Hazardous substances are essential elements of many manufacturing and engineering processes, yet too many site owners are in the dark about their duty of care under The Control of Substances Hazardous to Health (COSHH) Regulations 2002.
Simply storing safety data sheets is not enough to protect your team – so how do you go the extra mile to meet legal obligations? Our health and safety specialists share the fundamentals of COSHH compliance.
- Don’t rely solely on PPE. Instead, rethink procedures to eliminate unnecessary substances or introduce lower-risk substitutes. Undertake a COSHH inventory to review stock and responsibly dispose of redundant or out-of-date supplies.
- If protective equipment is required, carry out full employee training and a thorough PPE assessment to ensure all provisions are properly used and fit for purpose.
- Switching to a new substance? Make sure COSHH, fire and DSEAR assessments are updated to reflect changes in risk and are communicated to your team.
- Review COSHH assessments for all products every 1-2 years and share outputs with staff and first aiders. Reviews should cover all aspects of use, from spill clean-up to storage, including accurately labelling containers of decanted chemicals. Remember, you can group similar materials – such as oil or greases – under one assessment.
- Some processing, including cutting or drilling, can generate wood or metal dust that may require a separate COSHH assessment. When dealing with dust day-to-day, use filters to remove swarf and fines, and take precautions when moving or tipping machine waste.
- A number of substances are subject to strict Work Exposure Limits (WELs). Look to the HSE’s EH40/2005 publication for a summary of acceptable levels.
- Stay updated with changing HSE guidance – including tighter controls around welding and metalworking fluids (MWFs):
- Welding fumes are now considered carcinogenic, so review your COSHH assessment and implement appropriate measures to prevent exposure, such as using LEV rather than RPE, and providing controls when welding outside.
- Check MWF, LEV and compressed air equipment to prevent inhalation of harmful mists. Similarly, adding time delays to CNC doors allows vapour to dissipate before being breathed in.
- Undertake monitoring to ensure MWFs are as low as reasonably practicable.
- MWFs can also cause severe skin irritation, so keep tanks covered, add splash guards and train staff to safely mix top-up sumps. Test water-based coolants weekly to identify bacteria and problem pH levels and retain records for five years.
- Implement a comprehensive health surveillance programme to track reports of employee ill health, monitor controls and get an accurate view of overall worker wellbeing.