It's another 'the auditor says...':

I have an ordinary clerical work office with desks and computers and a coffee machine and a microwave.  We don't do hot works in the premises, though once a decade or so a plumber might when fixing a tap or something.

In the office we have can of WD40 for dealing with e.g. squeaky hinges and the like, once in a blue moon.  We also have a few cans of spray-paint of the sort that roadworkers use to write on the road.  I don't know exactly why, but I'm told they are used occasionally.  'Few' should normally be no more than say three.

The auditor says that all COSHH substance must be stored in a COSHH cabinet, and all flammables need to be stored in a flammables cabinet, by law.  I've done the usual "What law?  Show me" pushback, but am now thinking about it - is there guidance that has volumes that can be considered small enough that 'normal prudent' arrangements are adequate (e.g. not storing it adjacent to a source of ignition)?  Web search and AI tells me yes there is, but gives me a limit of 113.56 litres, being 30 US gallons, being a (surprise!) USA regulation.

I suspect that strictly these things might need a cabinet, since I think they are formally at least Highly Flammable, and DSEAR has no specified quantities that can be considered negligible.  DSEAR requires 'suitable and sufficient' risk assessment including consideration of the quantity of material, but I haven't found any guidance about a quantity that can be allowed.  I'm not going to insist our tippex bottles be stored in a flammables cabinet, but have no real experience of whether four aerosol cans (1x WD40, 3x paint) in one place tips the balance.

From my general 'common sense' (ie the prejudices I've accumulated to date) I'd say it's a low risk and needs no more than our current line in the office general risk assessment that it is flammable, quantities are small, used in accordance with manufacturers recommendations, stored in the specified location, etc. but I have been known to be wrong before...

I think that the professional H&S response  is to tell the auditor  to put there report where the sun don’t shine. No you do not need a COSHH cabinet( what ever that is) but pretending you are a competent H&S auditor when you are  not is clearly illegal and punishable by death.

Originally Posted by: A Kurdziel

tell the auditor to put there report where the sun don’t shine

The office is in Manchester, so it already is ?

Under DSEAR, as with all risk assessments, only significant findings need to be documented. Therefore, if no significant risks are identified, a formal written risk assessment is not required.

Additionally, the term "COSHH cabinet" is not recognised in any official guidance. COSHH does advise that small quantities of highly toxic or other really nasties should have appropriate controls to prevent unauthorised access—such as being securely stored in a locked cabinet.

From a fire risk perspective, assessors should consider the quantity of flammable materials present. For minimal amounts, they may conclude: "The level of storage and use is limited; therefore, no specific DSEAR risk assessment is required." If only a few aerosol cans are stored, a flammable storage cabinet might be advisable, but even in such cases, a full DSEAR risk assessment is unlikely to be necessary.

Nothing worse than an auditor who doesn't understand the practical and realistic application in the real world of the thing they are auditing against!!

Edited by user 26 February 2025 13:39:54(UTC)  | Reason: Not specified

Better get my orange Dangerous Goods placards on - I have a can of WD40 in the boot

Indeed its an oversight in the DSEAR regulations / HSE guidance ACOP etc not to set a minimum limit as to when a DSEAR assessment / hazardous area classification should be undertaken. The IP table/guidance is as good as it gets. Given the HSE often use data/information from various standards, not using this limt/advice would prevent such trivial questions etc around DSEAR. 

If the office is in Manchester, after it has stopped raining, I would advise the auditor to go and play marbles on the M60.

There's a special dispensation for retail. H&S isn't meant to be a barrier to doing business.

Originally Posted by: antbruce001

There's a special dispensation for retail. H&S isn't meant to be a barrier to doing business.

If I remember correctly, this was raised during the investigation of the Boots warehouse fire (1990's) that was started by a single LPG propelled aerosol getting trapped under the metal wheels of an FLT.  The same controls that became industry recommended in warehouses (individual pallet sprinklers etc) were not considered appropriate for retail spaces where theoretically equivalent risk existed.

All about that tricky concept of risk assessment you see.