Council Procedures for 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).