncontrolled release and in the use of personal protective equipment.

No employee can be required to wear any respiratory protective equipment unless adequately trained in its use and fit-tested.

5.5     Environmental Monitoring

Where there is a suspicion that exposure to a substance hazardous to health may be approaching harmful levels or where the adequacy of existing control measures is questioned a one-off monitoring exercise may be necessary.

For example, this may occur in the following situations

• dust in areas used for ceramics or woodwork where these areas have re-circulating heating systems
• solvent vapour produced in reprographic areas with poor natural ventilation.

5.6     Health Surveillance

Health surveillance is typically only required in certain circumstances and is dependent or circumstances. Where there is a reasonable likelihood that an identifiable disease or adverse health effect associated with exposure will occur and the risk assessment shows health surveillance is appropriate for the protection of employees then health surveillance should be carried out.            

Monitoring and health surveillance records relating to named individuals must be kept for a period of 40 years.

Advice should be sought from Occupational Health if there is any uncertainty regarding the need for health surveillance.

5.7     Emergency Procedures/First Aid

Special procedures may be required for managing any uncontrolled release of a hazardous substance which could result in exposure well beyond that associated with day to day activities, for example, spillages, sudden failure of extraction ventilation or during a fire or flood and for personal exposure requiring first aid treatment.

This could include:

• availability of information on the specific hazards likely to arise in certain circumstances, for example, during a fire or accidental mixing of substances
• practice of emergency procedures
• information and training for employees in the special procedures
• first aid facilities and arrangements
• information for emergency services
• procedures for clearing up and safe disposal, for example, availability of a suitable spillage kit

It may be necessary for first aiders to receive special training in dealing with exposure to hazardous substances. Access to first aid assistance and equipment should be considered including a reliable, suitable water supply for skin and eye irrigation.

Appendix 1 - Inventory of Hazardous Substances

Appendix 1 Inventory of Hazardous Substances (Download)

Appendix 2 - Risk Assessment

COSHH Risk Assessment (Download)

Sign off Sheet of Understanding (Download)

Appendix 3 - General Precautions

These general precautions apply to all cleaning, maintenance and other proprietary substance in common use including those not formally classified as hazardous to health. For substances hazardous to health these general precautions should be supplemented by the COSHH assessment.

Before Use

• Ensure the least hazardous substance suitable for the task is used.
• Keep the number of different substances to a minimum (one descales product, one floor stripper etc).

Storage

Do

• Store products in cool, dry, well, ventilated place, some substances are affected by light, so store away from sunlight.
• In establishments with children/vulnerable adults keep substances secure (special arrangements may be needed for clients personal use items).
• Safely dispose of any unwanted substances.
• Ensure products are clearly labelled in original containers.
• Label spray bottles containing diluted product

Do not

• Re-use concentrate containers, dispose of safely.
• Decant concentrate into smaller containers.
• Remove labels from container or transfer chemicals into containers containing other labels.
• Store bagged substances directly on the floor.
• Store substances on top of one another in case of leaks and incompatible substances mixing.

Usage

Do

• Read the instructions on label and safety data sheet (if available) carefully before use.
• Avoid contact with skin – wear gloves whenever possible.
• Keep the lid on products when not in use.
• Wash splashes off immediately.
• Clear up spillages promptly following manufactures instructions.
• Make up only as much solution as you need for immediate use.
• When pouring or diluting concentrated substances wear eye protection.
• Report any health problems which may be caused by the use of substances at work to your line manger e.g. dry, sore, itchy skin; difficulty in breathing, or wheeziness.

Do Not

• Mix or use substances together unless instructions allow.
• Add any other chemical to substances containing bleach as deadly chlorine gas can be generated
• Use a product for a purpose for which it is not intended (check instructions for use).

Appendix 4 - Hazard Symbols

There are currently 2 different classification systems in use to denote hazardous and flammable substances -

• Previous system - black symbol on an orange background (Table 1)
• New – black symbol in a red diamond with white background (Table 2)

The 2 systems are not directly comparable, some symbols are different and the associated wording and explanations that go with the symbols are also different, as is the way some hazards are defined.

The previous system was replaced by the new one system the transition in 2015. In the meantime either or both systems may be in use on product labels and in hazard data sheets.

Hazard signs and their classification (Download)

4.1: Control of Substances Hazardous to Health (Download)

December 2024