HSE Strengthens COSHH Focus on Respiratory Sensitisers Amidst Occupational Asthma Concerns

The Health and Safety Executive (HSE) has recently issued updated guidance reinforcing the importance of robust control measures for respiratory sensitisers under the Control of Substances Hazardous to Health (COSHH) Regulations 2002. This renewed focus comes as occupational asthma continues to be a significant health burden in the UK, impacting thousands of workers annually.

Respiratory sensitisers are substances that can cause a person to become sensitised through inhalation, leading to an allergic reaction such as occupational asthma or rhinitis upon subsequent exposure. Common examples include isocyanates (found in paints and varnishes), flour dust, wood dust, glutaraldehyde, and certain enzymes. The HSE’s emphasis highlights a proactive approach to preventing irreversible respiratory conditions.

The Persistent Threat of Occupational Asthma

Occupational asthma remains one of the most commonly reported work-related respiratory diseases in the UK. According to the latest available statistics from the HSE, an estimated 10,000 new cases of occupational asthma are reported to THOR (The Health and Occupation Research Network) by specialist physicians each year. While this figure represents reported cases, the true incidence is likely higher, with many cases going undiagnosed or unreported. The financial and human costs associated with occupational asthma are substantial, encompassing lost productivity, healthcare expenses, and a significant reduction in the quality of life for affected individuals.

The HSE's refreshed guidance aims to equip employers with clearer directives on how to identify, assess, and control exposure to these hazardous substances effectively. It underscores the employer’s legal duty under COSHH Regulation 6 to prevent or adequately control exposure to substances hazardous to health.

Key Updates and Employer Responsibilities

The updated guidance doesn't introduce new legislation but rather clarifies and strengthens the interpretation and application of existing COSHH regulations, particularly concerning respiratory sensitisers. Key areas of emphasis include:

  • Enhanced Risk Assessment: Employers are urged to conduct thorough and specific risk assessments that identify all potential respiratory sensitisers in the workplace. This includes reviewing Safety Data Sheets (SDS) and considering all tasks where these substances are used or generated.
  • Hierarchy of Control: The guidance reiterates the paramount importance of applying the hierarchy of control measures. Elimination or substitution of hazardous substances should always be the first consideration. Where this is not reasonably practicable, engineering controls (e.g., local exhaust ventilation – LEV) must be implemented and maintained effectively.
  • Health Surveillance: For workers exposed to respiratory sensitisers, robust health surveillance programmes are crucial. This includes pre-employment health screening and regular periodic health checks (e.g., spirometry, symptom questionnaires) to detect early signs of sensitisation or asthma. The guidance stresses that health surveillance is not a control measure but a way to check if control measures are working.
  • Information, Instruction, and Training: Employers must ensure that all employees who work with or near respiratory sensitisers receive adequate information, instruction, and training on the risks involved, safe working procedures, and the correct use of control measures, including personal protective equipment (PPE).
  • Maintenance and Review: All control measures, particularly LEV systems and PPE, must be regularly inspected, tested, and maintained to ensure their continued effectiveness. Risk assessments should also be reviewed periodically, and whenever there are significant changes in processes or substances used.

The HSE's guidance highlights that even low levels of exposure to sensitisers can trigger an asthma attack in sensitised individuals, making rigorous control measures essential. Employers are reminded that failure to comply with COSHH regulations can lead to enforcement action, including improvement notices, prohibition notices, and prosecution, alongside the devastating impact on employee health.

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Industry Impact and Proactive Measures

Industries particularly affected by this renewed focus include manufacturing (especially those using paints, resins, and adhesives), bakeries, woodworking, healthcare, and agriculture. Businesses in these sectors should take immediate steps to review their current COSHH assessments and control strategies. The HSE provides a wealth of resources on its website, including detailed guidance documents, case studies, and practical tools to assist businesses in achieving compliance.

For example, the HSE's 'Respiratory Sensitisers: Control of Substances Hazardous to Health' publication (HSG258) offers comprehensive advice on managing risks. Employers are encouraged to consult this and other relevant COSHH-specific guidance to ensure their practices align with the latest recommendations.

The message from the HSE is clear: preventing occupational respiratory diseases is a shared responsibility. By adhering to the principles outlined in the updated COSHH guidance, businesses can protect their workforce, meet their legal obligations, and contribute to a healthier working environment across the UK.

For organisations seeking to enhance their understanding and compliance with COSHH regulations, including specific training on respiratory sensitiser control, Abertay Training offers comprehensive health and safety courses. More information can be found at https://www.abertaytraining.co.uk.