Rank: Forum user 
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Dear All
I have been told today that it is a Co. Policy not to use a certain COSHH item across different client contracts - except when the customer requests for it to be used.
I have asked a number of questions about this;
Can I see this in writing?
Can I see the RA that supports this policy decision?
What happens if there is an incident - how do we justify its use at one location but not another?
Has anyone else come across a situation where a Co. Policy does not cover all the bases?
Cheers
DHM
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Rank: Forum user 
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I supose it would be difficult to have a policy on the use of a specific substance, as some sites may be more set up for using it than others perhaps? But this is not the job of a policy - the CoSHH assessment should detail these reasons and justifications.
What CoSHH item is it? and what's it used for?
It really depends on the substance, its intended use and the risks associated with it - (should be in the RA)
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Rank: Super forum user 
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As described, it does "cover all the bases" It covers the base of when the customer does not specify (in which case, don't use the substance), and it covers the base of when the customer does specify (in which case you may use that substance). What base do you think it doesn't cover?
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Rank: Forum user
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It is the use of bleach for commercial cleaning purposes. I don't believe there is a written policy, more like 'oh it's ok' we will take the risk of using it as the client has requested it. I have yet to see a COSHH assessment for it!
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Rank: Super forum user 
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When I worked as a cleaner before getting into health and safety I was cleaning student accommodation, and the area I worked was one of 2 areas where bleach could be used. I undertook a COSHH Assessment and method statement specific to the areas bleach was allowed to be used (They were mould heaven due to some students not opening their bedroom windows for almost a year). If it is being used have an assessment for that client/area perhaps?
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Rank: Super forum user
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I think the problem is here is that people tend to see COSHH risk assessments as substance specific. So you have a COSHH assessment for bleach-end of.
Except that is wrong. The risk assessment should be for the process. So it might be possible to have risk assessment allowing the use of bleach to clean toilets and another that says in should not be used on work surfaces.
The policy should not be process specific, as the person owning the policy might not be aware of what the job entails. The policy should be saying things like:
• Always Risk Assess the job including any requirements under COSHH .
• Use competent people to assess the risk.
• Check the SDS but don’t simply rely on that. Look at the specific job
• Make sure that the findings of the assessment are communicated to the staff doing the work in a format that they can understand and follow
• review the assessment periodically to make sure that it is an assessment of the job you are actually doing, not what you say you are doing
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Rank: Super forum user
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I would question the concept of a ‘COSHH substance’. I you consider the definitions of what constitutes a hazardous substance under COSHH you will come across the following:
“(e) 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 health” - COSHH Regulation 2 (1) Interpretation
In other words, as AK has stated in his posting, any substance, even water, can become a hazardous substance according to COSHH, depending upon how it is used.
The key words here are ‘how it is used’. We generally purchase chemicals to use them. In the process we may change their properties. So the hazard of the substance as used can be very different to the substance as purchased. The sixth ACoP for COSHH recognises this.
“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.- OSHH ACoP (6th edition), para. 10”
“All the substances hazardous to health (including biological agents and simple asphyxiants) arising from the work (use, produced, synthesised, created as waste or by-products, or released from processes or during accidents, incidents and emergencies);
Work done by sub-contractors, at the workplace, that may expose employees to substances hazardous to health.” - COSHH ACoP, para. 57
Any risk assessment has to start with what you do to the chemical(s) and the resultant hazard, not what is on the safety data sheet. Unless you do this there is a very real possibility that your risk assessment will not reflect the true risk. Determining the real risk particularly where we are considering skin exposure is often the most difficult part of the risk assessment. Note that it can change during the actual task or, where the chemical is used repeatedly for the same task, from task to task.
Chris
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Rank: Super forum user 
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As usual AK is bang on the money here. The ACOP to the COSHH regs will tell you that COSHH is about work, not about the substance. There are a number of good reasons for this; focusing on the substance means that you may well omit processes that produce hazardous substances from your assessment; a hunk of mahogany does not require assessment under COSHH, work that produces mahogany dust might well. Another is that some quite common-place and harmless substances can, under the right conditions, need to be treated as a hazardous substance. As a real world example I had to respond to a case of irritant dermatitis caused by water; and extreme case of this condition would be trench foot. So is water a hazardous substance? No, but the specific circumstances of the work being carried out meant that exposure to water brought about an identified condition.
It's not about the stuff, it's about the job,
John
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Rank: Super forum user
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I love been called AK. It makes feel I am part of the gang!
Don't call me Andy though!
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Rank: Super forum user
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John
Interesting you mention your experience with water. As it happens wet work, i.e. exposure to water is actually the most common cause of occupational irritant contact dermatitis. In Germany exposure to water for more than 2 hours in total in any 8 hour shift is considered a significant skin hazard requiring special measures. And wearing occlusive gloves is equivalent to (actually recent studies show worse than) having one's hands in contact with water. If you want more info on this drop me a PM with your e-mail address.
Chris
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Rank: Super forum user
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Thanks Chris. As it happens I asked a question about the dermatitis on this forum; it must have been about five years or so ago, and you made some very good contributions to the discussion. It was in a care home, staff were getting wet feet and were not able to get them dry for prolonged periods, in the end we gave them oversized wellies so they could put their feet in without taking their shoes off, and in the longer term we redesigned the shower cubicles,
John
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