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Posted By Geoff Burt
It is current safety policy at xxx that a written COSHH assessment must be provided when a substance to be used has been assigned any of the risk phrases R42, R43, R45, R46, R48, R49, R60 or R61. Other hazards may also dictate the preparation of a suitable COSHH assessment.
In a company using over 200 substances would this be a good policy to adopt? It would save a lot of work!
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Posted By Adrian Watson
Geoff,
The methodology proposed is not a good idea. Whilst it may save you paperwork, it'll certainly leave you with gaps in the system which may produce problems with the enforcement authorities or the civil courts.
You should remember the need to record the assessment is determined by the complexity of the risk assessment, the degree of risk and type and degree of the hazardous substance.
Regards
Adrian Watson
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Posted By Allan St.John Holt
Geoff,
I wonder what makes xxxxx think that the rules governing the rest of the country have been suspended in their favour? Seems to me a very arbitrary view of what is actually a more complex risk-based scenario. At the least, if their view was what was wanted then the directive would have been written differently, and just think how easy it would have been to draft the COSHH Regulations: 'You have to do this only in the following cases'.
I have a feeling this is the first joke entry of the year? Although in about 1994 I recall having a prolonged argument with the safety manager of a well-known multinational petroleum company (following its unsuccessful defence to a prosecution) who thought risk assessments only applied to things and situations that were dangerous. 'So how do you know it's dangerous?' Development of circular argument follows rapidly....
Allan
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Posted By Jane Blunt
The short answer to your question is no.
It is a very simplistic approach that appears to attribute risk only to those substances of a certain hazard category. Someone once said that you are in more danger standing knee deep in a totally innocuous powder than if you have the most dangerous substance in the world in a sealed rugged container in your pocket.
Its all about quantity, the physical form that the substance is in, and the opportunity for exposure, by what route, and what that subsequent exposure leads to. The R phrases are only a useful pointer to a small subset of the things that might merit more care. It does not even begin to address things that arise out of a process, such as welding fume!
xxx simplifies it at their peril
Jane
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Posted By Martin J Morley
COSHH Assessments do seem to frighten a lot of people, they seem to want easy answers. This is an easy but very poor one (see earlier replies)
A better one might be to use COSHH Essentials HGSG193, it has the advantage of being quite formulaic - but has the advantage of being 'official'.
Interestingly, it immediately puts R42, R42/3, R45, R46 and R49 into 'Special situations', an indication of how poor the original scheme actually was.
martin j morley
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