Hello

A bit of advice please. We have a school that has a COSHH file for cleaning activities such as cleaning floors etc. The COSHH file contains manufacturer data sheets and a risk assessment produced by the cleaning supervisor. The RA is a bog standard one that describes the activity and what control measures are in place i.e. need to wear gloves and cordon off area etc. Is this sufficient? I have been informed a COSHH control sheet needs to be in place as well that pulls off info from the data sheet. Is this a legal requirement and or good practice?

Copying information from the safety data sheet and labelling it "COSHH" is neither a legal requirement nor good practice. It is however very common.

You just need the risk assessment to adequately cover everything that is relevant, and to provide information and training to the people doing the task.  What format you do this in is up to you.

Forget the safety data sheet. There are many hundreds of chemicals that can be hazardous. particularly when used and if protection is by gloves. Consider what the currect ACoP for COSHH states:

Paragraph 10 - Employers should regard a substance as hazardous to health if it is hazardous in the form in which it may occur in the work activity. A substance hazardous to health need not be just a chemical compound, it can also include mixtures of compounds, micro-organisms or natural materials, such as flour, stone or wood dust.

It isn't what you buy, it is what you use and in particular how you use it that is important. There has been at least one fatality subject of a prosecution where a worker without adequate training who gassed himself by mixing two cleaning chemicals together.

Chris

If ever there was a set of regulations that need a complete overhaul and re-write, its CoSHH. It's overly complicated and a nightmare for smaller employers to have to deal with - to treat all hazardous substance users the same, irrespective of product/use/volume etc is just ridiculous.

In addition few employees (especially those who have ESL) will read either the MSDS or CoSHH RA - they might possibly read the label on the container once and then ignore everything...

Oxford

What would you propose to do to COSHH whilst at the same time retaining confidence that we have adequately transposed EC Directives.

There's plenty of guidance to enable people to keep it simple.

There's plenty of people who manage to find ways of complicating compliance.

Personally, I have thought that we could have implemented most EC Directives via the general duties under teh HSWA, with supporting Approved Codes of Practice and guidance but that's not the route that successive UK Governments chose to follow.