COSHH not the cosh

This blog post was written by Earl Anderson, an associate consultant who works with us.

The original Control of Substances Hazardous to Health Regulations 1988 (COSHH) came into force in October 1989, it was implemented to protect those who may be exposed to hazardous substances in the workplace: not as some cynics had said “to place an unnecessary burden on the employer ie to cosh them over the head.

The regulations have been amended and replaced several times over to the present Control of Substances Hazardous to Health Regulations 2002 (as amended), yet nearly 25 years later there are some employers who remain blissfully ignorant of the requirements of the regulations.

In defence of the employer, many have come to rely on the “external Consultant”, without realising that some of whom have had very little training with regards to chemicals.  In other cases the employer has delegated the task of carrying out COSHH assessments to a member of the work force as an “add on” to their workload.

In my experience, over the years I have seen the Material Safety Data Sheet (MSDS) transposed on to a pro-forma and presented as a COSHH assessment. I have also seen it called a COSHH Sheet and the phrase a COSHH risk assessment used.  I cannot over stress that a MSDS is not a COSHH assessment. The MSDS provides general information on a substance or product which is a valuable aid in completing a COSHH assessment.

With the boom in information technology, many employers are turning to “off the shelf electronic COSHH assessments” not realising their limitations. COSHH assessments are site and task specific and are best done by those directly involved with the process or substance with the assistance of specialist  “in house advice” or  “the external consultant” depending on the complexity of the task or process.

The key to completing a suitable and sufficient COSHH assessment is ensuring the assessor is competent to do it - i.e they are adequately trained and have the relevant experience; likewise for any specialist advisor you may call upon.

Earl's background is chemistry and he attended his first COSHH assessment training course at the Institute of Occupational Health, University of Birmingham back in October 1989. Like me, Earl is a Chartered Chemist, a Chartered Safety and Health Practitioner and OSHCR Registered Consultant.

If you need help with COSHH, contact us through our website.