Rank: Forum user 
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The company I am currently working for recently received an improvement notice from the HSE. I am ok with most of the notice, but am not really sure how we should answer one of the points,this being:
Please let me know how you intend to risk assess all of your hazardous substances and process by XXXDATE.
Have any of you come across this before and can you advise me of what to say?
In essence the company has hired me in to do the COSHH and risk assessments, but I don't really know what the HSE is likely to be expecting by way of an answer.
Also it will take considerably longer to do than the time we have left, so is it in order to ask for an extension on the time we have i.e about another 1-2 months? The company were originally given 2 months to complete the work but it has taken a month for them to get me in place and I think there could easily be 3 months work to do it justice, with me working on it full time.
Any comments please?
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Rank: Super forum user
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HSE are normally pretty good if you can give them specific reasoning for the request to extend the time frame. But you or the company (usually whoever they have written to name wise) will need to request.
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Rank: Super forum user
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smandeir wrote: Please let me know how you intend to risk assess all of your hazardous substances and process by XXXDATE.
It doesn't say 'Complete all risk assessments by XXXDATE'
They want to know what you plan to do.
So, before that date just tell them HOW you will do this, i.e.
consultant hired - date
plan completed - expected date
RA's expected to be complete - expected date.
John
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Rank: Super forum user 
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You could also remind the author of the Notice that Regulation 6 requires 'assessment of the risk to health created by work involving substances hazardous to health', and not that we "risk assess all of our hazardous substances" (whatever that means).
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Rank: Super forum user
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Are you sure its an improvement notice and not just a letter? Sounds like no notice I have ever seen. An improvement notice has to be very clear in what action you need to undertake to comply with the regulation/section it says you are in breach of.
If the wording you have quoted is actually on an improvement notice I would be very surprised if it was valid.
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Rank: Super forum user
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If smandeir comes back to us he can tell us what the notice actually says.
As you imply Brian, a notice will say what needs to be done, why, and by when, and the time period within which to take the remedial action will be at least 21 days.
In this case writing a whole pile of RA's is expected to take more than 21 days so maybe the inspector has just asked for a plan to be put in place in that timeframe - to 'take remedial action' but not to complete it?
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Rank: Forum user
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I think the man from the HSE is asking you to set out your strategy: I would look to go back to basic principles and the hierarchy of controls such as:
Elimination (look at the process)
Avoidance of risk e.g. subcontract to a specialist
Substitution e.g. use alternative
If non of the above:
Info, instruct and training
Apply management controls such as written procedures
PPE
Monitoring
etc.
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Rank: Forum user
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Thanks to all of you who have replied.
Yes it is definitely an improvement notice and it does specify the actual regulations and sections we are in breach of.
I have been told that it is likely we will be given an extension as there is a lot of work to do.
I was more concerned with answering the 'how we go about it' bit, but a couple of you have already confirmed what I thought about considering the hierarchy of controls, information, instruction and training etc.
So thanks again,
I feel happier now :0)
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