Needs to comply with reg 6 of CoSHH

http://www.legislation.g...2/2677/regulation/6/made

As long as it does that....
If you need more guidance... http://www.hse.gov.uk/pubns/priced/hsg97.pdf

Invictus,

If the materials and task are very low risk then the COSHH assessment should be a very quick thing to do, so I recommend recording the assessment in the same way as you usually do.

Use the same document as you use for other chemicals, and explain why you think the task is low risk - e.g. justify if there is no need for PPE or if gloves are worn then state the grade of gloves to be worn etc etc

You need to show that
- you have tried to foresee all the possible risks
- you have protected against those risks
- the cleaners receive adequate training in the use of the materials.

If an accident happens or someone gets a nasty rash then at least you can show you did an assessment, and what happened was possibly not foreseen or the cleaner did not follow the training he received.

You don't want the investigation to show that there was an obvious risk that was not controlled e.g. from splashing or from slippy floor etc etc

COSHH considerations can very often be captured within the general (MHSWR Reg3) task or activity risk assessment. No absolute need for a separate document for "COSHH" purposes.

Comment from the auditor may seem pathetic, but if that's what the Employer's Procedure says............

It might do if a spill of a floor wiping doesn't dry/evaporate quickly e.g. the cleaning chemical is thicker than water and if the chemical is hydrophilic it will slow down the evaporation :0)

I wrote the procedure and this is what we were using, I would agree if they had a different form but it was the way it had been done.

Ah yes, I do accept that creating a slippy floor isn't an exposure hazard - note I did do a :o)



As for flammability, yes Reg 5(1)(b) rules out a COSHH assessment "where the substance is hazardous to health solely by virtue of its .... flammable properties"

But I don't know such a substance. Anything I know that is flammable also has other health hazards :o))

My COSHH assessments include a review of the content of an MSDS and the CLP statements and phrases. H-statements H203 - H272 deal with flammability..... and I won't ignore these when deciding on handling precautions :o)

Striclty speaking Oxygen isn't flammable!

I'm not sure of this - Regulation 6 of the COSHH 2002, is prescriptive. The requirement (part 2)states 'shall' include considerations of, etc......

There is no such thing as ‘standard’ COSHH risk assessment form. Risk assessment as we all agree is a process that needs to be carried out and the findings from this process recorded in some suitable format. This can be done using a proforma. The sort of proforma varies with the sort processes involved. When I was working in labs we could deal with a whole range of substances in a range of scenarios. This required a long and detailed form (10 sides). If you are looking at a simple routine task, such as cleaning using products from a reputable supplier, the risk assessment process should be bit more straight forward and it would probably make sense to incorporate the COSHH bit of the risk assessment into a more general risk assessment form.
What I am curious about is what form the auditor was suggesting you use?
Was it an already existing COSHH form for some other (more complicated) process which means that as an auditor he is more interested in neatness and consistency than effectiveness (a common affliction of auditors)?
Was it another he had seen and believed was more suitable because it was longer (another common affliction)?
Or was it some hypothetical form that does not really exist but was just an excuse for the auditor to find something wrong so he can flex his compliance muscles and justify his fees?

When scrutinising safety systems, I expect to see a relevant 'risk assessment record' which may include, or cross-refer to, separate specialist assessment findings such as COSHH.

I also expect to see how the significant findings are then communicated to workers / users. And this may look very different from the assessment record (in line with reg 6) which is often way too complex for 'clear and understandable' user information. The 'answer' ie. 'what to do' - is far more important than the 'analysis'.

For simple substances, of limited potential, this could all be one document; the HSE example does not conform to Reg 6 but professes to be an assessment, and I could imagine would be pinned to an office wall as 'user information'. All-in-one assessment with user information proforma can work, with careful design, but may not be through enough for ALL situations, whilst OTT for many.

Unless an organisation has specified in it's own procedures that a certain proforma MUST be used, an auditor is on thin ice with the claim made.
But that's auditing for you . .

Just to add to my posting, I have just had to refer to the definitive guide on skin sensitisers (Anton C. de Groot, Patch Testing, 3rd edition) which lists 4350 substances known to dermatologists as sensitisers and for which a patch testing protocol exists. How many of these will have been assigned H317 and thus appear on the safety data sheet?

Chris

No such thing as a standard form for COSHH assessments and an auditor has no right to penalise you if you haven't used a specific template unless of course you haven't used the template that your company normally uses. An auditor is supposed to audit you to ensure you are doing what your system says you should do, not what he / she thinks you should do.

As for conducting a COSHH assessment, it is as important to include the process conditions eg het pressure etc as it is to include the properties of the chemical

Oh dear "Sevron" - this company posts out of date (M)SDS information cant update it correctly and last time I was involved speaking to one of its representatives.... OK I will admit a wholly personal perspective but they do not even conduct cursory checks (including the dreaded Google, other browser are available) to validate that the (M)SDS comes from the supplier annotated on page 1 or quoted by their client.