www.alcumusgroup.com COSHH Compliance: Recent changes and common failings Mike Harris - CMS Operations Manager Alcumus Sypol
www.alcumusgroup.com
COSHH Compliance:Recent changes and common failings
Mike Harris - CMS Operations ManagerAlcumus Sypol
What are we going to talk
about…
• The most recent statistics
• COSHH overview
• Common failings in COSHH management
• Recent changes in COSHH management
Ill health in the UK
3*refers to “Health and safety at work, summary statistics for Great Britain 2018” - HSE
144Fatal injuries to workers in 2017/18Source: RIDDOR
9.7Annual costs of new cases of work-related ill health in 2016/17,excluding long latency illness suchas cancerSource: Estimates base onHSE Costs to Britain Model
billion30.7
Working days lost due to work-relatedill health and non-fatal workplaceinjuries in 2017/18Source: Estimates based on self-reports fromThe Labour Force Survey
million
2595Mesothelioma deaths in 2016, with aSimilar number of lung cancer deathslinked to past exposures to asbestosSource: Death certificates
1.4Work-related ill health cases(new or long-standing) in 2017/18Source: Estimates based on self-reportsFrom the Labour Force Survey, peopleWho worked in the last 12 months
million
Ill health in the UK
4
35%Injury
Cost to Britain of workplace injuries and new cases
of work-related ill health in 2015/2016 by:
Type of incident Cost bearer
65%Ill health
£3 billionGovernment
£3.4
billionEmployers
£8.6
billionIndividuals
*refers to “Health and safety at work, summary statistics for Great Britain 2018” - HSE
Ill health in the UK
Lung diseases contributing to
estimated current annual deaths
32%ChronicObstructivePulmonaryDisease(COPD)
22%Non-asbestos
Related lung cancer
20%Mesothelioma
20%Asbestos-related
Lung cancer
5%Other disease
*refers to “Health and safety at work, summary statistics for Great Britain 2018” - HSE
Ill health in the UK
6
Occupational asthma; causal agents
most commonly reported by chest
physicians during 2012-2016
Isocyanates
Flour/Grain
Cleaning Products
Wood dust
Enzymes, Amylase
2% 4% 6% 8% 10% 12%0%
*refers to “Health and safety at work, summary statistics for Great Britain 2017” - HSE
What are the primary set of regulations looking to address this?
The Control of Substances Hazardous to Health Regulations
2002 (as amended)
7
The important COSHH regulations…
• Have a written assessment in place for every anticipated workplace
exposure (Regulation 6)
• Prevent exposure or implement suitable measures to control exposure to
those substances through all routes of entry (Regulation 7)
• Use all control measures provided and maintain them to ensure their
ongoing performance (Regulations 8 + 9)
• Where there is concern exposure is not adequately controlled, conduct
monitoring and health surveillance to ensure the protection of employees
(Regulations 10 + 11)
• Inform employees about all areas of the assessment (Regulation 12)
• Make plans for in the event of spillage, first-aid or fire (Regulation 13)
8
Elimination &
Substitution (Reg.7)
Formal Assessment
(Reg.6)
Implement Controls
(Reg. 7&8)
Inform, Instruct and Train (Reg
12&13)
Inspect and Maintain (Reg. 9)
Exposure monitoring
(Reg. 10)
Health Surveillance
(Reg. 11)
The COSHH Cycle
9
Common Failings
Common failings with manual COSHH management
• Expertise• Very few people have a true understanding of COSHH hazards and risks.
• Ability to scrutinise supplier information against current ECHA classifications.
• Speed• When compiled manually COSHH assessments can take 30+ mins.
• Quality• Are you sure everything that is legally required is present?
• Is your assessment up-to-date with current enforcement requirements?
• Who checks your checkers?
• Standardisation• There is no agreed template for COSHH assessments.
• Visibility• Can everyone access their most recent COSHH assessment when they need it at or near the
point of risk?
• How can you be sure people have read the assessment?
Common failings with COSHH management generally
• Assessing a substance not an exposure
• Failure to consider process emissions
• Failure to consider biological agents
• Uncontrolled copies
• Lack of workforce awareness
Assessing a substance not an exposure
13
• The COSHH regulations require a COSHH assessment to be produced for all
exposure to hazardous substances.
• Not only must the assessment consider the hazardous nature of the product but
also;
• Quantity in use
• The activity type
• Area of use
• Duration of work
• Frequency of use
• Failure to do this will lead to your COSHH assessments being little more than a
glorified Safety Data Sheet
Failure to Consider Process Emissions
14
• Process emissions are one of the most widely overlooked forms of hazardous
substance.
• These are the emissions such as fumes, dusts and vapours given off during a task
and include common substances such as:
• Welding fumes
• Wood dust
• Exhaust fumes
• Many of these emissions have serious ill health effects associated with them.
COSHH assessments are required for these in the same way as a purchased paint
or adhesive.
Failure to Consider Biological Agents
15
• A micro-organism, cell culture,
or human endoparasite,
whether or not genetically
modified, which may cause
infection, allergy, toxicity or
otherwise creates a hazard to
human health
• Example, Legionella
Uncontrolled copies of assessments
16
• Uncontrolled (printed) copies of assessments, while practical for site,
are potentially out of date the moment they are printed or created.
• Alcumus Sypol update over 200 assessments everyday, with potential
changes to:
• Hazard classification
• Emergency procedures
• Occupational hygiene/health
• Control measures
• Failure to keep uncontrolled copies up to date can leave operatives
vulnerable on site.
Lack of workforce awareness
17
• The biggest failure witnessed across all sites is the lack of awareness
by the workforce.
• Even when assessments are in place, operatives are often unaware of
where to source them or how to interpret them.
• Instruction and training on COSHH is a requirement.
• If assessments are in place, but operative don’t use them, it is simply a
box ticking exercise and will protect employees to the required level.
Lack of workforce awareness
18
• “This is the way we’ve always done it”
• “Why was it safe to do yesterday and its
not today?”
• The culture and perception of health and
safety in general is and needs to change.
• This can be very difficult with topics like
COSHH, which can be seen as “niche”.
Recent changes
EH40 updates
EH40/2005 Workplace Exposure Limit Changes
• Introduces the new limits listed in Directive 2017/164/EU, the fourth
Indicative Occupational Exposure Limit Values (IOELV) Directive.
• Came into effect on the 21st August 2018.
• New entries for 14 substances – common substances such as acetic
acid, nitrogen dioxide, nitrogen monoxide, sulphur dioxide, cyanide
compounds.
• Reduction in WELS for 11 substances – including acrolein, carbon
monoxide, dichloromethane, bisphenol A.
EH40/2005 Workplace Exposure Limit Changes
• New skin notations for 4 substances – tetrachloroethylene, methyl
formate, glycerol trinitrate, 1,4-dichlorobenzene.
• HSE consulted on a lower STEL for glycerol trinitrate but reverted back to
IOELV.
• Transitional arrangements for underground mining and tunnelling for
WELS for nitrogen monoxide, nitrogen dioxide and carbon monoxide until
2023.
What does this mean for me?
• If you use, or come into contact with any of the chemicals which have a
new / amended WEL or a new annotation (i.e. sk) action is required.
Changes to Welding controls
Welding and COSHH
• What COSHH covers:
• Purchased products (e.g. paints, adhesives)
• Process emissions (e.g. dusts, welding fume)
• Biological material (e.g. pigeon droppings, blood)
• Contaminants (e.g. used engine oils)
• While bulk metal is regarded as an article and therefore exempt from
COSHH. Hot work releases extremely hazardous fumes.
• Many people believe they protect against welding hazards, though all they
are considering is temperature and light exposure.
Recent HSE guidance
• February 2019.
• STSU1 – 2019 – Change in enforcement expectations for mild steel
welding fume.
• Targeted for all worker, employers, self-employed, contractors and any
others who undertake welding activities including mild steel in any
industry.
• With immediate effect, there is a strengthening of HSE’s enforcement
expectation for all welding fume, including mild steel welding; because
general ventilation does not achieve the necessary control.
Why was it needed?
• The International Agency for Research
on Cancer (IARC).
• While the main focus was on
carcinogenicity resulting from UV light
exposure during welding.
• Causal links were apparent between
inhalation of welding fume and
increased levels of lung and kidney
cancer.
Why was it needed?
• This is aimed at Mild and Carbon Steel.
• The Institute of Occupational Safety and Health (IOSH) reported on
January 21st that the HSE would enforce enhanced control measures for
welding in the UK.
What has changed?
• The enhanced enforcements:
• Indoor welding tasks require the use of LEV. If LEV is unable to
control fume capture, then Respiratory Protective Equipment (RPE)
is also required.
• Outdoor welding requires use of RPE.
• Enforcement of the raised control standards is with immediate
effect under COSHH Regulation 7.
What has changed?
• Regardless of duration, HSE will no longer accept any welding undertaken
without any suitable exposure control measures in place, as there is no
known level of safe exposure.
• This means that even with exposure monitoring data inhalation controls
will be required in all cases.
• No transition or implementation period was specified by the HSE.