COSHH Assessment
COSHH Assessment
Introduction
A popular misconception is that the Material Safety Data Sheet for a substance is a COSHH assessment. The difference between an MSDS and a COSHH assessment is that the former describes the properties such as health effects and emergency procedures for a substance whilst the latter assesses the exposure of people to substances used or generated by a work activity. It follows that a MSDS (or several MSDS') is prime source material for a COSHH assessment, however it must be recognised that this is NOT a substitute for an assessment.
A COSHH assessment must be performed to determine the risks to the health of people EXPOSED to that substance USED or GENERATED by an activity. COSHH applies equally to ALL workplaces and not just workshops and laboratories. In order to assess exposure a number of factors have to be considered.
Interpretation of information in a Material Safety Data Sheet
For those of you who are unfamiliar with a MSDS, or who want to find out more about the information presented to help support you carry out a COSHH assessment, please refer to the Guidance on How to Interpret Material Safety Data Sheets.
COSHH Risk Management
The COSHH assessment is an evaluation of risk to detemine what controls may be necessary to reduce/minimise exposure whilst ensuring safe handling, use, storage, transportation and disposal of a hazardous material or substance. The degree of control regarding exposure will depend on many factors:
- the substance phase (e.g. gas, vapour, mist, fume, liquid, powder, granule, paste, fibre, etc). This will often dictate how easily you can be affected by the substance. In many cases the substance phase can change during an activity - a solid may turn into a dust or a liquid may vapourise to give two examples. Usually, solids and liquids can be easily contained but dusts and vapours can quickly disperse over wide areas.
- route of entry into the body (e.g. Can you inhale it? Can you absorb it through your skin? Can it enter through a cut/abrasion or puncture? Can you get it into your eyes? Could it contaminate other things if it got onto your own clothes?)
- the severity of health effects (Carcinogenic, sensitising, toxic, harmful, irritating, corrosive etc.) The risk phrases or hazard statements will indicate the risks. R45, R46 or R49, or if a known carcinogen, or which carries the risk phrase of R42, R42/43, or which is listed as an asthmagen (a potential cause of occupational asthma) or sensitiser. Any substance or mixture carrying information regarding these must be controlled to maintain exposure to as low a level as is reasonably practicable.
- does the substance or mixture have any Workplace Exposure Limits (WEL) assigned to it? You can look these up on the latest list within the HSE's Guidance, EH40. If it has, then it is important to control exposure to that substance to ensure that the limit is never exceeded. Working with small amounts however in a controlled way may mean that it is not necessary to worry about these, but this all forms part of the risk evaluation.
- health status of those involved or affected by the use of that substance (some may be more susceptible to ill health effects than others e.g. asthmatics, pregnant women, immunosupressed etc). You may need to find a safer material or change the way that you work in order to exacerbate an existing known health condition. The Health and Safety Department and Occupational Health may be able to provide you with further support should you be worried about working with a particular material due to your health status.
- the stability of the substance (Does it need to be handled a certain way? Kept away from certain chemicals/substances/materials? Stored in a specific way? etc). Again, there risk phrases or hazard statements may indicate the risks. You will need to ensure that the relevant equipment and storage facilities are available to you to manage any specific risks here.
- the environment in which it is intended to be used (fume cabinet; glove box; portable local exhaust ventilation; bench extraction; open environment with general ventilation; enclosed space with limited or little ventilation; outside etc). You may wish to reconsider what environment you work in once you have sufficiently established the level of risk. Do not assume that a fume cabinet will remove everything from the workplace - there are a number of different types and you need to ensure that you have the right one in place to manage the risks. Similarly they must be inspected and examined every 14 calendar months and be in good working order. This may need to be verified prior to your work. If you are unsure about any of this, please refer to the person responsible for the area in the first instance or secondly, the Health and Safety Advisor.
- the activity may also generate other substances through intentional chemical reactions or side reactions such as thermal decomposition. It is not always easy to predict side reactions but it must be emphasised again that the COSHH assessment must cover exposure to ALL hazardous substances and must NOT just be a collection of information based upon individual details from separate MSDS.
- Personal protective equipment - should always be considered as the last resort over engineering controls and other methods of working. If specified in your COSHH assessment, you need to state type e.g. nitrile gloves, or type of filtering facepiece (FFP1/2 etc), otherwise you cannot demonstrate how you are managing the risk of exposure.
Essentially you are required to plan your work activities involving any hazardous material as you would any other activity and consider whether you can manage the risks effectively considering the above.
When do I need to complete a full written COSHH Assessment:
For all activities that use or produce hazardous substances (consider hazardous fumes, gases, vapours, mists, dusts, fibres etc), a full written COSHH assessment is necessary where there are considered to be SIGNIFICANT risks. If you have evaluated the risks and consider that the risks are insignificant, this can be stated in the SSOW that you have already generated for the activity and the risk assessment that supports this can explain what controls you have in place to maintain the risks to an acceptable level. You may draw this conclusion where you are already working under strict working practices e.g. where you always work in a fume cupboard/glove box or where the quantity of materials that you are using are small, or where you are only using the substance once or infrequently and it is of a low hazardous nature. For example, products that are irritants and flammable will always have a MSDS, but if used in small quantities, where there is no potential for the substance to enter the body (for example, perhaps they are pipetted, or provided in granular form) you may decide that the main control to manage the risks is to store the product in a flammable store. The pipetting arrangements, or dispensing the material using a shovel and suitable storage (putting the material in a flammable store when not in use) can be stated in the risk assessment and this will suffice. Where you deem the risks to be SIGNIFICANT during this process it may be easier to complete the following on-line assessment form as this will guide you through the process. Most of the required information can be selected from within the form but some safety critical information needs to be typed in. Guidance to where the safety critical information can be found on MSDS sheets is detailed on the form. Please include all materials used within an activity and all by-products given off if this is relevant to the activity. If easier, break the activity down into separate tasks e.g. pouring, transporting, weighing for example. This is particularly relevant where you need to put into place different control measures to control different risks.
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For further information on COSHH, please refer to the guidance document produced by the HSE: http://www.hse.gov.uk/pubns/indg136.pdf
Search completed COSHH Assessments
Guidance on how to interpret Material Safety Data Sheets (MSDS)
Be aware of the need to manage the risks in particular for Hazardous and Restricted Substances. Some of these will require annual reporting to the Home Office.
BIOLOGICAL RISK ASSESSMENT - for those using biological samples, materials, or human specimens