Managing COSHH

Managing the Control of Substances Hazardous to Health Regulations 2002 (COSHH) in the supply chain presents some significant challenges, but thankfully developments in technology are making these easier to overcome, says Tim Watson

COSHH requires employers to prevent or reduce worker, contractor or other people’s exposure to hazardous substances through risk assessment and the implementation of suitable and sufficient control measures. When it comes to managing the effective control of hazardous substances in the supply chain this can be complex, particularly concerning the need to ensure contractors have the necessary skills and knowledge to COSHH risk assess a job correctly and consider how different substances interact, cumulative exposure to multiple products and the complexities of specifying controls such as Personal Protective Equipment (PPE). Combine this with the fact that contractors often struggle to produce task-specific COSHH assessments and you don’t have to look far to find examples of companies not meeting their obligations under the COSHH Regulations.

The consequences of non-compliance
This is of significant concern as the cost of not complying with the COSHH Regulations is on the rise. Aside from the moral obligation companies have to protect their staff and the environment, changes to health & safety sentencing guidelines introduced in February 2016 mean that businesses can now face unlimited fines and prison sentences, not just for causing actual harm but also for causing risk of harm. In addition there is evidence that health & safety inspectors are increasingly identifying incidents where companies have created inadequate risk assessments and readily raising improvement and prohibition notices.

It is therefore essential that oil & gas sites ensure that their contractors have suitable and sufficient COSHH risk assessments in place. Thankfully the engagement of management software systems can simplify this process significantly and, as software systems continue to improve in terms of usability and affordability, they are becoming ever more accessible.

The ‘Alcumus COSHH’ Management System (CMS), for example, helps users identify, assess and manage hazardous substances in the workplace, and walks them through the process of completing and delivering fully compliant, taskbased COSHH risk assessments. Through the simple CMS interface which is available to companies of all sizes – from a small contractor in need of 10 COSHH assessments to a larger company requiring 5000 – an employer or employee can easily obtain a COSHH assessment. These assessments are provided in an easy-to-follow format with pictograms led by international standards that ensure the document is simple to interpret and ensures ownership. The CMS system also features bespoke symbols which have been specially created for areas where it is felt people would benefit from additional information, for example there is a symbol to make people aware when specific elements of the Registration, Evaluation, Authorisation and restriction of Chemicals (REACH) Regulations apply to a scenario.

Body of knowledge
The Alcumus CMS is managed from the Alcumus office in Aylesbury, Buckinghamshire, where the great breadth of experience and insight of the Alcumus team is harnessed through a central knowledge base. Over a 30 year period the Alcumus CMS team has written more than 1,000,000 COSHH risk assessments for over 150,000 products and substances, offering an ever increasing library for clients to use, and it is believed to be the most comprehensive database available. Clients receive access to this database of commonly used materials so that they can easily login and download relevant documents. If they can’t find what they’re looking for, or require something more tailored, the team of CMS experts will write any COSHH assessments that cannot be found on the database.

Affordable access to experts
Interpreting the COSHH Regulations can require expensive expertise and prove incredibly time consuming. This is another area where online systems can provide significant value for money. Alcumus can work as a competent body on behalf of employers and contractors to make sure suitable and sufficient COSHH risk assessments are in place for any anticipated workplace exposure to hazardous substances. The CMS offers access to an experienced team of chemists, toxicologists, occupational hygienists and health & safety consultants providing competent helpdesk support seven days a week.

Continual improvement
As the Alcumus CMS is a dynamic system it can be used to drive continual improvement as well as keeping users up-to-date with any changes to legislation and guidance. The Alcumus CMS can be used to monitor improvements in areas such as air monitoring survey results where data can be fed back into the system to track progress. Meanwhile if there are updates to documents such as the HSE’s EH40/2005, the list of approved Workplace Exposure Limits (WELs) or to hazard classifications they are automatically updated on the COSHH assessment and the user informed via the online system.

Future proof
Alcumus works closely with authority bodies and its clients to make sure that its services meet the requirements of industry in the future as well as today. This is particularly relevant in the oil & gas industry where markets fluctuate greatly, so it’s essential to ensure that services are future proof. Alcumus CMS customers can also be assured that they will be kept up to date with any changes to standards and guidelines that may affect them. As there is still uncertainty around the impact that Brexit will have on health & safety standards and guidelines in the UK, Alcumus continues to track any future developments but is not expecting any major changes, with the most likely outcome being that Britain will adopt European legislation and adapt it for the British market.

Key areas of COSHH compliance fulfilled through Alcumus CMS:

  • COSHH Regulations 2002 (as amended)
  • The Alcumus CMS COSHH risk assessment complies with the COSHH Regulations
  • Step-by-step consideration of the Hierarchy of Control and Principles of Good Practice
  • Indicating where workplace exposure monitoring, engineering controls & health surveillance are appropriate to demonstrate adequate control of exposure
  • Fully Classification, Labelling and Packing (CLP) Regulations 2008 (as amended) compliant
  • REACH: Identifying where it applies to controlled and regulated substances

Tim Watson is Alcumus Technical Account Manager. Alcumus is a market-leading provider of technology-enabled compliance risk management, certification and accreditation services, supporting both UK and International companies with a wide range of risk management services, including web based information management solutions, UKAS accredited certification services, contractor accreditation, health & safety inspection and consultancy, workplace monitoring services, training and HR consultancy.

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