Posted By Ian Bruce Hoping that someone out there can help me. One of the sites for which I am resposible is about to undergo a British Safety Council 5 Star audit. We've just recently had a Pre-Audit from the British Safety Council to help steer our action plan in the closing few weeks which was arguably worth the money! However, one of the recommendations from the pre-audit is troubling me. The auditor recommended that we undertake a COSHH impact assessment on how our chemical products are stored. To put this in perspective, we operate a residential setting where our chemicals are basically domestic cleaning products (Mr Muscle, Pledge, dishwasher tablets etc). Storage and use etc has been considered within the COSHH routines but the need for an imapct assessment escapes me! I'm also struggling to get my head around how I would record this. Does any one out there have a template document and/or advice that I could take benefit from?

Posted By Bob Shillabeer Your company must have money to waste. The types of chemicals you have stated are available to the general public with safety information on the pack. Tell them to go away, as long as you have done a valid COSHH assessment and implement the control measures having consiodered repalcing the substance with one that offers less risk you have met the legal requirment. If you meet the legal requirement why do more bevause if you can do more you ahve not met the legal requirement. Tell them to push off.

Posted By Bob Shillabeer No just having some lunch, a nice choc and orange cake to be precise, not bad just reading some posts as a way of passing the time (glad I only work three days a week would go crazy if it was five) It never ceases to amaze me how trivial and down right stupib how some peole sem to thinks that H&S law is hard to comply with.

Posted By Peter F. Ian, you seem like a very knowledgeable guy to me. chatered, sounds impressive. The items your talking about normally come with a data sheet that states non-hazardous, therefore they don't need a COSHH assessment so therefore no impact assessment.

Posted By Ron Hunter If the Data Sheet says non-hazardous, then why is there a Data Sheet?! Ian, no disrespect intended to the British Safety Council, however this is no doubt an item on their Checklists. One could wonder at the depth of COSHH knowledge of the person who made the recommendation. Legal gobbledegook aside, perhaps look at vulnerable groups (children?) the quantities and sizes of containers etc. where and how stored, compatability of products (not mixing acids and alkalis) that sort of thing. Otherwise, I can't see anything beyond instructions for safe use - as written on the containers!

Posted By Jay Joshi In my view, a COSHH Assessment is not about assessing a substance/chemical on its own, but its entire chain of activities in its "use", i.e storage, handling, disposal (if applicable) etc. I have not come across the term "COSHH Impact Assessment" as storage from a "hazardous to health" perspective is covered by a COSHH Assessment and not a COSHH Impact Assessment. The term, COSHH Impact Assessment is probably being used in the context of a checklist that the BSC 5-Star Audit system uses. Unfortunately, you will have to put up with whatever is required as there is no independent accreditation of such audit systems.

Posted By Adam Worth Here's a crazy aside. I search google for the term "COSHH Impact Assessment" as I was feeling a bit confused The only two results are this thread!!!

Posted By Toe Being the inquisitive sort, I dug out the requirements of the BSC Five Star Audit from a previous audit and section 2.9 is the part pertaining to Hazardous Substance Control, and it does not mention anything about COSHH Impact Assessment. What it does asks for is: COSHH Assessments, List of Substances, Training Records, Data Points. Don't know how old my audit specification document is, but it is possible that the Auditor may have got confused. Again if you want to score as high as is possible, I like the advice from Coshh Assessor above.

Posted By Chris Packham Read definition (e) of a substance dangerous to health in the COSHH Regulations. Just because a substance is not labelled as hazardous, i.e. has not had a risk phrase attached to it, does not mean that it is in someway exempt from COSHH. Studies have shown that one of the most common causes of occupational contact dermatitis is due to wet work, i.e. exposure to water. I am not aware that water has been allocated a risk phrase yet! Incidentally, you may not have a safety data sheet as there are no substances with risk phrases, but safety data sheets are for CHIP not COSHH. There is still a duty on the supplier under section 6-1 of the Health and Safety at Work etc. Act 1974 to provide the user with information such that he can use the product safely for the purpose for which it was supplied. Chris

Posted By Chris Packham Raymond I could not agree more with you. There are many recorded instances of domestic chemicals, that can normally be used safely, causing serious damage to health due to misuse. How many people have mixed bleach and floor cleaner together? It happens and the result is a reaction releasing chlorine. There have been fatalities due to this. This is why on that container of bleach it says: "Do not mix with any other chemical" or words to that effect - but who reads the label? Chris

Posted By Ian Bruce Thanks to all of you who provided reasoned comment... and Peter F, I know who you are!!! Seriously, my argument has been that the COSHH assessments we have carried out are more than suitable and sufficient as we have considered potential for mixing, storage and spillage etc and have considered the vulnerability of those likely to come into contact with the products - in my mind we've done everything we need to have done. The 5 Star spec does not mention impact assessment as correctly mentioned in the postings so I think it was just the auditor confusing the message. I'll stand by my guns when the 5 star audit happens and take comfort in the fact that others have a similar take to my own. Thanks again.

Posted By Bob Shillabeer Appologies to those who felt insulted by my comments from yesterday, it was not directed at any one individual just a general comment. I have been working in the H&S field now for some thirty years and it never fails me to see that some individuals always look on the complicated side of things. H&S is quite easy to understand and most legal requiremenmts are very much the same. COSHH is no different. If the sunstance is harmful, how is it harmful and what needs to be done to control that danger, it's as simple as that. Remember the hierarchy avoid it if possible, identify the true risks and control them, and then go into PPE. Remember PPE is a last resort. But with chemicals in common use the hard work has already been done and that can lead to a false idea that because the controls are used it is compliant, can a safer substance do the job?? In this case the chemicals quoted are on public sale so generally fall into a lower risk category anyway.

Posted By Stuff4blokes Bob, I cannot agree with your assertion that publicly available substances are lower risk. I refer you to Chris Packham's response. True, when used as directed these may well be less risky than industrial products but most bathrooms, kitchen cupboards and garden sheds have a collection of nasties that can cause significant harm.