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JasonMcQueen  
#1 Posted : 07 August 2017 14:51:39(UTC)
Rank: Forum user
JasonMcQueen

Afternoon all, I was wondering if anyone has any examples of what they'd consider to be a 'good COSHH' assessment'?

Most assessments that I come across are little more than a rehash of the MSDS and do nothing to actually assess risk. Just curious as to what others do and how etc.

A Kurdziel  
#2 Posted : 07 August 2017 15:03:48(UTC)
Rank: Super forum user
A Kurdziel

 Yes I agree entirely but there is not such thing as a one size fits all COSHH risk assessment. I work in a university and we have several different sorts of COSHH risk assessment. The proforma that I expect lab-users to utilise is very different from those that cleaning staff need which are different from that which field workers might need.

I am in the process of going thought the various types of COSHH proformas and deciding which is the best one for each role in the Uni.

What do you want your COSHH form for?

JasonMcQueen  
#3 Posted : 07 August 2017 15:42:00(UTC)
Rank: Forum user
JasonMcQueen

It's interesting that you use a different form for a different environments, how are they differentiated between each other as you'd assume on the face of it that the same set of circumstances are being applied in each case (nature of chemical, method of use etc..)

We're a food manufacturer and our application for chemical use includes ingredients/flavourings, engineering substances, cleaning, production aids etc.

I suppose I'm just trying to look at it differently and see what others do that actually DOES constitute an assessment rather than cut/paste from MSDS.

A Kurdziel  
#4 Posted : 07 August 2017 16:53:32(UTC)
Rank: Super forum user
A Kurdziel

The issues are

  1. the environment: a lab is (or it should) the most controlled environment that you can get so I would expect that they aim for controlling the risks at the highest point of the hierarchy of controls. So they would not be relying on PPE but other controls such as LEV etc.  Furthermore I would expect detailed knowledge and understanding from the users in such an environment. In our labs SDS is not that much use since they synthesise their own reagents in some cases.
  2.  Out in the field then there is less control and they tend towards PPE.  They rely on SDS but can also come across environmental samples which don’t have a SDS  and we again rely on user’s own knowledge
  3. Cleaners buy  stuff which comes with an SDS and they use it in accordance with manufacturer’s instructions.

The COSHH from I have drafted for labs now runs to 10 pages. I am looking at how I can cut it back a bit

chris.packham  
#5 Posted : 07 August 2017 20:50:57(UTC)
Rank: Super forum user
chris.packham

Safety data sheets will generally not provide you with the information you need for a COSHH risk assessment. In the first place the safety data sheet will only contain a limited amount of information on each constituent of the chemical listed. There are literally thousands of chemicals that may not appear on the safety data sheet as they have never been assigned a hazard statement, but that if exposure occurs may well result in damage to health. Water (wet work) is the most common cause of occupational contact dermatitis. When did you last see water on a safety data sheet?

Furthermore, we generally purchase chemicals to use for a particular purpose. In using them we may well change their properties (contamination, reaction, mixing, etc.) and thereby also the hazard. Your risk assessment needs to be based on the real hazard that exists when one or more chemicals are used for a particular task. The same chemical may present different hazards when used for different tasks.

So for a risk assessment for COSHH start with the task, what happens when it is carried out, what chemicals are used and how are they used. From this you can assess the hazard and exposure and determine the risk that these present in terms of damage to health. This will allow you to decide whether the risk is acceptable or whether you need to do more to eliminate or reduce exposure.

Chris

Hsquared14  
#6 Posted : 08 August 2017 10:36:22(UTC)
Rank: Forum user
Hsquared14

I would start with the COSHH acop and look at the factors it tells you to consider in your assessments and then work out how you are going to record that information and where you are going to get it from.  It amazes me that people will go off and do a COSHH assessment without even looking at the acop to find out what the regulations actually want you to do.  I agree that you need to tailor what information you collect and record and that will influence how you arrive at your risk decision and how you express that risk but you do at least need to start with the acop.

Ron Hunter  
#7 Posted : 08 August 2017 11:44:09(UTC)
Rank: Super forum user
Ron Hunter

Originally Posted by: A Kurdziel Go to Quoted Post

 Yes I agree entirely but there is not such thing as a one size fits all COSHH risk assessment. I work in a university and we have several different sorts of COSHH risk assessment. The proforma that I expect lab-users to utilise is very different from those that cleaning staff need which are different from that which field workers might need.

I am in the process of going thought the various types of COSHH proformas and deciding which is the best one for each role in the Uni.

What do you want your COSHH form for

Why would cleaners or field workers need to see a COSHH Assessment? We've 100s of cleaners here who are provided with supervision, information, instruction and training, but little or any of it's written. If it were, it would be a work instruction, or Standard Operating Procedure. It wouldn't be a COSHH/ risk assessment.

chris.packham  
#8 Posted : 08 August 2017 11:50:55(UTC)
Rank: Super forum user
chris.packham

They don't need to see the COSHH risk assessment. This is for you so that you can identify what you need to do to ensure that the workers carrying out the particular task do not come to harm. What the workers need to see is the working practice/method statement for the particular taskcreated as a response to the risk assessment so as to ensure adequate control.  Hopefully this will be with some explanation/training so that they appreciate that this is for their benefit and to encourage them to comply. 

Chris

thanks 2 users thanked chris.packham for this useful post.
A Kurdziel on 08/08/2017(UTC), lorna on 09/08/2017(UTC)
A Kurdziel  
#9 Posted : 08 August 2017 12:36:29(UTC)
Rank: Super forum user
A Kurdziel

The cleaners don't need to see the COSHH assessment (but they might like to know one has been carried out) but it is for their managers to do the COSHH assessment and then to make sure that the cleaners follow whatever controls they need based on the assessment ( which might be what the SDS recommends but might be something else) 

Hsquared14  
#10 Posted : 08 August 2017 13:10:04(UTC)
Rank: Forum user
Hsquared14

Just a second guys - not sure I am with you on "cleaners don't need to see the risk assessment"  Regulation 12 requires that employees are provided with an appropriate level of information, instruction and training etc and lists amongst other things access to manufacturer's data and the significant findings of the risk assessment - admittedly you can give them the significant findings without them seeing the whole risk assessment but that's like giving someone the punchline without the whole of the joke, a bit meaningless!  Not only that but surely employees need to be involved in the COSHH assessment process as stated earlier in the regulations?

JohnW  
#11 Posted : 08 August 2017 14:47:01(UTC)
Rank: Super forum user
JohnW

I've been preparing (and explaining) COSHH assessments for years. Who are they for?

1. Users - to remind them about PPE, LEV and any other controls they should be using. An aid to training, and it's a written record that management have provided this information

2. First aiders - they quickly need to know if there's any special precautions they need to take before rinsing etc.

I keep the documents to two pages. The identification, hazard symbols, phrases etc are on page 1. The PPE list (with symbols) and First Aid are on page 2.

John

chris.packham  
#12 Posted : 08 August 2017 16:00:29(UTC)
Rank: Super forum user
chris.packham

My experience is that if you start to provide employees with all the data that is contained in a risk assessment all you will achieve is confusion and possible unwarranted concern about the chemicals and the hazards that they represent.

What HSE suggests that you actually can provide to meet the requirements of COSHH is contained in the sixth issue of the ACoP for COSHH. Take a look at paragraphs 257 and 261. What you provide is up to you but I find it best if the information is simplified and the emphasis is on how to worksafely when carrying out the particular task.

Chris

Hsquared14  
#13 Posted : 08 August 2017 16:09:12(UTC)
Rank: Forum user
Hsquared14

Chris - I think I have interpreted those paragraphs in the ACOP in a totally different way to you but then I have only been explaining COSHH and COSHH assessments to people since the first consultative documents on COSHH in the mid 1980s.  If your assessment is clearly written and properly reasoned and set  out well there is no reason at all why anyone should be scared or overfaced by the content - the manufacturer's data sheets are a different matter and have caused more anxiety, dispute and argument than any properly prepared COSHH assessment. 

thanks 1 user thanked Hsquared14 for this useful post.
JohnW on 08/08/2017(UTC)
JohnW  
#14 Posted : 08 August 2017 17:07:09(UTC)
Rank: Super forum user
JohnW

I'm with Hsquared, I like staff to understand what they are working with, and I like First Aiders to know too

e.g. in some factories the most dangerous materials they use are degreasing cleaners, they usually have caustic (sodium hydroxide) or other corrosive substances. I've gone into some places and they wear simple safety glasses when clearly their face will be burned if there's a splash.

And first aiders need to know exactly what the substance is so they don't get burned too.

John

Ron Hunter  
#15 Posted : 08 August 2017 17:19:47(UTC)
Rank: Super forum user
Ron Hunter

Oops! I seem to have sparked off the old "purpose of risk assessment" debate again.

For my part, R/A is a management tool, not a training aid or method of imparting work instruction, although it may refer to those regimes and other documents as controls.

 Neither does the R/A unilaterally "prove" that information, instruction or training has been given, or adequate supervision maintained - that would be evidenced via monitoring, audit and review.

Next up: The RAMS debate......

JohnW  
#16 Posted : 08 August 2017 19:09:40(UTC)
Rank: Super forum user
JohnW

I will usually arrange for COSHH assessments to be placed at or near point of use. There for the user and there for the first aider. So it must be part of, or an aid, to training.

​​​​​​​John

aud  
#17 Posted : 08 August 2017 20:01:04(UTC)
Rank: Super forum user
aud

An assessment under the COSHH regs could range FROM - A full blown water system analysis for the purpose of controlling legionella (following L8). TO - A shorter 'sweeter' version of data sheets, user friendly, if there is only a minimal number of products, used in simple ways, and the readership has been taken into account. (Pesticide product labels are a good example of comprehensive but succinct information, these are usually used individually and solely for one specified purpose).

And a host of variations in between. It depends. If in doubt start with TASK, as it is the mixtures, by-products and unintendeds which cause most problems, not the product as analysed by the manufacturer.

I have in the past produced a COSHH assessment for each of about 12 trades (80 workers) in a maintenance unit, using over 300 inventoried products. None of the assessments was longer than 3 pages. Whilst I would now prefer not to combine user information with the management analysis, these were readable for most. This persuaded the HSE to close an investigation and NOT issue a Notice.

Recently I produced a COSHH assessment for a GRP and woodworking workshop. I used one of the example templates on the HSE website (which does actually use joinery as it happens), and built on it (total 4 sides with action plan). To accompany it was a list of the 20 or so products, with by-products, as an index (1 sheet), plus a summary of the key points, for employees, (also used as toolbox talk) 1 sheet. There was also cross-reference to recent hygienist measurements (which validated the risk level and ongoing monitoring).

This was (last month) reviewed by a visiting HSE inspector, who shared their view on how SPs so often just produce replicas of data sheets, and that a real assessment covers tasks and risks. Phew! No further action.

By the way - when I say 'I produced' I mean I did most of the faffing - the research, writing, formatting, organising and compiling. This all went back and forth through workers, supervisors, safety group and management until all were content, and I felt they understood the process and the outcomes. 

I must add that over this time an auditor has observed somewhat critically that 'there should be a COSHH assessment for every data sheet' and that he had never seen a COSHH assessment so done (by activity). I felt obliged to point out that this was the template & style suggested by the HSE. There was some tension! But I've had HSE acceptance of this approach, both at the very start of COSHH, and nearly 30 years later, so I feel vindicated. Hope this helps.

thanks 1 user thanked aud for this useful post.
JohnW on 09/08/2017(UTC)
Ron Hunter  
#18 Posted : 08 August 2017 23:46:04(UTC)
Rank: Super forum user
Ron Hunter

Good stuff, aud. Kudos
Kate  
#19 Posted : 11 August 2017 14:55:57(UTC)
Rank: Super forum user
Kate

The approach I take is to require a detailed assessment over several pages of a spreadsheet that includes, for example, a detailed description of the activity, what the justification is for using such nasty materials (if they are nasty materials) and what makes this acceptable, then use a macro to extract from the detailed assessment one page of user information which tells the user just:

1. What precautions to take

2. What to do in an emergency

3. What the hazards of the raw materials are

This enables the risk assessment to contain as much detailed reasoning, including calculations,  as you like,  while not overloading the user with unnecessary information.

chris.packham  
#20 Posted : 11 August 2017 15:36:34(UTC)
Rank: Super forum user
chris.packham

Kate

I would be interested in how you define 'nasty materials'. For me any chemical can be a nasty material depending on the circumstances. For example, water, in the form of wet work, is the most common cause of occupational contact dermatitis. Under certain conditions, therefore, water will, for me, be a nasty material. After all, dihydrogen monoxide is arguably the cause of more human deaths than any other chemical known to man! (Think tsunami, drowning due to shipwreck, floods, etc.)

When considering skin exposure the main problem with a risk assessment is frequently determining exactly what is the hazard. We generally purchase chemicals to use for one or more tasks. In the process we may change the properties of what we are using (mix, contaminate, react, oxidise, etc.) and thus the hazard. For the same chemical the hazard when used for different tasks may also be different. In my work I see many risk assessments that do not recognise this and have assessed the risk on the basis of the hazards stated on the safety data sheet. When did you last see a safety data sheet for water? All too often I have to tell the new client that their risk assessments are of very doubtful validity (if not simply plain wrong)!

Chris

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