At this point of the guide, you've learned more about the intricacies of a COSHH risk assessment, chemical hazards, COSHH responsibilities and more. It's time to dive into the eight steps you need to follow to build a successful COSHH management system.
Years’ Experience
Clients
With over 20 years’ experience working with 6,000+ clients, we have learned that many different organisations and staff have varying levels of knowledge of chemical safety and best practices. Here are some of the most impactful steps we’ve seen:
1. Develop a chemical safety policy
Chemical safety is often perceived by health and safety teams as intimidating and complex. This often makes it the last area to receive attention due to the nature of other tasks. Assumptions can often be made that members of certain departments have a high level of competency when it comes to chemical safety if they work in laboratories, for instance. It's important not to make any assumptions, as regulations have changed over the years and constantly evolve.
To begin, you need to map out the organisation and the department structure. Ensure that you thoroughly document and cover all aspects of chemical safety. Share that knowledge with staff and ensure to train and retrain all staff members to a sufficient level of competence so they can make safe choices. Assign roles and responsibilities to all employees where necessary (emergency response, storage, handling). Having a complete overview of chemical safety within your organisation will give you a clearer picture and help put your mind at ease.
2. Build your chemical inventory
It’s vital to have an accurate chemical inventory to work with. How many sites, and how many departments do you have? What chemicals do you have in each location?
Areas to consider for your chemical inventory:
- List all departments on the site regardless of chemical use. It’s possible there are chemicals present you are not aware of.
- Allow for multi-site structure if required.
- Design a consistent chemical inventory template for use across the organisation. You must collect the full product name along with the catalogue code. This is essential, as it allows you to source the most up to date safety data sheet for each product.
- Collect product information by department and store it centrally. This will prevent you from doing the same work on multiple occasions, and it’ll also help you control the information being gathered. This will also be useful in terms of getting the right safety data sheet for the product you are using and not a variation.
- Use a consistent naming system for chemicals. For instance, note the full product name – e.g. “Bleach” vs. “Domestos Bleach Original”.
- Document the full manufacturer/supplier name.
3. Source safety data sheets
An SDS is a very important and informative document which allows you to assess hazards associated with the products in use. The law requires that all chemical suppliers provide an SDS for a hazardous mixture they wish to supply. SDSs should be available where the chemicals are in use.
It’s important that all staff have read the SDS concerning all the chemicals they are working with. Upon receipt of the SDS, it’s important to check the document to ensure it’s in compliance with the applicable legislation in the country where it’s in use i.e. UK SDSs should be CLP and REACH compliant.
Does your staff know what an SDS is? Employers should provide some basic awareness on this. For example, section 4 covers First Aid. Does your staff know this? If not, the safety data sheet will not be useful to employees using the chemicals.
All sections of an SDS are important, however, the most useful sections that staff should have knowledge on is the information displayed in sections 1-10. Safety data sheets must be provided either electronically or as a hard copy.
Manufactures/suppliers will usually provide SDSs with the product, either electronically or as a hard copy. If possible, source the SDS before the product is brought on site in order to review the hazards and determine if it’s suitable (we will cover this in more detail later). Record basic information related to the product in your inventory. This will help you maintain control of the chemicals you have on site.
4. Design a COSHH template
Keep your COSHH template simple and relevant. Avoid long and lengthy pages and use as many multiple-choice options as possible. Free text is slow and encourages “copy & paste” from safety data sheets. This does not allow for the evaluation of the hazards.
One of the biggest mistakes we see in COSHH Assessments is generic information being filled as a box ticking exercise, which has no significance for the job in question.
You can pre-populate certain sections with approved statements for all controls/procedures that are most relevant to each location on your site (first aid, fire, ppe, etc.). Remember to put your brand-logo on the template. It differentiates the document from an SDS and highlights ownership of the document within your organisation.
5. Write COSHH Risk Assessments
COSHH Risk Assessments are a necessary part of evaluating the possible substances hazardous to health in your organisation. Who will create these COSHH Assessments? Let's take a look at the following four options.
1. Completed by EHS with no input from staff
Creating a COSHH risk assessment in an office and not on the ground, is not advisable as it is often not specific to the location and task. In this scenario, the creation of the assessment has not been informed by the lived experience of people carrying out this task.
2. Completed by staff with no input from EHS
This is the reverse of the above scenario. Creating a COSHH assessment without EHS input, excludes valuable expertise and could lead to inconsistencies in quality.
3. Completed by staff - signed off by EHS
This scenario can speed up the completion of COSHH assessments but could lead to delays and inconsistencies in quality. This option works best when all staff have had some basic level of COSHH assessment training.
4. Completed by EHS in conjunction with staff
This is a scenario that is recommended, as staff are actively collaborating with EHS to complete the risk assessments. This ensures nothing is left out and everything is documented as it should be.
In our experience, best in class COSHH management systems typically use options 3 and 4.
6. Distribute information
COSHH assessments must be accessible to all staff, ideally electronically. Distribute assessments and safety data sheets to employees in a timely manner. The completion of COSHH assessments is vital to ensure the health and safety of staff involved.
A common mistake organisations make is once the documents are completed, they are placed in a folder until they require review again. These are documents which you should continuously improve at a regular cadence, as previously mentioned.
Soft Copies
Distribute soft copies to your organisational network, ideally through a document management system with features to allow for search, revision control, etc.
Hard Copies
If it’s not possible to provide soft copies, they should be provided via hard copy (printed).
In particular, these are required in areas that do not have access to systems. Strict procedures must be put in place to ensure they are kept up to date with soft versions. Ensure multiple revisions of the same document are not available to staff to avoid confusion.
7. Purchase new products
In our experience, this is one of the most important aspects you need to get right for chemical safety and COSHH management to be successful. The rationale behind this is when you purchase a chemical, you are often going to be using that chemical for 5, 10, or maybe even 15 years. Do you consider the potential impact of implementing control measures for that product for that length of time?
To understand how that chemical may affect your process, it’s important to complete your COSHH assessment early on i.e. before the chemical comes on site. Liaise with your supplier to ascertain all key information on the product and check the SDS.
There are a number of areas to consider during procurement including:
Inventory
Procedures must be put in place to ensure all products are placed within the department inventory.
Safety Data Sheet
This should be sourced before the product is brought on site. It’s the responsibility of the manufacturer to provide you with the safety data sheet, so don’t hesitate to contact them and ask for it.
COSHH Assessments
Consider conducting trial COSHH risk assessments for a product before committing to using it on site. This will help you identify whether the material is appropriate for your intended task.
8. Maintain and update safety data sheets
- Check for up-to-date safety data sheets with manufacturers –preferably on an annual basis.
- Archive old versions of safety data sheets. (Ensure staff only have access to the latest version).
- Centralise your inventory where possible.
- Update COSHH Assessments in line with revised SDSs.
- Put procedures in place to review COSHH assessments on an annual basis.
The European Chemicals Agency, or ECHA, are reviewing and revising the classification of substances on an ongoing basis, so it’s essential that you have the most up to date safety data sheet to reflect such a change. If for example, something changes from an irritant to a corrosive substance, you must update your COSHH Assessments accordingly, as it poses a different risk.
Individual departments should review and update inventory lists accordingly, but it’s essential that the SDS is managed centrally. The workload to implement a good COSHH system is significant and requires a lot of hours and input. Some companies work hard to get COSHH management updated to a good place and then they feel the work is complete. This should not be the case.
It’s an ongoing battle to maintain the quality of your COSHH system. If a product classification changes or you stop sourcing updated SDSs, then you increase the risk to your staff members and open your company up to a damaged reputation, lawsuits, and even closure.
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