COSHH risk assessments
RMT Circular No. NP/307/05: 4 August 2005
Referring to the above, a resolution was carried at the 2005 National Conference of Station Staff and Associated Grades Conference calling for the Union to take up members' concerns in connection with the lack of consultation and information regarding the Control of Substances Hazardous to Health (COSHH) risk assessments and safety data sheets.
This matter has been considered by the General Grades Committee, which has asked me to remind Branches of the requirements of the COSHH Regulations, so that these can be brought to the attention of health and safety representatives. Representatives should also be reminded to be vigilant and ensure that any problems that arise are raised promptly with Management.
The COSHH Regulations place a duty on employers not to allow any work activity liable to cause employees to be exposed to a substance hazardous to health unless there has been a suitable and sufficient assessment of the risks to health created by the work, and the necessary steps taken to prevent or adequately control exposure. Health and Safety representatives have the right to be consulted and provided with information as to the significant findings of the risk assessment, including the preventative or protective measures required.
The risk assessment must take into consideration the following:
* The hazardous properties of the substance.
* Information the supplier has provided on health effects, including the content of any relevant safety data sheet.
* The work activity, including the amount of substance involved.
* The level, type and duration of exposure.
* Any potential for a high level of exposure e.g. during maintenance.
* Any relevant Workplace Exposure Limits.
* The effect of preventative and control measures.
* The results of exposure monitoring and any health surveillance results.
* Where the work involves exposure to more than one hazardous substance, the risk presented by the combined exposure.
* The approved classification of any biological agent.
Employers must review the risk assessment whenever there is reason to believe it is no longer valid e.g. alteration in the method of work etc. However, even where no changes take place, the assessment should still be reviewed at least every five years.
Where it is not reasonably practicable to prevent exposure to a hazardous substance, the employer should apply adequate controls that will reduce the level of exposure and present less risk to the health of employees. Such control measures should be considered in the following order of priority, perhaps in combination as necessary:
* Replace with a less hazardous substance or in a less hazardous form.
* Totally enclose the process or handling systems.
* Introduce plant, processes or safe systems of work that minimize the emission of hazardous substances and reduces the risk of leaks, spills and escapes.
* Install suitable ventilation systems.
* Reduce the level of hazardous substance, or the level and duration of exposure.
* Arrange safe storage and disposal of hazardous substances.
* Provide adequate facilities for washing, changing and the laundering of contaminated clothing.
* Provide suitable personal protective equipment (PPE), but only as a last resort and in addition to other control measures.
Employees must make full and proper use of any control measures provided for materials, plant and processes, and follow the defined method of work. They should wear any PPE correctly, and return it after use to the accommodation provided. They should also promptly report any defects they find in any control measure, device or item of PPE
Any PPE that becomes contaminated by a hazardous substance must be removed when leaving the working area, and kept apart from any uncontaminated clothing or equipment. Contaminated PPE must be either decontaminated and cleaned or if necessary, destroyed.
I should be grateful if you would bring this matter and the need for vigilance to the attention of health and safety representatives.