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Topics > Chemical Hazards > COSHH: In-depth

COSHH: In-depth
Summary
The Control of Substances Hazardous to Health Regulations 2002 (COSHH) as amended
apply to substances and mixtures found in the workplace which are hazardous to health.
This topic outlines the requirements placed on employers under the regulations to prevent
or adequately control exposure of employees to hazardous substances. Such control is
based on risk assessment and the introduction of appropriate control measures.

Employers' Duties
Employers have a number of general and specific duties under UK legislation relating to
hazardous substances at work. They include the following.
• A general duty under the Health and Safety at Work, etc Act 1974 to ensure, as far as
reasonably practicable, the absence of risks to health from using, handling, storing and
transporting substances.

• A duty under the Control of Substances Hazardous to Health Regulations 2002

(COSHH) (as amended) to either prevent employees being exposed to substances
hazardous to health or, if prevention is not reasonably practicable, to adequately
control exposure.

To comply with their duties under COSHH, employers must:

• ensure, as far as reasonably practicable, the safe use, handling, storing and
transporting of substances

• prevent employees being exposed to substances hazardous to health or, if prevention

is not reasonably practicable, they must adequately control exposure

• provide personal protective equipment (eg face masks, respirators, protective

clothing) only as a last resort and never as a replacement for other control measures
which are required

• identify the hazardous substances present in the workplace

• assess the risks the hazardous substances pose to people’s health

• ensure control measures for dealing with hazardous substances are kept in efficient
working order and good repair, and are properly used and maintained
• ensure local exhaust ventilation equipment is examined within the specific intervals
set by COSHH (eg 14 monthly), and records of examinations and tests carried out are
kept for at least five years

• measure the concentration of hazardous substances in the air breathed in by workers

in any instance where:

– exposure limits might be exceeded

– failure or deterioration of control measures could lead to serious risks to health

– control measures may not operate correctly.

• keep a record of any exposure monitoring for at least five years

• where appropriate, carry out health surveillance for their employees and keep the
records for 40 years after the date of the last entry

• prepare plans and procedures in the case of an accident or emergency caused by a

work activity

• provide employees with suitable and sufficient information, instruction, training and
supervision

• protect workers from the fire and explosion risks associated with dangerous
substances under the Dangerous Substances and Explosive Atmospheres Regulations
2002.

Employees' Duties
Employees must:
• co-operate with their employers to enable their employers to comply with the Control
of Substances Hazardous to Health Regulations 2002 (as amended) (COSHH)

• make proper use of control measures, including personal protective equipment

• return equipment after use to any storage place and report any defects found in the
equipment

• attend medical examinations at the appointed time and give any information about
their health as may be reasonable

• participate in health surveillance (if required)

• report any accident or incident which could have resulted in the release of a biological
agent into the workplace and which could cause severe human disease.
In Practice
What are Substances Hazardous to Health?
COSHH covers the use of substances or mixtures that are hazardous to health. Substances
are defined as individual chemical compounds. Mixtures are mixtures of two or more
substances, eg paints, cleaning products and many pesticides.
Substances or mixtures hazardous to health are defined in five categories.
1. Substances which have certain dangers: these will be classified under European
Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances
and mixtures (CLP Regulation) as very toxic, toxic, harmful, corrosive, or irritant.

2. Substances with a workplace exposure limit (WEL) assigned to them under COSHH are
classified as hazardous to health.

3. Substances which are biological agents, whether exposure results from a deliberate
intention to work with a biological agent or exposure is incidental to the work activity.
Examples of biological agents include tetanus, legionnaires’ disease, anthrax, Lyme
disease, etc. It does not include exposure which does not arise out of the work activity,
eg if an employee catches a respiratory infection from another employee.

4. Dusts. This category covers all types of dusts that are not classified as very toxic, toxic,
harmful, corrosive, or irritant under the CLP Regulation or have a WEL and are present
at a concentration in air above:

a. 10mg/m3 as a time-weighted average over an eight-hour period, of inhalable

dust

b. 4mg/m3 as a time-weighted average over an eight-hour period, of respirable

dust.

Dusts and respirable dusts which can be inhaled are defined in BS EN 481:1993, BS
6069-3.5:1993 Workplace Atmospheres. Size Fraction Definitions for Measurement of
Airborne Particles.

5. Substances which otherwise create a risk to health. Substances which are not covered
by the other four groups but, because of their hazardous properties and the way they
are used, create a comparable risk to health are also included in COSHH.

Substances Not Covered by COSHH

COSHH does not apply to substances which are covered by separate legislation, eg lead or
asbestos.
Nor does COSHH cover substances and mixtures which are hazardous solely because of
their physical properties, eg substances and mixtures that are:
• hot, eg molten metals
• cold, eg liquid nitrogen and other liquid gases

• pressurised, eg gas cylinders

• flammable, eg solvents

• explosive

• radioactive.

Substances and mixtures with hazards not covered by COSHH are still subject to the
general requirements of the Health and Safety at Work, etc Act 1974 and the Management
of Health and Safety at Work Regulations 1999 (as amended). Some are also subject to
specific regulations, eg radioactive substances are covered by the Ionising Radiations
Regulations 2017 and flammables and explosives are covered by the Dangerous Substances
and Explosive Atmospheres Regulations 2002 (DSEAR).

Biological Hazards
There are some “hazardous substances” that occur in nature such as pathogens, micro-
organisms and parasites which also fall within the scope of the regulations. Biological
hazards can be fatal and the need to assess significant biological risks is a specific
requirement of COSHH. Examples include infections from contact with sewerage (eg mild
cases of gastroenteritis and potentially fatal diseases, such as hepatitis), rat's urine
(leptospirosis, or Weil’s disease) and tick-borne diseases such as Lyme disease.
For the purposes of carrying out an assessment, infectious micro-organisms include
bacteria, viruses, fungi and internal parasites, all of which are hazardous to human health.

Occupational Asthma
A more stringent risk assessment is necessary where substances are used that may cause
occupational asthma; exposure must be reduced to as low a level as is reasonably
practicable. For these substances, the SDS will have the hazard statement H334 (may cause
allergy, asthma symptoms or breathing difficulties if inhaled) or H317 (may cause an
allergic skin reaction).
Examples of substances that cause occupational asthma that may be encountered on the
construction site include certain wood dusts (eg western red cedar and western red
hemlock) and disocyanates, which are used in some foams and paints. Special advice on
surveillance of personnel at risk of such substances can be found in the HSE's guidance,
G402 Health Surveillance for Occupational Asthma.

Carcinogens
Those substances accorded with either H350 (may cause cancer (state route of exposure if
it is conclusively proven that no other routes of exposure cause the hazard)) or H350i (may
cause cancer by inhalation) are categorised as carcinogenic under the terms of the COSHH
Regulations. For these, like occupational asthmagens, the exposure must be reduced to as
low a level as is reasonably practicable.
COSHH also requires additional measures when carcinogens are used. Examples of
carcinogens that may be encountered on construction sites include petrol, mineral oils,
wood dust and used engine oil.

Infection Risks
While some infections have long-term ill effects, many are mild and often do not require
any medical intervention. The range of infections to be assessed applies only to those
specifically relevant to the work activity; it does not apply to general infections such as
influenza that are often acquired from colleagues; hence there is a separate risk assessment
form (with guidance) for infections.

Risk Assessment
The basis of the Control of Substances Hazardous to Health Regulations 2002 (COSHH) (as
amended) is a suitable and sufficient risk assessment. This means simpler and lower-risk
situations will not require as much consideration as more serious and complex risks. The
assessment requires:
• information to be gathered about the hazardous substances at the workplace and ways
they are used; or, in the case of biological agents, ways they can be contracted

• evaluation of the likelihood of exposure and risks to health

• determination of the measures required to prevent employees being exposed to the

substances or to adequately control the exposure.

• the hazardous properties of the substance

• information on health effects provided by the supplier, including information

contained in any relevant safety data sheet

• the level, type and duration of exposure

• the circumstances of the work, including the amount of the substance involved

• activities, such as maintenance, where there is the potential for a high level of
exposure

• any relevant workplace exposure limit (WEL) or similar occupational exposure limit
(OEL)

• the effect of preventive and control measures which have been or will be taken

• the results of relevant health surveillance

• the results of monitoring of exposure

• in circumstances where the work will involve exposure to more than one substance
hazardous to health, the risk presented by exposure to such substances in combination

• the approved classification of any biological agent

• such additional information as the employer may need in order to complete the risk
assessment.

If the hazards are known, specific steps can be taken.

1. Identify the hazard.

2. Assess the risk.

3. Decide what precautions are required.

4. Eliminate, prevent or control the risk.

5. Maintain and monitor the controls.

6. Monitor the exposure.

7. Monitor the health of the workforce, carry out appropriate health surveillance.

8. Ensure assessments and controls are up to date.

9. Prepare a plan for accidents and emergencies.

10. Inform and train the workforce. Ensure they are adequately supervised.

Who carries out the assessment?

The legal responsibility for the assessment rests with the employer or operator. Employers
or operators can carry out the assessment themselves, delegate the task to other
employees, or call in an expert. The employer or operator must, however, ensure the
following apply to the person who carries out the assessment.
• They have access to and understands COSHH and any relevant approved codes of
practice, or is able to consult someone who does.

• They have access to sufficient information about the substance and how it is used.

• They have sufficient knowledge and experience to make correct decisions about the
risks and the actions needed. A qualification in occupational hygiene or chemistry or
membership of relevant professional bodies is a valuable indicator of competence,
especially in more complex situations. However, for in-house assessment of less
technically demanding risks, training in the principles of occupational hygiene or
infection control may be sufficient, particularly if complemented by practical
experience.
• They have sufficient knowledge and experience to make correct decisions about the
risks and the actions needed.

• They have the necessary facilities, time and authority to do the work.

• They are able to talk to the appropriate people, look at existing records and examine
the workplace.

• They have clearly defined reporting arrangements so the findings can be acted on and
any necessary action authorised.

Carrying out COSHH assessments is dependent on an appreciation of what happens in the

workplace, therefore employees, and particularly those who carry out the operations, can
contribute vital information.
Consequently, assessments should be started in-house if possible. If the necessary
knowledge and experience is not available in-house, outside consultants can be used.
Complex and hazardous situations may require specialist help.
Guidance can be found in the relevant approved Code of Practice, L5 The Control of
Substances Hazardous to Health Regulations 2002.

What Hazardous Substances are Present?

The first step in the risk assessment is to identify what hazardous substances are present,
or are likely to be present, in the workplace, or to be encountered during working
operations.
An inventory of hazardous substances can then be drawn up. This requires identifying:
• all the organisation’s activities whereby staff might come into contact with potentially
hazardous substances

• the hazardous substances involved

• where substances are used

• where substances are produced

• how substances are handled and transported

• where substances are stored.

Areas that should be considered include:

• substances coming into the organisation

• substances in stock

• substances produced, not only finished products, but also by-products,including:

– dusts
 – fumes

– effluents

– residues

– wastes

• substances that may be encountered during work activities, eg dusts produced from
work on the structure of a building, by painters, maintenance personnel or research
and testing laboratories

• micro-organisms that may be present, eg the legionella bacteria that causes

legionnaires’ disease and the range of diseases carried by farm animals which affect
humans.

Prescription medicines are controlled by legislation such as the Misuse of Drugs Act 1971
(as amended). However, it is good practice to include prescribed medications within the
COSHH assessment process.

What are the Hazardous Effects?

Once the relevant substances present have been identified, the hazards presented by each
one need to be determined. This process has two aspects, which are:
• the route by which the substance enters the body

• the adverse effects of the substance on the body.

Route of entry
Substances can enter the body by:
• inhalation

• ingestion

• injection into the body, either by high pressure equipment or contaminated sharp
objects (for example glass)

• absorption through the skin or through the eyes.

In addition, contact with irritant and corrosive substances can cause serious damage to
skin and eyes.
The physical form of the substance will govern the route by which it can enter the body. A
large block of metal cannot be inhaled but the same metal in the form of dust or fume can
be. A liquid with a low volatility will be much less likely to be inhaled than the same liquid
in the form of an aerosol.
The adverse effect of a hazardous substance often depends on its route of entry, eg
inhalation of wood dust can cause nasal cancer, whereas ingestion or contact with wood
dust will not bring about the disease.

Adverse effects
Information about the adverse effects on health can be obtained from a variety of sources.
Suppliers of chemicals for use at work are required to label the product with basic
information on the substance’s hazards.
The Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH) requires suppliers of chemicals to provide safety data sheets (SDS) with the
chemical and these should be requested if not provided. These provide information under
16 headings specified by REACH, including:
• the hazards the chemical presents

• how the chemical should be stored

• how it should be disposed of

• the actions that should be taken in the case of an accident.

The HSE publication, EH40: Workplace Exposure Limits should be consulted to determine
whether the substance has been assigned a WEL.
If safety data sheets are not available, eg if materials are made in-house, consultation with a
trade association or a specialist advisor, may be required. Specialist literature and the
internet are other useful sources of information.
The hazard information should indicate the period over which the adverse effects of a
hazardous substance develop. The following questions should be asked.
• Are the effects immediate, short-term, acute?

• Are the effects delayed, long-term, chronic?

• Are the effects a combination of the above?

It is important that carcinogens and mutagens are identified as COSHH requires additional
measures to be taken for these substances, such as prohibiting eating, drinking and
smoking in areas that may be contaminated by carcinogens or mutagens, designating those
areas and installations which may be contaminated and using suitable and sufficient
warning signs.

Evaluating the Risk

The first step to evaluating the risk from using a hazardous substance is to find out:
• how the substance is used
• where the substance is used

• how much of the substance is used.

Those who are likely to be exposed should be identified, including those not directly
involved in the activity, eg maintenance staff, cleaners, contractors and visitors.
It will be necessary to decide whether to assess an activity, or to assess the uses of a
specific substance. The assessment will involve considering:
• the potential of the substance to cause harm to health

• the chance of exposure

• frequency and duration of exposure

• the level of exposure.

The assessment should not only consider normal activity. Activities such as maintenance
and cleaning should also be considered, as should emergency or non-routine situations. It
should also be remembered that employees do not always “do things by the book”.
It may not be necessary to carry out measurements as it may be obvious what is required.
However, if particularly hazardous substances are used, or the level of exposure is not
known, it may be necessary to carry out measurements. Circumstances in which the
determination of the level of exposure is important include:
• frequent exposure

• a high level of exposure

• if the substance has a WEL or a biological monitoring guidance value

• if the substance can cause cancer, asthma or respiratory sensitisation or is very

hazardous.

Where the assessment is considering biological agents (exposure to infectious people or

material) the risks associated with tissues and other waste materials removed from the
person should be assessed at each stage of handling. This includes specimens taken and
sent for analysis.

COSHH Essentials
The generic risk assessment guide The Technical Basis for COSHH Essentials: Easy Steps to
Control Chemicals from the Health and Safety Executive (HSE) can be used to carry out the
assessment. The assessment is based on:
• information on the hazard under the CLP system

• the amount used, whether it is:

 – small (grammes or millilitres)

– medium (kilograms or litres)

– large (tonnes or cubic metres).

• the dustiness of a powder

• the volatility of a liquid.

This allows the steps required to control exposure to be identified. It also provides detailed
advice and task sheets on control measures required for several common industrial
operations.
An electronic version of COSHH Essentials is available.
COSHH Essentials produces generic advice which may be sufficient for many assessments.
The legal requirement is that the risk assessment must be suitable and sufficient. The HSE
therefore recommends checking that the downloaded COSHH Essentials sheets fully
describe the task. Managers should think about how else they can use the advice to avoid
workers’ health being harmed.

Control Measures
After the risks to health from the hazardous substances in use have been established,
decisions have to be made about the measures required to prevent or control exposure. If
there are a significant number of problems, the necessary actions will need to be
prioritised.
There are a range of measures that can be used to prevent or reduce exposure. In order of
priority, the measures include:
• avoiding use of the hazardous substance

• altering process design and working procedures

• altering engineering controls

• if control measures cannot be achieved by other means, the use of personal protective
equipment (PPE) in addition to the other measures.

The selection of the control measures should be proportionate to the level of risk.

Curricular activities
Control measures will need to be put in place for certain curricular activities.
• Control chemical fumes from experiments.

• Keep hazardous chemicals and substances, solvent-based adhesives, paints, stains,

varnishes, stripping fluids, etc in locked cupboards.
• Fit dust extraction to circular saws, planers, band-saws and sanders.

• Reduce exposure to dusts from hardboard, plywood, MDF, timber laminates, etc. to the
lowest level reasonably practicable (ie as far below the workplace exposure limit of 5
mg/m³ as is reasonably practicable).

• Use effective local exhaust ventilation to control welding fumes and dust from
grinders.

• Ensure acid solutions are only be made up by a competent person, using appropriate
gloves, protective clothing and chemical-grade eye and/or face protection.

• Store corrosives in a low-sited, ventilated and lockable cupboard, lined with acid-
resistant material.

Guidance on the safe use and control of hazardous substances in the curriculum can be
obtained from CLEAPSS or the Association of Science Education. Information on controlling
the risks in woodwork from exposure to wood dust is available from the Health and Safety
Executive (HSE).

Chemicals
Any school that holds hazardous chemicals must by law ensure they are purchased, stored,
used and disposed of in a safe and secure manner.
The HSE, in collaboration with CLEAPSS and the Home Office, has produced additional
guidance, SYC. Secure Your Chemicals: Education. The guidance is accompanied by a Code of
Practice and a quick reference card.
The Code of Practice states that:
• chemicals should be locked away until needed

• hazardous chemicals held in storage must be carefully monitored and a full stock list
kept

• formal stock checks should be carried out, as well as informal ones that are done on a
daily basis as chemicals are supplied for, and used in, lessons

• schools should be able to account for all hazardous chemicals kept on site

• when chemicals are removed from storage for use, it should be noted how much has
been removed and how much has been used and/or returned

• laboratories should be checked for any substances that have been left behind

• hazardous chemicals should be disposed of properly, using a suitably authorised

disposal service

• waste chemicals should be stored securely before disposal

• the ordering of chemicals should be limited to essential and authorised personnel

• effective record keeping should be in place so that an audit trail is established

• access to hazardous chemicals should be restricted and those who do have access
should be properly trained.

Hazardous chemicals are usually sold by companies who belong to professional

associations such as the Chemical Business Association (CBA). Any school that is concerned
about a company mis-selling chemicals should contact CLEAPSS or the CBA.
The SYC Code includes a list of chemicals of particular security concern. If any of these go
missing, schools should notify the police.

Principles of Good Practice

Exposure should be controlled by implementing the following principles of good practice.
• Design and operate processes and activities to minimise emission, release and spread
of substances hazardous to health.

• Take into account all relevant routes of exposure, eg inhalation, skin absorption and
ingestion when developing control measures.

• Control exposure by measures that are proportionate to the health risk.

• Choose the most effective and reliable control options to minimise the escape and
spread of substances hazardous to health.

• Provide suitable PPE in combination with other control measures where adequate
control of exposure cannot be achieved by other means.

• Check and review regularly all elements of control measures for their continuing
effectiveness.

• Inform and train all employees the relevant staff on the hazards and risks from the
substances with which they work and the use of control measures provided to control
the risks.

• Ensure that the introduction of control measures does not increase the overall risk to
health and safety.

Avoiding Use of Hazardous Substances

Avoiding the use of hazardous substances should prevent exposure. This can be achieved
by:
• modifying the process so use of the substance hazardous to health is not required, ie
elimination

• substituting the substance with a less hazardous alternative.

Different physical forms of substances that do not present a hazard can be used. The most
common example of this is the substitution of hazardous dusty substances which can be
inhaled, with a pellet form of the substance.

Process Design and Working Procedures

Typical process design and working procedural measures that the employer should
consider when selecting the control measures that are required include the following.
• Arrangements for the safe handling, storage and transport of substances hazardous to
health. (This should be applied not only to hazardous substances used at work but also
to handling and disposal of waste containing such substances.)

• Adoption of suitable maintenance procedures.

• Reducing the following to the minimum.

– The number of employees subject to exposure (this could include excluding

non-essential employees and reducing the need for maintenance staff to go into
hazardous areas).

– The level and duration of exposure.

– The quantity of substances hazardous to health present at the workplace. The

amount of hazardous substances used, produced and held in stock should be
kept to a minimum. Processes should be designed to keep the production of
hazardous dust, fume, vapour or biological agent to a minimum.

• Control of the working environment. This could include totally enclosed processes and
handling systems, limiting the area contaminated by containing spills and leaks,
providing ventilation in the form of partial enclosure with local exhaust ventilation
(LEV), and sufficient general ventilation.

• Appropriate hygiene measures. This could include prohibition of smoking (including

e-cigarettes), eating and drinking when substances hazardous to health are used,
adequate facilities for washing, changing, and storage of clothing and personal
protective equipment, and regular cleaning or disinfection of contamination from
walls, surfaces, etc.

Personal Protective Equipment

Personal Protective Equipment (PPE) should only be used if the other control measures
cannot give sufficient control of exposure.
The PPE must be:
• suitable for controlling exposure adequately

• properly stored
• checked at suitable intervals

• repaired or replaced if found to be defective.

Employees should be trained on how to correctly use and look after the PPE to be used by
themselves and pupils.

Recording the Results

If five or more people are employed, the significant findings of the assessment must be
recorded. Even if there are fewer than five employees, it is still good practice to record the
results.
There is no specific format for records, but the justifications for the level of risk assigned
and the measures selected need to be shown. The degree of detail will depend on the level
of risk and the detail with which the assessment was carried out.

Risk Assessment Review

The assessment should be reviewed at regular intervals, and immediately if there is reason
to suspect the assessment may no longer be valid, eg:
• if there is a change in the process

• if defects in the system are reported, particularly if there has been an accident or
incident

• as a consequence of results from monitoring exposure, examination or testing of

engineering controls or health surveillance.

• as a consequence of illness or injury.

• if there is a change in legislation.

Where, as a result of the review, changes to the risk assessment are required, those
changes must be made.

Exposure Monitoring
Monitoring is the measurement of an employee’s exposure to substances hazardous to
health and should be carried out if:
• the assessment indicates there could be serious risks to health if control measures fail
or do not work properly

• exposure limits might be exceeded.

Monitoring is not necessary if the employer can show exposure is prevented or adequately
controlled by other means of evaluation. However, monitoring must be carried out if
employees are exposed to certain substances specified in COSHH.
Airborne Sampling
Most monitoring involves measuring the airborne concentration of a substance in the
employee’s breathing zone, using personal sampling equipment. Air can also be sampled in
the workplace using static sampling.
If the objective of sampling is to measure the relative importance of different sources of
emissions in an area, it may be adequate to collect a number of samples using static
sampling devices. More often, the objective is to measure personal exposure, in which case
it is necessary to collect the samples with personal sampling devices fitted to the breathing
zone of the operator.

Biological Monitoring
Biological monitoring can also be used, particularly if there is likely to be:
• significant skin absorption

• significant uptake following ingestion of the chemical

• control of uptake dependent on PPE.

Biological monitoring involves taking samples of breath, blood or urine.

The accumulation of the substance or its metabolites (substances the body converts the
chemical into) are analysed from the sample.
There has to be clear criteria for interpreting the results. The HSE has established a system
of non-statutory biological monitoring guidance values to provide an authoritative guide to
the interpretation of biological monitoring results. There is no requirement in the COSHH
Regulations for compliance with these values.
Biological monitoring involves measurements of samples collected from individuals, so it is
essential the rights of the individual giving the sample are safeguarded and confidentiality
maintained.

Records
Records of exposure monitoring must be kept for at least 5 years, and if the record is for an
individual employee, it should be kept for at least 40 years.
It is suggested that the records are separated into five sections as follows.
1. Substance/process information: This section should contain information about each
substance used and each process identified as generating harmful substances. The
section should contain the substance identification records, process identification
records, copies of the safety data information, any other relevant information which
may be useful in making an assessment of exposure and the substance purchase
records.
2. Assessment area: This section should contain information for each area in which an
assessment of the exposure to substances hazardous to health is made. The area
assessment records, maintenance procedure assessment records, emergency
procedure assessment records, the records of any surveys or air monitoring carried
out in the area and the reassessment records should be stored here.

3. Engineering control measures: The section on should contain information for each
item of equipment provided to control exposure to a substance hazardous to health.
This would include records of commissioning and testing of LEV, containment
cabinets, glove boxes and similar engineered control measures.

4. Personnel: This section should contain the records for each member of staff who
works in an area where substances hazardous to health are used. This may include
records of issue and training in use of personal protective equipment (PPE) and
provision of information on hazardous substances.

5. Health surveillance: Additional records should contain a folder for each member of
staff who works in an area which is the subject of an assessment of the exposure to
substances hazardous to health. The folders contain the individual’s sickness record,
the records of any medical tests and examinations carried out, the job/workplace
record, the PPE training, issue and maintenance records, the information issue records
and an acute exposure record.

The format of the records and the level of medical surveillance necessary will be controlled
by the organisation’s medical advisors.

Brought forward
“Brought forward” is an optional filing system designed to work as an aide memoire to the
person responsible for COSHH implementation. The maintenance of the records, together
with the necessary testing and procedures, requires organisation on the part of those
responsible to ensure that items are not overlooked.
Use of the brought forward record system requires each action (or set of actions) required
under the regulations and the date on which it is completed to be entered on a separate
sheet. The sheets are filed in chronological order so that the next action required for
maintenance of the system is always at the front of the file. On completion of the required
action, the sheet is discarded or, if it has to be repeated, the action is again entered on the
sheet, which is reinserted into the brought forward file in chronological position.

Health Surveillance
Health surveillance puts in place systematic, regular and appropriate procedures to detect
adverse changes which may be attributed to exposure to substances hazardous to health at
an early stage or to assist in the evaluation of the suitability of control measures or the
evaluation of hazards. (The common one in dentistry is mercury.) The results are then
acted on. This is one of the most effective methods of monitoring.
Health surveillance will be appropriate if:
• there is exposure to a substance known to damage health in some particular way

• there are valid ways to detect the disease or condition

• an employee is found to be suffering from an illness or infection which is suspected to

be the result of exposure at work (in this case other employees who have been
similarly exposed should be placed under suitable health surveillance until it is
established that they are not affected)

• it is reasonably likely that damage to health may occur under the particular conditions
at work.

Training
Employers must provide employees with suitable and sufficient information, instruction,
training and supervision. This should include:
• details of the substances hazardous to health that they are likely to be exposed to,
including:

– the names of the substances

– the risks they present to health

– any relevant workplace exposure limit

– access to relevant safety data sheet

• the significant findings of the risk assessment

• the actions and precautions necessary to safeguard against exposure

• the results of monitoring of exposure or medical surveillance

• the collective results of medical surveillance; these should be in a form that does not
allow results to be attributed to a specific individual.

Control measures will not be effective unless employees are trained to use them correctly.
Employees should be provided with information on:
• the purpose of health surveillance, the duty of employees to attend for health
surveillance on the appointed time and date and arrangements for employees to have
access to their individual health records

• when to use the hygiene facilities provided

• any information resulting from a review of the assessment, why it was done and how
any changes will affect them in future

• any procedures for dealing with accidents, incidents and emergencies.

The extent of information, instruction and training will depend on the nature of the
hazards, risks, processes and controls. It should be determined by the risk assessment and
should be proportionate to the risk.
Employers must provide additional information and instruction to any person who may be
required to work with a substance hazardous to health, including both employees and
others under their control. This duty would include, for example, instructing a maintenance
contractor in the hazards of substances that may be present in ventilation ducts or drains,
and of the precautions that should be taken.
There are many options for providing information, instruction and training. It may take the
form of formal or informal tuition, be in-house or external, be on-the-job training or use
leaflets or videos, etc. It must be comprehensible and appropriate for the work situation,
and must be updated whenever there are changes.

List of Relevant Legislation

• Data Protection Act 2018

• Health and Safety at Work, etc Act 1974

• Ionising Radiations Regulations 2017

• Control of Substances Hazardous to Health (Amendment) Regulations 2004

• Control of Substances Hazardous to Health Regulations 2002

• Dangerous Substances and Explosive Atmospheres Regulations 2002

• Education (School Premises) Regulations 1999 (Wales only)

• Management of Health and Safety at Work Regulations 1999

• Regulation (EC) No. 1272/2008 on the classification, labelling and packaging of

substances or mixtures (CLP Regulation)

• Regulation (EC) No. 1907/2006 on the registration, evaluation, authorisation and

restriction of chemicals (REACH Regulation)

Further Information
Publications
HSE Publications
The following are available from HSE Books.
• EH40/2005 Workplace Exposure Limits: Containing the List of Workplace Exposure
Limits for Use with the Control of Substances Hazardous to Health Regulations 2002 (as
amended)
• HSG97 A Step by Step Guide to COSHH Assessment
• HSG167 Biological Monitoring in the Workplace: A Guide to Its Practical Application to
Chemical Exposure
• HSG173 Monitoring Strategies for Toxic Substances
• HSG220 Health and Safety in Care Homes
• INDG136 Working with Substances Hazardous to Health. A Brief Guide to COSHH
• INDG307 Hydrofluoric Acid Poisoning: Recommendations on First-aid Procedures
• INDG463 Control of Exposure to Silica Dust: A Guide for Employees
• L5 Control of Substances Hazardous to Health. The Control of Substances Hazardous to
Health Regulations 2002 (as amended). Approved Code of Practice and Guidance
• MS32 Guidance for Appointed Doctors on the Control of Substances Hazardous to Health
Regulations 2002 (as amended)
• Microsite for Control of Substances Hazardous to Health (COSHH)
• Microsite for Health Surveillance
• The Technical Basis for COSHH Essentials: Easy Steps to Control Chemicals

British Standards
The following is available from the BSI Shop.
• BS EN 481:1993, BS 6069-3.5:1993 Workplace Atmospheres, Size Fraction Definitions
for Measurement of Airborne Particles
• BS EN ISO 14123-1:2015 Safety of Machinery. Reduction of Risks to Health Resulting
from Hazardous Substances Emitted by Machinery. Principles and Specifications for
Machinery Manufacturers

Other Publications
• Care Certificate Framework (and Supporting Documents), available on the Skills for
Care website
• Guidance for Providers on Meeting the Regulations (2015)
• Hazcards, CLEAPSS

• How CQC Regulates: Community Adult Social Care Services — Appendices to the Provider
Handbook (2015), Care Quality Commission, available on the CQC website
• How CQC Regulates: Community Adult Social Care Services — Provider Handbook
(2016), Care Quality Commission, available on the CQC website
• How CQC Regulates: NHS GP Practices and GP Out-of-hours Services — Provider
Handbook (2016), Care Quality Commission, available on the CQC website
• How CQC Regulates: NHS GP Practices and GP Out-of-hours Services — Appendices to the
Provider Handbook (2015), Care Quality Commission, available on the CQC website
• How CQC Regulates: Residential Adult Social Care Services — Provider Handbook (2016)
• PS021 Health and Safety in the School Laboratory and the New Science Teacher,
CLEAPSS
• REACH and the Teaching of Practical Chemistry, CLEAPSS in collaboration with the
Royal Society of Chemistry, the Association for Science Education, the Scottish Schools
Education Research Centre
• Secondary Science Laboratory Handbook, CLEAPSS
• Secure Your Chemicals: Education, CLEAPSS in collaboration with the Home Office and
the HSE
• Student Safety Sheets (2016), CLEAPSS
• Subsport, an EU-backed Chemical Substitution Support Database Portal, featuring
more than 200 case studies on safer alternatives to hazardous chemicals

Organisations
• Association of Science Education (ASE)

• http://www.ase.org.uk
• As the professional body for all those involved in science education, from pre-school to
higher education, the ASE promotes excellence and provides a national support
network for teachers and other staff.

• British Occupational Hygiene Society (BOHS)

• http://www.bohs.org
• The BOHS seeks to promote and protect occupational and environmental health and
hygiene and offers training in occupational hygiene and related subjects.

• British Standards Institution (BSI)

• http://www.bsigroup.com
• The BSI develops, publishes and offers independent certification services for the UK,
the EU and international standards.

• Chemical Hazards Communication Society (CHCS)

• http://www.chcs.org.uk
• The CHCS is a professional society for those involved in chemical hazard
communication.

• Chemical Industries Association (CIA)

• http://www.cia.org.uk
• The CIA is the UK’s leading trade association for the chemical and chemistry-using
industries, representing members both nationally and internationally.

• CLEAPSS

• http://www.cleapss.org.uk/
• CLEAPSS provides support in science and technology for a consortium of local
authorities and their schools, including establishments for pupils with special needs.
Independent schools, post-16 colleges, teacher training establishments, curriculum
 developers and others can apply for associate membership. CLEAPSS secondary school
science resources can be found at www.science.cleapss.org.uk.

• D&T resources appear in a website at dt.cleapss.org.uk. Primary school resources can

be found at primary.cleapss.org.uk. A CLEAPSS helpline is available on 0189 525 1496.

• Health and Safety Executive (HSE)

• http://www.hse.gov.uk
• The HSE is responsible for the regulation of the risks to health and safety arising from
work activity in England, Scotland and Wales, except in certain businesses (regarded
as lower risk), which are the responsibility of local authorities. Its roles are to prevent
work-related death, injury or ill health.

• Institution of Occupational Safety and Health (IOSH)

• http://www.iosh.co.uk
• IOSH is Europe’s leading body for health and safety professionals and provides
guidance on health and safety issues, with over 44,000 members worldwide.

• Royal Society of Chemistry (RSC)

• http://www.rsc.org
• The RSC is the UK professional body for chemical scientists and an international
Learned Society for the chemical sciences. It is a major international publisher of
chemical information, supports the teaching of chemical sciences at all levels and is a
leader in bringing science to the public.

• Scottish Schools Education Research Centre (SSERC)

• http://www.sserc.org.uk
• SSERC provides science and technology support across Scottish education authorities,
including to further education colleges and independent schools.

Source URL: https://infoservice.britsafe.org/topics/coshh/indepth

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