Phil Chambers BSc CMIOSH, Strategic Safety Systems Ltd
Over the years, I have seen a range of assessments of substances hazardous to health. Some pose problems, so here are five common mistakes and what you need to do to avoid them.
Mistake 1 — A collection of datasheets
I sometimes go into companies and the management says: “Here’s our CoSHH file.” You look at it and find that it is just a collection of (often incomplete) datasheets.
What you are required to do is assess the risks from each substance depending upon how you use it in your workplace, then put appropriate measures in place to control the risk. Finally, you have to verify that those control measures work. And don’t just go by what you’ve bought recently; open up cupboards and see what might be lurking.
Mistake 2 — A perfect set of CoSHH assessments sitting on the shelf
The next mistake is to have a perfect set of CoSHH assessments in a pristine folder, while people on the shop floor don’t know anything about them.
A thick manual full of assessments and datasheets on the shop floor is not a workable solution, so I promote the practice of having summaries at the point of use. These state how the substances are to be used and the emergency measures to take in the event of an incident. You also have to talk to people about these instructions. It is best practice to involve them when coming up with the control measures in the first place — that way they are more likely to buy into them.
Mistake 3 — Getting distracted by trivia
I have seen control measures for a carcinogen lost in a collection that included Mr Sheen (with separate assessments for Original and Pot Pourri). If you assess every substance on your site, then apart from the effort involved, you will end up with an unworkable system where the critical substances are masked by the trivial ones.
It is critical that people using substances believe that following the control measures is a necessity. If they are asked to follow measures that they regard as silly, it can devalue the whole approach. By all means cover yourself by listing substances that are low risk, but don’t clog up the main system.
Another way of making it controllable is to group substances together. For example, printing inks for a particular type of printing process are generally the same, irrespective of their colour. So just have one assessment for conventional litho inks, another for digital inks. Don’t have one for magenta, one for cyan, etc.
Mistake 4 — Failure to follow the hierarchy of control measures
There is a hierarchy of control measures you need to follow, with elimination/substitution at the top of the list and PPE at the bottom. Often, people put effort into the middle and lower order control measures and never consider substitution. Where a substance is an inherent part of your process, substitution may be unrealistic. But there are plenty of solvents and cleaning substances in use where less hazardous alternatives are available.
To aid management commitment, I use a colour coding system of:
Mistake 5 — unrealistic use of personal protective equipment (PPE)
People on the shop floor need to “buy into” the practices around hazardous substances. One good way of defeating this is to require staff to wear PPE for everything. A substance may irritate to the eyes, but so is soap, and you don’t wear goggles when you wash your face. You want to make sure that people wear eye protection when handling a substance that has a serious risk of eye damage.
Datasheets tend to recommend PPE, even when there is no effect. What the supplier has to address in his datasheet is all possible uses of the substance. What you have to do is to assess the outcome based on what you do and take appropriate steps. The two may not be the same and your PPE requirements need to suit the latter.
With all risk control measures, the emphasis should be on effectiveness and implementation. If you avoid the above pitfalls, you can be well on the road to achieving good control of substances hazardous to health in your workplace.
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