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August 6, 2009

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Michelle Twigg looks at the current strategic standpoint taken by the Health and Safety Executive, and asks whether it will adequately address emerging chemical risks in the workplace and lead to significant improvements in worker health.

The European Agency for Safety and Health at Work recently published a report claiming that workplace illness and fatalities resulting from exposure to hazardous substances are on the increase, with numbers set to rise further over the coming years. The report not only identified new and emerging risks to health but pointed out that key systematic failings in chemical management procedures are leading to these exposures.

The report went on to say: “The number of work-related diseases is considerably higher than the number of accidents. In particular, work-related cancers are among the main causes — if not the main one — of deaths in Europe related to working conditions.”

When considering the UK experience, it is interesting that when looking at progress against government targets identified in Revitalising Health and Safety, improvement in the rate of incidents resulting in physical injury is actually on track and will probably be met by 2010. However, the same cannot be said of occupational illness and days lost per worker.

Regulatory reform

In recent years, efforts to harmonise standards on the management and use of chemicals across Europe, through the Chemical Agents Directive, has prompted the UK to redefine a number of personal exposure limits related to the control of personal exposure to hazardous substances, for both chemical and physical agents. For example, the updated COSHH Regulations make reference to Workplace Exposure Limits (WELs), which have replaced the Maximum Exposure Limit (MEL) and Occupational Exposure Standard (OES). These changes have made COSHH simpler, as the emphasis is now on managing all substances, and using good hygiene practices to keep exposures low.

Other legislative changes have been introduced to make the COSHH Regulations easier to manage. This year will see a shift to the Globally Harmonised System (GHS) for the classification of chemicals. This has resulted in changes to the Chemicals (Hazard Information and Packaging) Regulations. The implementation of the Registration, Evaluation and Authorisation of Chemicals (REACH) regime is another move aimed at safeguarding the users of chemicals, through, among other measures, the harmonisation of Safety Data Sheets.

Further efforts to assist employers to understand and carry out their duties under COSHH have been made by simplifying HSE guidance. In December last year the HSE issued its third simplification report, ‘Reducing paperwork, not protection’, a document that gives a progress report on the HSE’s work to reduce unnecessary administrative burdens caused by health and safety legislation. It also demonstrated how the HSE is meeting the Government’s wider ‘better regulation’ agenda. In line with this, several pieces of health and safety legislation have been under review, with the HSE looking to improve guidance provided for employers so that administrative burdens and cost can be kept to a minimum, and compliance with legislation can become a more efficient and sustainable process.

In order to address the high cost of risk assessment, as estimated by the cross-government Administrative Burden Measurement Exercise (ABME), and to help employers understand their duties under COSHH, the HSE has focused its efforts on making chemicals-management guidance more accessible and easier to understand. The HSE has already reduced the amount of guidance in this area from 130 items to 30 but other areas for improvement include:

  • Revising the HSE’s COSHH Web pages to make them more accessible and easier to use, focusing on key ‘how to’ information for employers undertaking risk assessments of substances at their workplaces;
  • Redesigning the COSHH Essentials website — an interactive tool that helps users conduct an in-depth risk assessment — in order to bring it up to date, integrate it within the COSHH Web pages, and make it more user-friendly. Options for taking this forward were consulted on in late 2008. The aim is to have the selected option in place by the middle of this year; and
  • Rewriting the leaflet ‘COSHH: A brief guide to the Regulations’, which aims to help employers meet their specific duties under COSHH, by presenting the information in a clearer, more user-friendly format.

Meeting the challenge

The HSE’s decision to develop a new strategy3 has been prompted by many factors. One goal identified in it is to “specifically target key health issues and to identify and work with those bodies best placed to bring about a reduction in the number of cases of work-related ill health”. The document goes on to state that “setting targets and implementing actions is complex”, adding: “The pressure is on to find ways of beginning again the process of improvement.”

To focus finite resources in the battle to reduce occupational disease, the HSE introduced the Disease Reduction Programme (DRP), which targets three significant areas of risk: skin disease; cancer; and respiratory disease.

However, in a report entitled ‘The lack of investigation 2001-2007’, trade union Unite accused the HSE of failing in its role as enforcer and overseer of social justice, through insufficient investigation following reports made by employers under RIDDOR.

The union claimed that a lack of investigation ultimately leads to a lack of enforcement following serious lapses in health and safety. The figures would seem to suggest that incidents relating to hazardous substances are not investigated as much as those relating to physical safety issues. Although, disappointingly, the research fails to show the HSE response to reports of disease, the figures quoted nevertheless show that 459 major injuries resulting from contact with a harmful substance were reported in 2006/07, with 90 investigated — an investigation rate of just 20 per cent.

The HSE strategy consultation document concluded: “Significant advances have been made in pressing down on the causes of safety failures using existing tools and methods. But leverage on health issues will require new methods. Among all of our challenges, occupational health demands a more strategic and partnership-based approach.”


Occupational ill-health trends in Great Britain reflect Europe-wide patterns identified by the European Agency for Safety and Health at Work, i.e. illness and fatalities are on the increase. The situation is likely to become more pronounced in the coming years, owing to a range of new and emerging chemical risks, which indicate that the need to manage hazardous substances in the workplace is becoming more challenging. In particular, it is recognised that more needs to be done in terms of preventing occupational illnesses caused through dermal exposure, as well as focusing on airborne contaminants.

The HSE has implemented strategies that focus its limited resources on how best to tackle key areas of occupational illness, but a renewed vigour is required via the provision of advice and guidance for those sectors at greater risk — construction and waste treatment, as well as SMEs — while a tougher enforcement approach needs to be taken when employers fail to manage the risks adequately. However, it must not be overlooked that employers are ultimately responsible for managing health risks in their workplace, as the HSE strategy is quick to underline. Evidence suggests that good efforts have been made to embed these strategies — particularly in terms of chemical management — with supporting guidance to meet these needs.

The way forward is for the HSE to deliver these strategies as they have committed to do, giving employers the means to manage risks sensibly. Employers should continually review their chemical management systems to ensure they are sufficiently robust to cope with constant changes and technological evolution. Employers should also engage their workforce in making improvements and maintaining high levels of performance in this area.     


1    HSE (2008): Health and Safety Statistics 2007/08, see
2    HSE (2008): Achieving the Revitalising Health and Safety Targets: Statistical Progress Report, see
3    HSE (2008): The Health and Safety of Great Britain, Be Part of the Solution,

Michelle Twigg is a consultant at Sypol.

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