Do you use solvents, chemicals, oils, paints, powders, or generate smoke, dust or other vapours? COSHH applies to virtually all processes in all industries and requires you to demonstrate that you are adequately controlling exposure of your employees.
Last year HSE undertook a COSHH project based on major hazard sites in South Wales. The aim was to examine how well employers were complying with the COSHH Regulations and controlling exposure in the major hazard industries. The findings of the project are applicable to anyone dealing with COSHH issues.
We asked all major hazard sites in South Wales to provide us with a list of their 'top ten' COSHH substances and work activities. A simple tool was provided to these companies to rank their substances according to the duration of exposure, numbers exposed, and the hazardous nature of the substance involved. Following a visit from an inspector 5 work activities where selected for physical inspection. A COSHH inspection proforma was completed at each of these to enable an assessment of the standards found against the 'benchmark standard'.
Differences between the benchmark and actual standards were measured as a 'risk gap' in the following categories:
Both moderate and substantial risk gaps require positive enforcement action to be taken. Visited companies were provided with detailed written feedback, asking for a time dated action plan of how they intended to address their shortfalls. These issues were then followed up by regular communication and inspection, and were integrated into local inspection plans for the sites.
Of the 2 extreme risk gaps identified one resulted in an improvement notice. Written advice was given on the other, because it related to a task that was not being immediately carried out, but could be carried out in the future.
The current position is that all of the major hazard sites involved have made significant progress with COSHH. Feedback from the companies has confirmed this. By carrying out the work in this way, we were able to satisfy the first three aims of the project:
In order to satisfy aim 4 - (Improve standards of compliance with COSHH) we needed to involve smaller stakeholders that are not necessarily major hazard sites, but still have interesting COSHH challenges to deal with. In some ways, these sites were seen to be more important to 'get the message across to' than the major hazard sites, simply because they do not have the resources of the larger sites to address the problems in the same way.
A project feedback event was held, and a number of representatives from all relevant chemical sites in South Wales were invited. By publishing the findings on HSE's website, sharing the information with anyone who deals with COSHH across all industries, we are hoping to further raise the profile of and compliance with COSHH. Overall findings for the project are presented in the project report.
The project focused upon 3 key areas of COSHH. The findings for each are presented below.