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Posted By Alias
I've just been having an interesting discussion with a learned colleague and we disagree over whether COSHH and DSEAR assessments can be integrated.
I could be so far off mark here as I haven’t really researched this but the way I see it is you take a substance that may be irritant and also flammable, in the assessment you assess the risks arising through its use e.g. irritant to skin when used for x,y, and z and also needs to be kept away from sources of ignition and the blow torch or whatever etc. etc.
Storage conditions take into account both requires for COSHH and DSEAR…in a labelled bottle in an inflammable cupboard where x litres can be stored etc etc.
Specify environmental risk factors;
Training needed;
Health Monitoring;
First Aid;
Fire Fighting;
Disposal.
This way you have one concise form stating all you need to know about this substance instead of two different ones for one substance, plus your fire risk assessment and normal risk assessment to boot. I’m a big fan of streamlining and making safety straightforward and accessible but in my attempt to do this I may have missed the point.
Any thoughts would be greatly appreciated.
Thanks.
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Posted By Jim Walker
I can think of situations/instances were you are both right.
Integrate if it helps, keep seperate if RA gets unmanageable.
When people ask me what is the difference between COSHH & DSEAR my reply is:
COSHH is for Health risks, and DSEAR is for Physical risks.
I also explain that most of us were "covering" DSEAR (under COSHH) before DSEAR existed, so not much has changed.
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Posted By MichaelM
After a discussion with a HSE Inspector, approx a year ago, regarding highly flammable material, I was told that COSHH Assessment would not do and that it had to be a DSEAR Assessment, even though the necessary information was in the COSHH Assessment.
Hope this helps.
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Posted By Alias
Hi Michael,
Seems your HSE Inspector hasn't read the enforcement management model which is supposed to help inspectors not enforce pish on businesses where it isn't necessary. If the risk is adequately managed and the law doesn't say a DSEAR has to be completed seperately like a fire risk assessment for example then what's the harm.
I concur with the first reply when it said most of us were managing DSEAR with COSHH long before DSEAR exisited and that nothing has really changed provided you had a good management system before hand. I also can see where with some substances that are extremely difficult to manage from a DSEAR point of view they should be looked out indivifually as a special case.
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Posted By MichaelM
Alias
Believe it or not, the inspector was very helpful in several areas and gave very good advice.
Michael
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Posted By Jay Joshi
One can integrate, but should ensure that the assessment takes into account the DSEAR-Regs, ACoPs & Guidance--the standard COSHH assessment formats will not be adequate. In some cases, the assessment can be complex-where it requires zoning and use of "zoned" (ATEX) equipment.
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Posted By Kevin Drew
Our client in his wisdom integrated, DSEAR, COSHH and CLAW into one all encompassing risk assessment.
While on the face of it this might seem a good idea in practice it is a nightmare. Since most substances that we deal with are only covered by COSHH but not DSEAR it makes for plenty of blanks or N/As in the risk assessment which is many pages long which just discredits the whole process. It also causes slight problems with appointments. Competent persons under COSHH are two a penny whilst DSEAR is a little more tricky.
Given the choice I would avoid integration like the plague but this obviously depends to a large extent on the substances that you use.
Sorry to appear negative.
Kevin Drew
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Posted By Frank Hallett
Hi Alias
CoSHH & DSEAR are aimed at very different risks and have very different outcome requirements.
CoSHH application is pretty well known and fairly well understood, but DSEAR still isn't. Essentially, DSEAR is primarily intended to control "process" hazards and not the type of situation outlined in your post. Though there are situations such as some fume cupboard and extraction system use that I would initially consider to be within the remit of DSEAR until proven otherwise because they fall outside the criteria for DSEAR to apply. There have been articles in SHP on the application of DSEAR & FP[W] Regs.
The FP[W] Regs are currently the vehicle for control of flammable substances outside the "process" situation and will remain so until the RRFSO is activated on 1st April [honest] 2006. The RRFSO will essentially take over where the FP[W] Regs leave off as they are superceded by the RRFSO.
Sorry about all the repeated acronyms but I couldn't find another way to explain it.
Frank Hallett
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