COSHH - Workplace monitoring

What you should be aiming for…

Before embarking on a monitoring programme, it is important to have clear objectives of what you intend to achieve from the exercise. It is also important to consider exactly when you should be monitoring.

Why monitor?

Well planned monitoring provides a demonstration that your engineering and procedural controls are adequately controlling exposure to hazardous substances.

The results of monitoring will highlight where your controls are not adequate, and target the areas where improved controls are required (it should be possible to identify specific exposure 'hot spots' - procedures or tasks that particularly increase exposure). On the other hand, monitoring can also be a useful demonstration that further control measures are not required, and you are already doing all that is reasonably practicable.

If there are changes to your process, or work procedures, monitoring can be used to assess whether or not employee exposure has changed as a result of the changes.

When to monitor

The decision of when to monitor should be informed by your COSHH assessment. It is usually appropriate where there is the potential of exposure to particularly hazardous chemicals (carcinogens or sensitisors), where there is significant exposure to less hazardous chemicals (such as solvents), or where you have dusty processes. COSHH Essentials is a very useful tool to help you target areas where monitoring may be required.

• COSHH Essentials website

You should specifically repeat a monitoring exercise if there are any changes to plant or procedure.

A sensible approach should be taken to determine how frequently the monitoring exercise should be repeated (assuming there are no process/procedural changes as discussed above). You are not required to re-monitor following the initial exercise (and especially if the results show that you are achieving adequate control), however, it does provide you with the assurance that your control measures are still functioning as they should.

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Project findings

• Monitoring seems to be carried out at the majority of the sites we visited under the project. Generally companies place a lot of value on monitoring, and set aside suitable resource to ensure that it is carried out.
  
• Key substances with Occupational Exposure Limits were generally identified in COSHH assessments, and monitoring carried out, however a common finding was that monitoring was carried out for the sake of it, and there was no clear aim to the exercise. We saw several examples where monitoring results were routinely collected where it was clear there were 'exposure hotspots' and no corrective action had been taken.
  
• It was common to find on-going monitoring programmes in place on major hazard sites, which is positive, but considering the observation above, these required clearer objectives.
  
• Whilst occupational exposure levels are recognised it is unusual to find 'in-house' exposure levels set and it seemed substances without OELs were generally not considered when identifying monitoring needs. However, some sites did set their own 'in-house' levels below EH40 OEL's or where there was no OEL.

Points to consider

• Why is monitoring being carried out - be clear on your objectives and know what you intend to do with the results
  
• Use monitoring to help you identify areas where you may be able to further reduce exposure to as low a level as reasonably practicable
  
• Be realistic about re-monitoring and consider how frequently the exercise should be repeated to get the best value
  
• Think about activities you carry out on site where monitoring should be in place and isn't - do you have any unusual/infrequent activities? Remember to include maintenance and contractor activities
  
• Do your monitoring results show there is a need for 'retraining'? This is particularly appropriate where individual employees are identified as having disproportionately high monitoring results

The presentation from Dow Corning gives a detailed account of the strategy and approach they used to control exposure to a hazardous dust on their site.

• Dow Corning presentation [669kb]

This HSE presentation (given by an Occupational Hygiene Inspector) discusses monitoring strategies and the various equipment and techniques available to implement a successful monitoring programme.

• HSE presentation [279kb]

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