Risk Assessments - Under the COSHH?

Malcolm Gardnerin Consultancy

When people discuss the completion of risk assessments, whether they are activity or chemical based, it is the perceived mountain of paperwork that usually stops people in their tracks. But that need not be the case.

If you were completing a build project of a new 3G football pitch, I would expect that most of you would not be throwing your arms in the air and claiming that the world is against you. But, like it or not, paperwork is part and parcel of what both managers and individuals have to complete.
In this article, I will set out some of the ideas and methods that I have worked to in the past, and hope that they will take some of the pain out of what some percieve as a chore.

First and foremost, don't feel that you have to be chained to the desk for days on end completing the paperwork until you have an assessment for every single substance that you have and use in your working environment. It is your ultimate goal, for sure, but a measured approach will soon see you through the task and, in time, you will have built your library of assessments succesfully without the pain. This also has a good side effect, assuming that you have chosen to review your assessments either every 12 months or 24 months, they will not come up for review all at once.

Secondly, get help. If you have a large team, involve others in your assessments. In such cases you could turn the task over to an assessment team, but remain as the assessment supervising officer. It gets other people involved and interested in the provision of safe working environments.

Thirdly, work to a system. The purpose of a COSHH assessment is to identify substances and activities where there may be exposure to a hazardous substance, whether used or generated, that could damage health. Where there is an identified risk, action must be taken to eliminate exposure or, at least, reduce it to acceptable levels, for example controlling and limiting the exposure to dust and fumes, ensuring they fall below the occupational exposure limits laid out in the 'Manufacturer's Safety Data Sheet'.

In the situation of turf management, a COSHH assessment will generally come in the form of an activity based assessment and often arises from spraying activities. Do not forget though, any of the other activities associated with the use of substances - cleaning equipment with solvents, filling mowers with petrol, using correction fluid in the office etc.

  • Gather information
  • Assess the information
  • Make informed decisions to reduce risks to health and the environment

Gathering Information

Complete a product inventory and, for each product, look at obtaining a Manufacturer's Safety Data Sheet. Manufacturers have to supply these by law and they will have a good deal of information on them that will help you to make your assessment. Keep them on file where they can be easily accessed.
Assessing the Information

This now becomes the most important part of the assessment. With all the information to hand you could make your assessment subjectively or it could be calculated. Whichever way you do it, you will need to ensure that you have assessed the pertinent factors involved, and show some written evidence of how you have reached your final outcome.

Basically, you will need to assess the factors and identify whether the activity/chemical:

  • is safe to operate/use
  • needs better control (such as ventilation) or operator protection (PPE)
  • is a significant hazard to health to warrant special containment (restricted access)

To make a subjective decision can be difficult, particularly if you are not used to thinking through the implications of using one chemical over another. But, there are some calculations that you can perform that will help you to understand at what point you should be concerned, and at what point you should be taking action.

Making A Calculated Assessment

To make a calculated assessment we will need to quantify:

  • The overall exposure potential
  • Damage potential

With the first three of the factors below used to calculate the overall exposure potential, followed by the fourth that is used to determine the damage potential, we can make a reasonable overall assessment.

  1. Quantity being used - handling and using a large quantity of a substance hazardous to health presents a much greater risk than a small quantity under similar conditions of handling and use

  2. Physical form of the substance - under the conditions of use, handling a fine dust or a volatile liquid presents more of an inhalation risk than handling a dense solid or a non volatile liquid

  3. Containment of the substance - a low containment process (open) presents a greater risk of exposure than a high (closed) containment process, such as an induction system on a sprayer

  4. Damage potential of the substance - how toxic or corrosive it is

For each of the four factors above, a hazard rating can be applied and multiplied in use to give a quantitative figure which, in turn, gives an indication of the overall risk of damage to health from any substance being assessed. This approach provides an objective, rather than a subjective, appraisal based on the calculation made.

Calculating the Exposure Potential

1. Quantity being used. Quantities may be of less than a few ml of substance (use of a small quantity of typewriter correction fluid) to any number of litres, particularly when spraying a number of hectares on your grounds with a liquid fertiliser. Using a few ml of a hazardous substance will represent much less of an exposure risk than using one or more litres. The variation of quantity can be expressed by a hazard rating factor of 10 in each case:

2. Physical form of the substance. Identifying the physical form of the substance being assessed is important, as a dense solid is less likely to be less hazardous to health than fine dust. Each different physical characteristic can be expressed again by a hazard rating factor of 10 as follows:

3. Containment of the substance. The containment of a substance in storage and use can vary depending on the substance and activity. Some activities are inherently better at containing a hazardous substance/s than others. The variation in containment and the associated exposure hazard rating can be expressed by a factor of 10 as follows:

Calculating the Overall Exposure Potential can be carried out thus:

"Quantity" x "Physical Form" x "Containment", the sum of which can be used against the table below to give an overall rating

4. Damage potential. Finally, we need to categorise the damage potential of the substance and this is where the Manufacturer's Safety Data Sheet comes in handy. Manufacturers have a great deal of knowledge about the hazardous properties of the substances they supply, and a substance will often be given a "CHIP" classification characterised by the hazard symbols found on a label.

For a full list of and description of the CHIP symbols, along with a full list of risk phrases and safety phrases, visit the HSE site at http://www.hse.gov.uk/chip/phrases.htm

Some products may contain more that one chip category, in which case for the purposes of making a calculated assessment you need to assess the substance within a product that has the highest CHIP rating:

Having identified the overall exposure and damage potential, the risk of damage from the combination of the two can now be be expressed numerically between 1 and 3 from the table below, and used as guidance on what controls are required to reduce any risks to health and the environment involved with using the assessed substance:

If the risk of damage is:

  1. The activity is probably safe to continue without changes, consider the need for appropriate personal protective equipment where accidental exposure may occur.

  2. Action required to reduce the risk. Select personal protective equipment as a short term solution while investigating other long term solutions.
    1/2. Action may be required to reduce the risk. Consider carefully the factors that have the potential to damage health and/or levels of exposure, and look at ways to control the risks further. Decide if the weighting is towards the Low or High category and act to reduce the risks accordingly.

  3. Take immediate action to reduce the risk. Consider changes to the control measures that need to be made to bring the risk rating down to an acceptable level. Activities may need to be suspended until adequate controls have been established.

Putting this into practice

There are many forms out there, from the very complicated to the very simple. For more details and a greater in depth look at COSHH Assessments, including some sample forms, take a look at the HSE COSHH assessments page at http://www.hse.gov.uk/COSHH/index.htm
COSHH Screenshot.jpg

Some parts of your COSHH assessment may require you to then look at how you control your handling of the substance, the PPE that you specify and, more importantly, if you have considered the substitution of a substance with less risk attached to it.

In Summary

Remember, I stated earlier that you do not need to rush in and do all your assessments at once, and that is true. If you have completed an inventory of all the products that you use then you will, no doubt, have some idea of the ones that you use that concern you the most, some that you use more often than others and those that you have noticed that have a great big skull and crossbones on the label, which indicates to you that it needs particular care in use.

Those are the ones that you will need to concentrate on first, and then migrate on to the rest as and when they come up for use. If you can complete just one assessment this week it will be a start, then do another next week or a couple the week after, and you'll be surprised at how quickly they build.

I hope that this has given you an insight into how you might carry out an assessment of your own. Personally, I devote the first Tuesday of each month to carrying out my assessments and you know, they don't seem such a hard thing to accomplish.

Malcolm Gardner, Grounds Manager, BA Clubs
Article Tags: