I wrote these notes for the Printing Industry, though the principles are applicable in all other areas.

What is required

The key steps in COSHH assessments are:

  1. To identify the risks
  2. To identify who is exposed to those risks
  3. To determine how the risks shall be controlled
  4. To implement these controls
  5. To monitor the effectiveness of the controls

Sources of information

The main source of information is the materials safety datasheet which must be provided by the supplier. This is discussed in more detail below. It is important to realise that the MSDS tells you only about the risks. Who is at risk and how these risks may be controlled is under the control of you, the user and therefore COSHH requires more than just the accumulation of MSDS’s.

The other sources of information areEH40/YY Occupational Exposure limits which are available from HSE Books. These change from year to year, and the YY part refers to the year. The version available at the time of writing is EH40/05.  Whilst it is should not be necessary to have EH40/YY to carry out COSHH assessments, the variability of MSDSs makes it highly desirable.

MSDS’s

These have a common format, but be warned that the quality of MSDS’s varies from supplier to supplier. The format is:



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How to carry out an assessment of substances hazardous to health (CoSHH assessment)

Exposure limits and standards

There are two types of limit and standard.

With both MELs and OESs, the target is to get as low as is reasonably practical under the limit or standard.

Both standards are expressed as both short term and long term exposures. Normally short term relates to the exposure over a 15min period and long term relates to exposure over an 8-hour period.

Exposure limits may be expressed in parts per million (ppm) or mg/m3 which is not quite as easy as ppm to appreciate. Note that these values relate to the constituent itself and allowance must be made for the concentration in the final product. A substance with an OES of 100ppm present at 5% effectively means that the exposure may be 2000ppm of the final substance (ie 100ppm/5%).

As a guide, beware of substances in the low 100’s ppm and be very concerned when it goes below this.

(For some notes on typical concentrations measured, see "Some solvent measurements from printing") 

Primary risks

In general, ingestion is not a primary route, though vomiting after ingestion may cause serious problems if vomited material is taken into the lungs which are far less robust than the digestive tract.

Hierarchy of controls

You are required to choose from the highest reasonably practical alternative in the following hierarchy. I think that it is fairly obvious that as you go further down the list, then you get closer to the substance and more and more things have to work to reduce the exposure.

Control Comment

Elimination

Stop using the substance or process

Substitution

Use a less hazardous alternative

Engineering

eg Provide local exhaust or dilution ventilation

Administrative

eg Limit exposure to people who are trained in the process

Personal Protective Equipment

eg provide gloves

Assessing risk

I recommend the following steps.  Note that, with experience, you will probably go to step 2 before step 1.

Step Action
1

Review Section 11 Toxicological Information and Section 3. 
Are the risks caused by single or repeated contact?
What damage occurs?

2

Review section 8 Exposure Control and section 2 Composition.
Are there any MEL’s? 
Are there any OES’s?
If so what is the nett exposure concentration?
Nett exposure concentration = MEL or OES ppm / Concentration

                                                  
3

Decide from the above information, what the primary risks are.
For example:
A substance which cause corneal burns on contact must obviously be kept away from the eyes.
A substance which causes skin defatting obviously needs to be kept away from the skin.

Steps in assessing risk and assigning controls

Assessing exposure

Exposure really relates to those who use the substance or those who may be affected by its inadvertent release.  In general, the problems due to inadvertent release are low in the Printing Industry; the predominant problem is the risk of fire if large quantities of solvent are spilled.  200L of IPA spread over a large area causes a major fire risk.

Assigning controls

Refer to risks you have identified above.

Ask how you are going to control each one.  Choose your control measure from as high up the hierarchy as possible. 
What is required to make this control measure work and keep on working?
eg Do extraction filters need to be changed regularly?  How do you control the continued effectiveness of activated carbon filter masks?
Are there any conflicts with other control measure?  eg Is the glove material incompatible with other fluids used?  Do you need to colour code gloves?

Preparing for the worst

First aid measures

Review the first aid measures on the MSDS and transpose these onto you COSHH assessment form.

Are there any special provisions required? eg Treatment creams or eye baths.  Have you got these already?

Spill provisions

Review the required provisions on the MSDS.  Have you got the measures required and are they quickly available at the point of use, storage or transport?
eg How do you stop the substance entering the drains? 

Implementation

Informing people

The whole exercise is pointless unless those who are responsible for working with the substance know about it. The key steps are:

Step Action
1

Make copies of the assessments available at the point of use.
I would also strongly advise having a summary of substances and controls available at the point of use.  You can get several substances onto one page.

2
Tell everybody about the substances, the risks involved and how these are going to be controlled.  Do not assume that, because people have worked in the particular industry for many years they know this already.
3
If there is a potential conflict, say with glove materials, then tell people how you are going to overcome this. 

Implement the controls

If there is a phasing to the controls, eg PPE first, then local exhaust ventilation, then tell the people exposed that this is going to happen.

Monitoring

Health surveillance

It may be that when making your assessment, you identified the need to carry out a health check, say for Dermatitis.  Set up a system to do this, record the finding and investigate what is going wrong if you start to get adverse effects.

Are controls being used?

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Section
Comments
1
Identification of product and company  
2
Composition/Information on ingredients One of the prime sources of risk identification to more experienced assessors
3
Hazard identification Very variable. Quite often is not as helpful as it sounds
4
First aid measures Used in determining what to do if things go wrong.
5
Fire fighting measures
6
Accidental release measures
7
Handling and storage .
8
Exposure control/personal protection One of the prime sources of risk identification
9
Physical and chemical properties Not normally of much use
10
Stability and reactivity As for 4,5,6
11
Toxicological information One of the prime sources of risk identification
12
Ecological information Used for determining how to minimise environmental impact.
13
Disposal considerations
14
Transport information Relate more to the supplier than the user
15
Regulatory information
16
Other information