Posted By Mark Dutton I would be interested to know what anybody has done about the potential exposure to haz substances in the warehouse from something like a spillage. I can think of a couple of ways to tackle this but do not want overkill. As there is no exposure in normal circumstances I could argue that there is no real need for an assessment, however if a spillage happens we should have one if only to defend ourselves from the potential litigation claims as a result of so called exposure. If anybody has tackled this i would be interesed to hear how you have done it and if you have any experience/opinions from an inspectors point of view.

Posted By Paul Leadbetter Mark All COSHH assessments should address three scenarios: normal use, maintenance operations and emergencies. In the case of storage, the risk during normal 'use' is low or very low, as you have said. Maintenance is not really applicable to storage but you do have to consider emergencies such as spillage or leakage. Depending on the substances involved, you will probably have to rely on PPE to control exposures during any cleanup. You should make sure that appropriate spillage kits are available and remember that, again depending on the substances involved, the used spillage kit may be special waste. You should also ensure that appropriate training is provided to those required to clear up any mess. Paul

Posted By Adrian Watson Geoff, Yes, because there is no reasonable practicability in the requirement to carry out a risk assessment. Assessment of the risk to health created by work involving substances hazardous to health 6. - (1) An employer shall not carry out work which is liable to expose any employees to any substance hazardous to health unless he has - (a) made a suitable and sufficient assessment of the risk created by that work to the health of those employees and of the steps that need to be taken to meet the requirements of these Regulations; and (b) implemented the steps referred to in sub-paragraph (a). (2) The risk assessment shall include consideration of - (a) the hazardous properties of the substance; (b) information on health effects provided by the supplier, including information contained in any relevant safety data sheet; (c) the level, type and duration of exposure; (d) the circumstances of the work, including the amount of the substance involved; (e) activities, such as maintenance, where there is the potential for a high level of exposure; (f) any relevant occupational exposure standard, maximum exposure limit or similar occupational exposure limit; (g) the effect of preventive and control measures which have been or will be taken in accordance with regulation 7; (h) the results of relevant health surveillance; (i) the results of monitoring of exposure in accordance with regulation 10; (j) in circumstances where the work will involve exposure to more than one substance hazardous to health, the risk presented by exposure to such substances in combination; (k) the approved classification of any biological agent; and (l) such additional information as the employer may need in order to complete the risk assessment. (3) The risk assessment shall be reviewed regularly and forthwith if - (a) there is reason to suspect that the risk assessment is no longer valid; (b) there has been a significant change in the work to which the risk assessment relates; or (c) the results of any monitoring carried out in accordance with regulation 10 show it to be necessary, and where, as a result of the review, changes to the risk assessment are required, those changes shall be made. (4) Where the employer employs 5 or more employees, he shall record - (a) the significant findings of the risk assessment as soon as is practicable after the risk assessment is made; and (b) the steps which he has taken to meet the requirements of regulation 7. Regards Adrian Watson

Posted By Geoff Burt But is 'reasonably practicable' not implicit in: "(a) made a suitable and sufficient assessment of the risk created by that work to the health of those employees and of the steps that need to be taken to meet the requirements of these Regulations;" Taking an overall view - substances on the domestic market are 'generally' low risk. I know that some may not be but if you could accept this general term for the discussion. Again generally the maximum quantity in each container is 5 litres. The majority of containers are much less. Each substance has hardardous warning signs on the container and instructions for, and in, use. Staff are trained in general issues surrounding COSHH including evacuation of the immediate area/s if necessary. Staff have access to PPE (but not RPE) for handling the substance/s. So, instead of having an assessment for each substance (with its attendant difficulties including training, constant reviews, availability etc), why wouldn't a blanket assessment for the majority of substances be sufficient - bearing in mind the low risk involved? For the higher risk substances, eg thinners, then individual assessments could be produced. Geoff

Posted By Geoff Burt Complements the point nicely - if a company has the MSDSs for all the substances why then do they have to carry out individual assessments for each low risk substance. My concept of low risk takes into account the toxicity of the substance, the dangers if it was spilled, the size of the containers, the number and types of persons involved and the existing general precautions & arrangements in place. On the simplest plane is it necessary to do an assessment on, say, powder Polyfilla, but at least one of the responses above suggests that it is. Not in my opinion and the term 'reasonably practicable' should always be taken into account - unless credibility is unimportant. One company has assessed table salt in their canteen - for goodness sake, what was the Safety Advisor thinking of? Mark - you may think the discussion has been 'hijacked' but I think they are closely related topics/concepts. Geoff

Posted By Geoff Burt I'm completely in agreement with that Adrian. Geoff

Posted By Dave Wilson All very good stuff people however we are missing the nature of the contamination and its effects on the Environment etc which also need to be taken into consideration. Groundwater protection and escape into the Drainage system and the effects this may have need to be addressed as well as the safety aspects. Just a thought, as apart from the attention of the EA you would also be required to foot the bill to do any clean up etc and may put you out of business!