HSE Sounds Alarm on COSHH Compliance as Incidents Climb

The Health and Safety Executive (HSE) has issued a renewed call for UK businesses to meticulously review and update their control measures for substances hazardous to health (COSHH). This comes in the wake of persistently high figures for work-related ill health, a significant portion of which is attributed to inadequate management of hazardous substances in the workplace.

According to the latest HSE statistics for Great Britain (2022/23), an estimated 1.8 million working people are suffering from work-related ill health. While a broad category, respiratory diseases, skin diseases, and certain cancers are directly linked to exposure to hazardous substances. The HSE’s proactive stance underscores the critical importance of robust COSHH management to protect employee wellbeing and ensure regulatory compliance.

The Pervasive Threat of Hazardous Substances

Hazardous substances are ubiquitous across various industries, from manufacturing and construction to healthcare and cleaning services. They can take many forms, including chemicals, fumes, dusts, vapours, mists, nanotechnology, gases, and biological agents. The risks associated with these substances range from immediate acute effects, such as burns or poisoning, to long-term chronic conditions, including occupational asthma, dermatitis, and certain types of cancer.

The Control of Substances Hazardous to Health Regulations 2002 (COSHH) provide a comprehensive framework for employers to prevent or adequately control employee exposure to hazardous substances. Key requirements under COSHH include:

  • Risk Assessment: Identifying hazardous substances and evaluating the risks they pose.
  • Control Measures: Implementing appropriate measures to eliminate or reduce exposure, prioritising elimination or substitution where possible, followed by engineering controls, administrative controls, and finally, personal protective equipment (PPE).
  • Monitoring and Review: Regularly checking the effectiveness of control measures and reviewing risk assessments.
  • Information, Instruction, and Training: Providing employees with clear information, instruction, and training on the risks and control measures.
  • Health Surveillance: Implementing health surveillance where appropriate, especially for workers exposed to substances known to cause specific health effects.

Despite these clear regulations, HSE investigations frequently uncover instances where COSHH principles are either misunderstood or poorly implemented, leading to preventable incidents of ill health.

Industry-Specific Concerns and Common Pitfalls

Certain sectors are particularly susceptible to COSHH-related risks. For example, in the construction industry, exposure to silica dust (from cutting concrete, stone, and brick) and wood dust are significant concerns, both of which can lead to severe respiratory diseases such as silicosis and occupational asthma. In manufacturing, exposure to solvents, metalworking fluids, and welding fumes poses ongoing challenges.

Related training: If you are looking to qualify as a trainer in this area, see lone worker safety training or explore food hygiene trainer qualifications for nationally recognised UK and Ireland qualifications.

Common pitfalls identified by the HSE include:

  • Inadequate Risk Assessments: Failing to identify all hazardous substances or underestimating the risks.
  • Over-reliance on PPE: Using personal protective equipment as the primary control measure without exploring higher-level controls.
  • Poor Ventilation: Ineffective local exhaust ventilation (LEV) systems or lack of maintenance.
  • Insufficient Training: Employees not understanding the risks or how to use control measures effectively.
  • Lack of Supervision: Inadequate oversight to ensure control measures are being followed.

The HSE emphasises that a proactive approach, rather than a reactive one, is essential. Employers should not wait for an incident to occur before reviewing their COSHH arrangements.

Strengthening Your COSHH Strategy: Practical Steps

To assist businesses in strengthening their COSHH strategy, the HSE recommends a structured approach:

  1. Revisit Your Risk Assessments: Ensure all hazardous substances are identified, including those generated during work processes (e.g., welding fumes, dusts). Evaluate the routes of exposure (inhalation, skin contact, ingestion) and the potential health effects.
  2. Hierarchy of Controls: Apply the hierarchy of controls rigorously. Can the substance be eliminated or substituted with a less hazardous alternative? If not, can exposure be controlled through engineering solutions like LEV or process enclosure? Only then consider administrative controls and PPE.
  3. Maintain Equipment: Regularly inspect and maintain control equipment, especially LEV systems, to ensure they remain effective. Keep detailed records of maintenance.
  4. Comprehensive Training: Provide tailored training to all employees who work with or near hazardous substances. This should cover the risks, safe handling procedures, use and limitations of control measures, and emergency procedures.
  5. Health Surveillance: If required, implement and maintain robust health surveillance programmes to monitor the health of exposed workers and detect early signs of ill health.
  6. Emergency Preparedness: Develop and communicate clear emergency procedures for spills, leaks, or accidental exposures.
  7. Regular Review: Periodically review your COSHH assessments and control measures, especially after any changes in work processes, substances used, or reported incidents.

By adhering to these principles, businesses can significantly reduce the risk of work-related ill health stemming from hazardous substances, thereby protecting their workforce and ensuring compliance with UK health and safety legislation.

For businesses seeking to enhance their understanding and implementation of COSHH regulations, comprehensive training is invaluable. Expert-led courses can provide the necessary knowledge and practical skills to conduct thorough risk assessments, implement effective control measures, and ensure ongoing compliance. Abertay Training offers a range of health and safety courses, including those focused on COSHH, to help organisations meet their legal obligations and foster a safer working environment. More information can be found at https://www.abertaytraining.co.uk.