Rank: Forum user
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The Company I work for currently use SYPOL to produce COSHH assessments and was wondering if anybody use a different system or are aware of a systems that does the same thing. I have also looked at the HSE COSHH Risk Assessment documents but feel these do not meet the requirements of the regulations.
thanks in advance
Paul
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Rank: Super forum user
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paul reynolds wrote: I have also looked at the HSE COSHH Risk Assessment documents but feel these do not meet the requirements of the regulations.
Paul
That's a worrying statement!
We make our own! COSHH assessments as it can be a complex area and you need to understand the process and how contact occurs with intermediates and bi products etc
It all depends on what you are doing.
If you have one chemical and one application then it can be much easier to assess.
I have looked at the sypol system where they assess for you and it certainly had applications for some of our areas (engineering for example)
However as we have a few chemists on site and the cost was high it was not worth it for us.
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Rank: Super forum user
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If you genuinely need external assistance on COSHH, there are many dozens of competent hygienists listed on the BOHS directory of consultants. They are experts in hazardous substance exposure.
http://www.bohs.org/consultants-directory/
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Rank: Super forum user
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Im not too sure what the "SYPOL" system is that you use, but if they visit your workplace, watch the task being done, see the potential routes of exposure, take into account the PPE and engineering controls you are using, know the quantity and volumes of material you use, the dustiness or volatility of the material, how its applied or mixed etc. then it may be that the COSHH's they write for you are sufficient.
However if all they do is write a generic COSHH based on you giving them only the name of the material you use, they use standard statements and never see the work place, understand the process / your controls I doubt they would be sufficient.
Echo the comments below, no better solution than doing them yourself, a safety rep maybe, or if you cant train someone up an external consultant (such as those registered with the BOHS)
Des
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Rank: Super forum user
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The COSHH essentials tool does have limitations. So does Sypol. There is no substitute for undertaking & reviewing a risk assessment first hand, in real-time.
An over-dependency on tools and systems can also obscure the actual requirements of the Regs.and diminish, as opposed to adding, value. (These systems don't come cheap either).
We're supposed to routinely review what we do to see if safer alternatives and technological advances for risk reduction have become available. A 'heads down, blinkers on' approach as encouraged by some commercial systems can lead to undue focus on screen grabs and bits of paper, and does not foster that essential approach to risk reduction and legal compliance.
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Rank: Super forum user
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When carrying out a COSHH risk assessment, particularly where skin exposure is a concern, one of the major problems is identifying the real chemical hazard. The safety data sheet is only one item of information and with severe limitations. Even the COSHH ACoP recognises this (read paragraph 13). Furthermore, we usually purchase chemicals to use them. In the process they can change, i.e. oxidise, become contaminated, react with another chemical, etc. The safety data sheet does not cover this. In my experience the only way to identify the true hazard is to study what is happening in reality when a task is carried out. In other words, attempting to carry out a risk assessment for COSHH without a visit to study the actual task runs an extremely high risk of being invalid, potentially either overstating the risk (causing excessive expenditure in unnecessary controls) or understating the risk (putting the health of the workforce at risk). If anyone is interested I can quote examples (but off the forum).
Computer based systems may be excellent at recording the findings of risk assessments and ensuring regular follow up, but not, in my view, as a method of conducting a risk assessment.
Incidentally, have you considered section 6-1 of the Health and Safety at Work etc. Act 1974? This places a duty on the supplier to provide information on the safe use of their product for the purpose for which it has been supplied. This is far more than is required for the safety data sheet. How many of your suppliers provide you with information to meet section 6-1?
Chris
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Rank: Super forum user
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Got to agree with Chris here. Computer based systems are useful for data input, storage and retrieval only. You still have to go out and do the assessment and that assessment has to be process based. Take water as an example. If you were to conduct a COSHH assessment on a process that used water then you would have to consider the following.
Temperature - is the water in the form of live steam, water or ice and what measures would be required to prevent prolonged skin contact - burns (steam), dermatitis (water), frostbite (ice).
If the process took place in a water bath or enclosed vessels you may need to consider breathing apparatus if you needed access.
If the process involved elevated pressures then you would have other risks such as high pressure injection etc.
Water is only one example and many would argue that they wouldn't COSHH assess water but there are thousands of substances that are used and many COSHH assessments consider the substance only without considering how the process affects the nature of the substance.
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Rank: Forum user
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used to use sypol myself and found it overly generic and quite expensive to be honest.
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Rank: Super forum user
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pl53
Interesting that you mention water. As it happens several studies have identified wet work, i.e. contact with water, as one of the most common causes of occupational irritant contact dermatitis. At a EU meeting in Dresden (on policies to reduce the incidence of dermatitis among hairdressers) we had a discussion on water. The conclusion among the dermatologists was that they would classify water as a skin irritant.
In Germany their Technical Regulation on Hazardous Substances (TRGS) no. 401 stipulates that where exposure to water or wet work is for more than two hours in total in any eight hour shift this must be considered a situation hazardous to the skin requiring action.
Actually, if you look at regulation 2(1) in COSHH on the definition of a hazardous substance, paragraph (e) reads: "which, not being a substance falling within sub-paragraphs (a) to (d), because of its chemical or toxicological properties and the way it is used or is present at the workplace creates a risk to healthâ. In other words, any substance can become a substance hazardous to health under specific circumstances. So any COSHH assessment needs to look at all substances involved in a particular activity to identify whether this condition would apply.
Chris
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Rank: Forum user
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Depending on the substance and talking in very general terms (trying to hedge my bets!) it can take between half an hour and three hours to complete a COSHH assessment depending on its toxicity and how it is used, the control measures already in place. This takes into account researching the substance, and talking to the managers and users.
Going by this would an average charge of £60 per assessment be reasonable?
Bear in mind some contributors on this board wouldn't get out of bed for less than £120 an hour and we don't want to cheapen the task.
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Rank: Super forum user
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Geoff
I can see where you are coming from. However, my experience (and bear in mind that I am primarily concerned only with skin exposure) is that the time taken to risk assess a particular task can vary enormously. Many can be done in just a vew minutes, others (as you say) may take several hours. In some cases some research into the effects of the chemical in use and resultant hazards may require quite a lot of research. So I have tended to shy away from a figure per assesement but rely more on a daily rate.
Also, for my clients, what they are really looking for is not the risk assessment. This only tells them if there is an actual, or potential, problem. What they expect from me is advice on the 'risk management' aspect, e.g. can we use a less harmful substance, how can we modify the process to eliminate the exposure, what sort of gloves should be used and how frequently should they be changed, etc. In other words, they are looking for answers to the problems that often they did not know that they had, although they may have suspected that this was the case.
Again, the risk management aspect may be extremely simple, or it may require quite a lot of research to find the best solution. In one case it involved considerable financial expenditure on the client's part in remodelling their process, having first identified how this could be done, who could supply the required equipment, etc. (It did subsequently pay for itself in a reduction in operating costs - somewhat to his surprise).
So again, trying to determine a price per assessment/task is a route I have not tended to take.
Hope this is of some help.
Chris
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Rank: Super forum user
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There are some very good comments herein and it goes to show what is needed - but sometimes its a 'never mind the quality feel the width' situation as many employers want the easy route and are satisfied with a set of risk assessment where they should have a management system and as Chris P has pointed out already; a quality RA etc [its the etc that is usually the hard area] may even bring with it financial benefits as well as day to day health benefits
The problem I find is that people do not understand just what is required with regards to management; especially managing COSHH and the only time that 'depth of effort' may pay back is in a court many years later but people only see today's budgets and do not plan for tomorrows budgets
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Rank: Forum user
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Thanks Chris & Bob
The reality of it is if we tried to price a COSHH assessment for the time it takes, some would be in the region of hundreds of pounds.
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