We are a utility company in UK and have a few dangerous chemicals, but mainly low risk items, cleaning products, WD40 (spray cans) etc.

For the "dangerous" chemicals we have a 2-3 page, fairly detailed CoSHH assessments (based on MSDS data, actual use and the HSE CoSHH essential on-line assessment form.

For the less hazardous substances, we have a simplified matrix for our employees that identifies the chemical + hazard symbols + controls (PPE, ventilation etc.) and this is backed up with a generic chemical awareness leaflet (general first aid / fire / storage / handling requirements).

Last week we sent our CoSHH assessors on a refresher course (CIEH level 2) - they've come back and stated that
1. We cannot have 2 systems - every hazardous substance needs a full assessment completed.
2. The full assessment form requires us to modified to include / add
 Potential effects – acute or chronic, superficial or systemic
 Routes of entry
 Concentration in air
 Attitude and behaviour of users
 Existing Health issues of workers

Finally the queries:
1. Does everyone agree that every hazardous substance need a full assessment?
2. What do we put into the boxes for "concentration in air" & "attitude and behaviour of users" & "existing health issues of workers" when we use a quick squirt of WD40 to release a rusted nut/bolt? Does anyone else do this?

The latter 2 also implies to me that we need to do a separate CoSHH assessment for every employee using every chemical - I deem this impractical (+ illegal to divulge personal medical conditions on a generic form going out to each employee in a gang)

Each process involving hazardous substances requires a risk assessment. So one assessment might cover more than one substance or the same substance could be involved in several different assessments if it is being used in different ways.

If you consult the latest edition of the ACoP for COSHH you will see that the risk assessment should be based on the task rather than on the chemical. It also draws attention to the fact that the hazard that you need to assess for is the one that occurs when the chemical is actually used. And COSHH has always stated that any substance may become a hazard to health due to its use (see regulation 2(1)(e).
So the emphasis has to be on the task, then on the exposure and to what and the hazard it represents. Perhaps concentrating on just the hazard is why wet work (i.e. exposure to water or occlusion from glove use) is still the most common cause of occupational irritant contact dermatitis.
Chris

Hi Evans,

I previously worked for a company using 300-350 different chemicals in over 800 applications. Our system was simple, all chemicals were vetted prior to use (pre-assessment), this would then determine the level of assessment that was required. You may even deem the pre assessment enough depending on the risk.

Also I used process risk assessments which covered upto 20 substances. Your assessing exposure and its quantity, if you do this and apply the "Principles of Good Practise" from the COSHH ACoP - you will be on the right path.

PM me your email and I will dig out some samples for you.