Hi All

Im after some opinions on how to interpret HSE guidance.

We use fogging equipment with a sanitising product as a measure to sanitise areas after have a confirmed covid case in the business. ( i know its not a effective control, however this is established and unlikely we will remove the process anytime soon)

Im of the opinion that there is not a requirement for certified training for this equipment/process, as we are using a sanitising product and not a fumigant. All the HSE guidance seems to be targetted at fumigants which obviously are a lot nastier and require more stringent training requirments to avoid killing people.

I believe just formal in house familirisation training would be sufficient for our purposes, accounting for manufacuters instructions and our RA and COSHH RA.

HSE guidance, under the section Disinfecting premises using fog, mist or UV treatment there is a link "users must be competantly trained" : https://www.hse.gov.uk/coronavirus/disinfecting-premises-during-coronavirus-outbreak.htm

It takes you to this guidance which only seems to be about fumigants:

https://www.hse.gov.uk/coshh/industry/fumigation.htm

Any thoughts?

The problem with these machines is that the SDS provided is quite often a copy of a copy for the material under supply which completely neglects the physical transformation of the material during the generation of fog.

It will likely state the physical form as solid/powder/liquid when in fact the equipment is eminating vapour -change the physical form and you change the exposure scenario. As such you need to be very competent to undertake a COSHH assessment in these circumstances - it is not something any on-line provider could ever accurately execute on your behalf.

Also remember that the agents used need to be registered as biocides - but at the begining of the pandemic they were given exemptions which have now expired. However not everyone has gone through the the approval process yet. I found one of my sites had decided to use a fogging agent and they could not understand that the exemption they had did not prove it was safe to use.