Who is Responsible for COSHH in the Workplace?
Updated: Jul 19, 2019
COSHH was created to protect people from hazardous substances, but who is responsible for ensuring it happens? The easy answer is.. Everybody!
The employer's COSHH responsibilties Yes, if you're the employer, then the onus is mostly on you. You must not only make sure everybody can do their work safely, but also make sure they are all doing their part to abide by the COSHH regulations.
You will carry out COSHH risk assessments throughout your site, installing control measures where necessary, to protect your employees from exposure to hazardous substances. You will also inform your employees of the dangers of the work they do, and train them to safely do it using the proper tools and control measures. The full list of your responsibilities under the COSHH regulations, as an employer:
Perform COSHH risk assessments,
Eliminate or control exposure to hazardous substances,
Implement control measures,
Monitor and review control measures,
Monitor and review exposure levels,
Monitor employee health,
Inform and train your employees in correct chemical safety procedures,
Design, and implement, plan for emergencies, incidents and accidents.
Perform COSHH risk assessments
Your first COSHH responsibility as an employer is to conduct risk assessments across your workplace. This involves you and your safety team identifying the hazardous substances you use, or produce, in your work processes. Once you know which substances are in use, you are then able to assess the risk.
Eliminate or control exposure to hazardous substances The COSHH regulations call on every employer to "ensure that the exposure of his employees to substances hazardous to health is either prevented or, where this is not reasonably practicable, adequately controlled.
It's never going to be possible to completely remove the risk from some jobs, but it will always be possible to control those risks. Your second responsibility as an employer is to ensure that you do everything in your power to properly control each and every hazard in your workplace. You can apply the hierarchy of COSHH control measures to identify which controls are applicable for each work station:
Personal protective equipment.
The important thing is that if the risk cannot be eliminated, it must be controlled.
Implement control measures Putting the control measures in place is only the first step in your third responsibility as an employer under the COSHH regulations. It's your job to ensure your workers use the control measures you implement. It's also your job to ensure they receive the needed training. They need to understand why the control measure is being installed, and how to properly use it. Unfortunately, this step often requires enforcement, because some people will fight against the need to use personal protective equipment. Even when they know it's going to save their eyes. Do not be afraid to enforce it. Allowing your employees to flaunt these regulations makes you an accomplice to their COSHH breaches, in the eyes of the Health and Safety Executive.
Monitor and review control measures As with your employees and their PPE, control measures are only going to work for as long as they are used. The control measures you implemented need to be reviewed, maintained and cleaned regularly. This includes regular testing and examination of each and every control measure on your site.
Monitor and review exposure levels Your responsibilities do not end there. Workplace monitoring is another of the most important parts of the COSHH regulations.
It requires you to regularly examine the atmosphere of your workplace, and the personal area surrounding your workers, to ensure that you're not exceeding workplace exposure limits.
Monitor employee health Monitoring your employees health is critical to ensuring you meet the regulations. COSHH was designed specifically to protect people's health from hazardous substances. Several of those substances are classified as high-risk and require special attention. Monitoring employee health, or health surveillance, involves you constantly monitoring the well-being of your employees. This is generally done through regular on-site checkups through a doctor or nurse who is present specifically for this reason. If problems arise then it may be necessary to move the employee to a job with no exposure, or to send them for further medical attention until they are deemed in no more danger from the hazardous substance.
Inform and train your employees in correct chemical safety procedures One of the last - but arguably one of the most important - responsibilities you have as an employee is the proper training of your employees. There are things your employees absolutely need to know if they're going to be able to do their job efficiently, and safely. You are obligated to inform them which substances they will be exposed to, how much they can be exposed to over their work period, and the steps you have taken to eliminate or reduce their risk to acceptable levels.
Once they know the dangers and how you are protecting them, it's necessary to properly train them how to do their job, and how to properly handle each control measure, where applicable.
Design, and implement, a plan for emergencies, incidents and accidents There is only so much you can do to protect your workers. You are human, after all. And, like every other human, you might miss something from time to time.
There will always be unforeseeable failures in control measures, or incidents that appear to come from nowhere. You need to accept that, sometimes, an accident or emergency is going to happen. It's a given. But when that accident or emergency involves hazardous substances, the stakes rise quite considerably. As you know, many of the substances your workers use every day are dangerous. Some of them can kill you simply by breathing them in, others are flammable and explosive. What's the worst that could happen? Well, that's for you to determine. As an employer your last responsibility is to put into place a set of procedures to guide your management team and workers when something catastrophic happens. As an example; You run a chemical storage facility and one of your storage tanks fails. A massive crack appears along one side and the substance inside begins to leak out. How will you minimise the exposure to your workers and the environment? How do people exit the area quickly, and safely? What should already be in place to minimise the effects of the leak? It would depend on the exact circumstances, but for this example, you would already have installed a bund, prior to filling the tank. This will ensure the leakage cannot pass a certain point. Ensuring anyone in the surrounding area is kept away from the hazardous substance. It's likely you would have already installed extraction and ventilation systems, too. You know that the fumes released by the substance are toxic to human health and if an incident were to happen, those fumes would need removing quickly and efficiently. Your emergency plans should include exit routes and roles for each person. Whether that is guiding others, tackling the leak, or just removing themselves from the building as quickly, and safely, as possible.
The employee's COSHH responsibilities If you're an employee, then you are obligated to follow the chemical safety guidelines and use the control measures put into place by your managers. While your employer plays the critical role of risk assessor, your job is probably more important.
As an employee you spend most of your time on the shop floor, with eyes on the hazards you work around. A very important part of COSHH safety is the reporting of incidents, near-misses or new hazards. You are the best person to spot failures, and potentially new hazards, pertaining to the equipment and control measures you use on a daily basis. The full list of your responsibilities under the COSHH regulations, as an employee:
Make use of control measures put into place,
Ensure equipment is returned and stored in the correct designated storage area,
Report inadequate or defective equipment and control measures,
Make use of, and care for, all provided personal protective equipment (PPE),
Remove contaminated PPE, in a specified area, before interacting with people or taking in food or drink,
Make use of all provided wash facilities, where applicable,
Adhere to all COSHH training and information provided for you.
Make use of control measures put into place Your employer installs control measures specifically to keep you, and your colleagues, safe from harm from hazardous substances. Your first responsibility as an employee, then, is to ensure you use and abide by any and all control measures implemented in your workplace. You're obligated by law to protect yourself, and others, by following the proper procedures designed to minimise risk of exposure.
Ensure equipment is returned and stored in the correct, designated area Returning the equipment you use to it's proper place ensures that it will not be damaged inadvertently. Tracking and storing your equipment in specific areas also allows your employer to ensure it's properly maintained and kept safe for you when you need it.
Report inadequate or defective equipment or control measures Using inadequate or defective equipment to perform your work increases the risk of exposure you face. Ensure you report any and all defects immediately. Your employer already conducts regular equipment checks and maintenance, but it's entirely possible that their assessments missed something. When you spot a defect, immediately report it.
Make use of, and care for, all provided personal protective equipment Personal protective equipment is designed to protect those parts of you where harm would be life-changing. It's also the last line of defence you have against all those hazards you face daily. Your employer spends a lot of time and resources on ensuring your safety while you do your work. PPE isn't cheap and it's there for a reason. To keep your body in one piece. Never refuse to use the PPE your employer provides. You needlessly endanger your own safety and it is a direct breach of the COSHH regulations, Your employer has every right to discipline you and the HSE has every right to prosecute you, if they deem your actions dangerous.
Remove contaminated PPE, in a specified area, before interacting with people or taking in food or drink You are obligated to not only keep yourself safe, but everyone else in the building too. Removing your contaminated PPE will ensure most, if not all, of the hazardous substance is left behind, where there are control measures in place. It will also come nowhere near your colleagues who could breathe it in or ingest it, if you removed it during your lunch, for instance
Make use of all provided wash facilities, where applicable
Tying in with removing contaminated PPE is ensuring you wash your body thoroughly. A lot of the work that involves hazardous substances are dirty jobs. You may be covered in oil, dust and smelling of fumes at the end of your day. It's important to clean yourself thoroughly to ensure you do not contaminate locations you visit after work. These wash facilities are also designed specifically to remove the contamination from you, ensuring you are kept safe from the hazardous substance when you leave work.
Adhere to all COSHH training and information provided to you As with personal protective equipment, the training and information given to you by your employer is designed specifically to keep you safe from harm when doing your job. You have an obligation under the COSHH regulations to abide by the training and information you were given in order to do your work safely.
Learn all about those obligations by taking the free COSHH Risk Assessor Certification™.