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:
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:
Menu
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 risksIn 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. |
2 |
Review section 8 Exposure Control and section 2 Composition. |
3 |
Decide from the above information, what the primary risks are. |
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. |
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?
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 | |