H&S02_03_V4 - Page No.1 summary Control of Substances Hazardous to Health document control Responsible Author Sig for Sig for RB Issue Date Review Date Director CFO/CE ACFO B Hoad October 2013 October 2016 Related documents Health and Safety at Work, etc. Act 1974 Management of Health and Safety at Work Regulations 1999 (as amended) Control of Substances Hazardous to Health Regulations 2002 (as amended) Chemicals (Hazard Information and Packaging for Supply) Regulations 2009 Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) (as amended) EH40/2005 - Workplace Exposure Limits Control of Asbestos Regulations 2012 Control of Lead at Work Regulations 2002 Ionising Radiations Regulations 1999 Personal Protective Equipment at Work Regulations 1992 (as amended) Environmental Protection Act 1990 Hazardous Waste (England & Wales) Regulations 2005 Health & Safety (Safety Signs and Signals) Regulations 1996 Health & Safety (First Aid) Regulations 1981 Safety Representatives & Safety Committees Regulations 1977
H&S02_03_V4 - Page No.2 summary Related manuals H&S 01_01 (H&S Management System) H&S 01_03 (Management of Safety Events) H&S 02_02 (Biological Hazards) H&S 02_13 (The use of Personal Protective Equipment (PPE) at Work) OPS (F) 01_04 (Agricultural Dusts (Respiratory Hazards & Explosions)) OP 02_05 (Fibre Hazards at Aircraft Incidents) OPS (F) 03_05 (Incidents at Poultry and Wildfowl Sites within Designated Avian Influenza Protection Zones) OPS (F) 10_02 (Hazardous Materials) OPS (F) 10_03 (Toxic Hazards Fires and other Occurrences involving Isocyanates) OP 03_01 (Breathing Apparatus) OPS (E) 05_03 (Limited life Gas Tight Chemical Protection Suits) OPS (E) 24_02 (3M Particulate Respirator (Type 9332)) OPS (E) 24_03 (Personal Protective Equipment for Firefighting and other Operational Events) OPS (E) 25_04 (Half Mask Respirator) HR 04_01 (Medical Reviews) 1 Summary 1.1 The Control of Substances Hazardous to Health (COSHH) Regulations 2002 (as amended) is the main piece of legislation covering the control of risks from chemical and biological hazards. The Regulations apply to all hazardous substances, except those as detailed within this Manual Note (3.2). The Regulations set out, within a single legislative framework, the steps that employers must take to control exposure of their employees arising out of or in connection with their work, and of non-employees who may be affected by their activities involving substances hazardous to health.
summary H&S02_03_V4 - Page No.3 1.2 A substance hazardous to health is any material, mixture or compound used at work or generated during work activities, which is hazardous to health in the form in which it occurs in the work activity. Categories specifically mentioned are toxic, very toxic, harmful, corrosive, irritant, sensitising, carcinogenic, mutagenic or toxic to reproduction, and substances which are assigned a Workplace Exposure Limit (WEL) as detailed in the Health and Safety Executive publication EH40. These groups of substances having the potential to cause harm to health within the workplace will normally be marked with a hazard-warning symbol. Appendix A describes these warning symbols in detail. 1.3 The COSHH Regulations 2002 (as amended) apply to all East Sussex Fire and Rescue Service s (ESFRS) activities, (emergency and non-emergency), and work carried out by contractors at the request of ESFRS. 1.4 The information contained within this document provides clear and concise roles and responsibilities of all employees of ESFRS in relation to the COSHH Regulations.
policy H&S02_03_V4 - Page No.4 2 Policy 2.1 ESFRS shall make suitable arrangements to prevent exposure of its employees to substances hazardous to health within the Workplace, and of others who may be affected by its undertakings or, where this is not reasonably practicable, to implement adequate control measures. 2.2 ESFRS shall ensure that suitable and sufficient risk assessments are completed for all substances hazardous to health in accordance with the Control of Substances Hazardous to Health Regulations 2002 (as amended) Regulation 6, and suitable controls implemented to eliminate or reduce exposure to an acceptable level. Risk assessments will be made available to all employees via the ESFRS Risk Assessment database. 2.3 ESFRS shall avoid, so far as is reasonably practicable, the use of a substance hazardous to health in the workplace by replacing it with a substance or process which, under the conditions of its use, either eliminates or reduces the risk to health. 2.4 ESFRS shall manage risks associated with hazardous substances in the workplace through the design and use of appropriate work processes, systems and engineering controls, provision of suitable work equipment and materials (including identified PPE), and by providing suitable and sufficient information, instruction and training given to employees. 2.5 ESFRS employees shall comply with this policy and procedure to ensure the health, safety and welfare of themselves and others who may be affected through their acts or omissions. 2.6 All employees are required to use hazardous substances in compliance with the control measures detailed on the relevant risk assessment. Employees who are
policy H&S02_03_V4 - Page No.5 required to be routinely exposed to hazardous substances will, where identified as appropriate, be provided with suitable health surveillance.
procedure H&S02_03_V4 - Page No.6 3 Procedure Scope of the COSHH Regulations 3.1 The Control of Substances Hazardous to Health Regulations 2002 (as amended) (COSHH) apply to the following:- Substances that have already been classified as being dangerous for supply under the Chemicals (Hazard Information and Packaging for Supply) Regulations 2009 Substances which have Workplace Exposure Limits (WELs) Biological agents Dusts of any kind when present at a substantial concentration in air Any other substance which, because of its chemical or toxicological properties and the way it is used or is present in the workplace, creates a risk to health. 3.2 The Regulations do not cover the following groups of substances listed below: Asbestos (The Control of Asbestos Regulations 2012) Lead (The Control of Lead at Work Regulations 2002) Where the substance is hazardous to health solely due to its radioactive, explosive or flammable properties, or solely because it is at a high or low temperature or a high pressure. Exposure to biological agents which does not arise out of the work activity itself (for example, where one employee catches a respiratory infection from another). 3.3 Responsibilities 3.4 The ACFO shall: Ensure suitable resources and training are available to enable ESFRS to discharge its duties under the Control of Substances Hazardous to Health Regulations 2002 (as amended).
procedure H&S02_03_V4 - Page No.7 3.5 The Strategic Health and Safety Advisor shall: Provide corporate advice in relation to the COSHH Regulations Ensure that suitable and sufficient risk assessments are available and reviewed in accordance with service procedures Ensure suitable management systems are in place for the effective discharge of duties under the COSHH Regulations in relation to procurement of hazardous substances Maintain a portfolio of all COSHH risk assessments held on the ESFRS Risk Assessment Data Base Monitor the adequacy of control measures in place Respond in accordance with the Service s Management of Safety Events in the event of any investigation involving exposure to hazardous substances. Monitor trends in relation to COSHH related incidents, providing feedback to the appropriate Director and / or the Health Safety and Welfare Committee Instigate and report upon business audits and reviews in relation to matters involving the management of hazardous materials that fall within the scope of this policy. Maintain on the ESFRS network a COSHH Product Data File held electronically that will contain COSHH Data (including Material Safety Data Sheets) for any item/substance handled, stored or used on those premises falling within the scope of COSHH. Consider the environmental impact when disposing of a substance, as detailed in the Hazardous Waste (England and Wales) Regulations 2005 Where necessary, in conjunction with the Service s Occupational Health Adviser, arrange appropriate monitoring of exposure and health surveillance of persons who may be at risk. The purpose of this is to detect as early as possible any changes which may have an adverse effect on a person s health Ensure monitoring of compliance with these procedures during visits to workplaces. Implement the Management of Safety Event procedures for any reported instance where an employee/contractor/visitor suffers ill health following exposure to a hazardous substance.
procedure H&S02_03_V4 - Page No.8 Review the arrangements for the management of hazardous substances within the Service on a three yearly basis. The review process will address any changes in legislation, occupational health reviews, new equipment, working methods and current issues. 3.6 The Head of Human Resources shall: Arrange for prospective support employees to complete the ESFRS Pre-Employment questionnaire. This requests medical information relevant to the condition of a person s health that may affect their ability to undertake work safely. (Uniformed personnel will be expected to declare any relevant information during their pre-employment medical) Arrange for all personnel have access to the Service Medical Advisor via the Occupational Health Provider at Fire Service Headquarters. When considered appropriate advice will be sought from the Occupational Health Provider and employees referred if necessary. Ensure records of health surveillance be kept in a suitable form for at least 40 years from the date of the last entry made in it Ensure, in conjunction with the Occupational Health Adviser, that appropriate health surveillance is initiated whenever necessary following exposure of personnel to hazardous substances. (See HR 04_01). 3.7 The Procurement Contracts and Insurance Manager shall: Liaise with appropriate Service Managers into the requirements / business case relating to the purchase of products that fall within the scope of COSHH, establishing the organisational needs for the product Establish if a product is hazardous prior to first purchase and investigate the availability of a less hazardous alternative product if available Not purchase, or allow to be purchased, any hazardous substance until such time as a suitable and sufficient risk assessment is carried out and a safe system of work is in place, and details have been communicated to those persons identified at risk. The pre-procurement document in Appendix D should be used for this purpose
procedure H&S02_03_V4 - Page No.9 Maintain a central stock list of all approved products as available through Procurement. Periodically review and update list as required. Ensure that appropriate manufacturers Material Safety Data Sheets (MSDS) are obtained from suppliers prior to purchasing for all relevant items/substances held on the Central Stock List, and to forward copies to the Health and Safety Department. Where any item on the Central Stock List falls within the scope of COSHH, the Procurement Contracts & Insurance Manager will liaise with the Service s Health & Safety Department to ensure that a COSHH risk assessment has been completed Liaise with the Service s Health & Safety Department regarding requests for COSHH assessments from their central database Consider the adequacy of any respiratory protective equipment (RPE) to control exposure to hazardous substances to which wearers are exposed. All such equipment must be CE marked. Ensure RPE is compatible with any other equipment worn and provide information on training requirements for employees. Consider the environmental impact when disposing of a substance as detailed in the Hazardous Waste (England and Wales) Regulations 2005 3.8 The Head of Engineering shall: Ensure that all requests for the purchase of substances / product that comes within the scope of the COSHH regulations are referred through the Procurement Contracts & Insurance Manager and not to allow any direct purchase without first liaising with Procurement and the Health and Safety Department. Ensure that suitable arrangements for the maintenance, examination and thorough testing of local exhaust ventilation systems are carried by a competent person at least once every 14 months and to maintain adequate records of such inspections. Ensure risk assessments are in place for all hazardous substances used/produced within workshops. Where a COSHH assessment is not in place for a hazardous substance, ensure an assessment is carried out in accordance with service procedures.
procedure H&S02_03_V4 - Page No.10 Maintain a safe system of work to ensure that the disposal of hazardous substances is undertaken in a safe manner in accordance with the Hazardous Waste (England & Wales) Regulations 2005 Ensure that suitable procedures are in place to deal with accidents, incidents and emergencies, including the provision of appropriate first aid facilities, in the event of an accident, incident or emergency related to the presence of a substance hazardous to health in the workplace Provide support to Service Training Centre staff on the qualitative test for BA. Ensure existing operational personnel have been subjected to an appropriate face fit test for all types of RPE. Carry out any necessary face fit tests for workshops staff and the Urban Search and Rescue Team. Maintain records of test results for all face fit tests on the "Facemask Donning & Face Seal Test Record Data Sheet". 3.9 The Estates Manager shall: Ensure, before any contractor commences work on Service premises that they have provided written evidence to show that they have appropriate systems in place to ensure compliance with COSHH and that risk assessments are in place. This will be ascertained as part of the selection process carried out by the Estates Department prior to awarding the contract. Ensure contractors (including cleaning contractors) working on Service premises provide MSDS for any hazardous substance that they bring onto the premises. Ensure that contractors and visitors be given suitable information regarding hazards and associated risks from hazardous substances or processes when on Service premises. Ensure appropriate delivery arrangements and suitable storage for hazardous substances have been agreed and arranged in advance.
procedure H&S02_03_V4 - Page No.11 Provide Service premises with adequate facilities to enable employees to maintain an appropriate standard of personal hygiene. These will include facilities for washing, changing, eating and drinking. Post appropriate safety warning signs where hazardous substances are stored or used. Signage shall conform to the Health & Safety (Safety Signs and Signals) Regulations 1996. 3.10 The Head of Learning and Organisational Development shall: Ensure Service Training Centre staff carry out face fit testing (with respect to new trainees) as part of BA Initial/Conversion courses. This applies to BA, 3M Particulate Mask and any other respirators brought into Service use 3.11 Borough Commanders shall: Enforce the arrangements, within their scope of responsibilities, to ensure compliance with the contents of this policy and procedure. Ensure that only approved substances are stored on the premises Only allow the use of hazardous substances that have had assessments undertaken and ensure that suitable measures are in place to control exposure Ensure that employees and visitors receive adequate information, instruction and training (regarding the risk from exposure to hazardous substance) and know when and how to use protective equipment provided Monitor and enforce the usage of personal protective equipment Liaise with the Health and Safety Department and the Procurement Contracts & Insurance Manager regarding the above as required 3.12 Station/ Workplace Managers shall: Ensure that no local purchase of hazardous substances takes place unless given prior approval by the Procurement Contracts & Insurance Manager Ensure that personnel use products correctly, following guidance on the relevant risk assessment
procedure H&S02_03_V4 - Page No.12 Ensure that all persons directly/indirectly under their responsibility that may use or come into contact with any hazardous substance are informed of the control measures required as detailed on the COSHH Risk Assessment Where doubt exists whether contractors are complying with COSHH when on site, not allow work to start or continue until satisfactory precautions have been taken. Advice on this should be sought in the first instance from the Estates Manager or the Health and Safety Department. Ensure employees wear the appropriate Personal Protective Equipment and that it is maintained in good working order Ensure that a physical check is made at least once a quarter during the quarterly health and safety inspection to ensure that no items / substances other than those held on the Central Stock List are stored or used on those premises. Advise Strategic Health and Safety Advisor of any discrepancies or non-compliance of this policy / procedure through current reporting processes contained within ESFRS Manual Management of Safety Events H&S01_03. Ensure that all substances are disposed of in accordance with the guidance contained in the manufacturer s Safety Data Sheet and Service risk assessments Ensure that all control measures are visually checked regularly, in line with standard active monitoring procedures, to ensure they are functioning properly Regularly undertake local monitoring to ensure the arrangements detailed in this operating procedure are implemented and followed within their area of control/responsibility. Any concerns should be communicated to the Health & Safety Department. Identify the training needs of staff. Employees should be given suitable information regarding any hazardous substances in the workplace. This should include the risks from a hazardous substance and how it should be used, transported, stored, disposed of, emergency procedures, etc. This information should be contained on risk assessments for specific substances. Ensure Manufacturers or Suppliers information on any label, packaging or container is followed.
procedure H&S02_03_V4 - Page No.13 Ensure employees receive suitable information and training during workplace induction. This should include: o The names of substances they work with or could be exposed to, and the risks created o The main findings of the risk assessments o The precautions they should take to protect themselves or others o How to use personal and respiratory protective equipment o Emergency procedures that need to be followed o That facilities to enable employees to maintain an appropriate standard of personal hygiene are suitably maintained. These will include facilities for washing, changing, eating and drinking. o Assessments for work carried away from Service premises should consider the above issues. 3.13 Incident Commanders shall: Where during the course of the risk assessment of an operational activity, it appears that personnel are likely to be exposed to any substance hazardous to health, (e.g. body fluids at RTAs, zoonoses at animal rescues, etc.), the assessors must take full account of the hazard and associated risk and ensure that appropriate and effective control measures are identified and documented where possible using the Service s analytical systems. Maximise organisational advice and support e.g. request for a Hazmat Officer (HMEPO) Feedback learning outcomes in relation to hazardous substances through the Service s debrief arrangements Monitor the safe disposal of harmful substances in accordance with the Hazardous Waste (England & Wales) Regulations 2005. 3.14 Employees shall: Use products in accordance with the instructions and training received
procedure H&S02_03_V4 - Page No.14 Follow manufacturers guidance read user label Follow information contained in risk assessments held on the Service s risk assessment data base Wear the appropriate Personal Protective Equipment provided Not bring to or use in the workplace any hazardous material that has not been authorised through the Service s COSHH risk assessment procedure Practice a high standard of personal hygiene Report all spillage or near hits immediately and initiate emergency procedures necessary where these occur Report any concerns, defects in protective measures or cases of ill health to their line manager. Keep RPE regularly cleaned and checked to ensure it remains effective, and stored away from sources of contamination when not in use. Report all accidental exposures of personnel to hazardous substances, either on Service premises or at operational incidents, using the Level 1 Safety Event Investigation Report form (see Manual Note H&SO1_03 The Management of Safety Events). Ensure that all substances are disposed of in accordance with the guidance contained in the manufacturer s Safety Data Sheet and Service risk assessments. 3.15 Control Measures The COSHH Regulations require employers to ensure that the exposure of employees to substances hazardous to health is either prevented or, where this is not reasonably practicable, adequately controlled. Whenever possible, this control should be achieved by measures other than the use of personal protective equipment. (Clearly at operational incidents fire fighters are called upon to deal with a wide range of hazardous substances in emergency conditions, and personal protective equipment may be the only reasonably practicable control measure available.)
procedure H&S02_03_V4 - Page No.15 3.16 Examples of effective control measures include: Eliminating the use of the substance altogether Substitution of a substance by a less hazardous substance, or by the same substance in a less hazardous form Engineering solutions( i.e. the design of systems and work processes, work equipment and materials used) to minimise personal exposure Control of exposure at source by enclosing the process using ventilation / extraction systems Providing safe means of handling, transporting and storage, Using only approved substances from a centrally maintained stock list, all of which have been the subject of a suitable and sufficient COSHH risk assessment Provision of suitable personal protective equipment (PPE) in addition to the above if they alone cannot reduce exposure to acceptable levels. 3.17 Personal Protective Equipment 3.17.1 Fit testing of face pieces The performance of RPE with tight fitting face pieces (filtering face pieces, half and full face masks) depends on a good contact between the wearer's skin and the face seal of the mask. A good seal can only be achieved if the wearer is clean-shaven in the region of the seal (including ori-nasal unit) and the face piece is of the correct size and shape to fit the wearer s face. If spectacles with side arms or other items of PPE are worn, they should not interfere with the correct fitting of the face piece or face seal A qualitative face-fit test will be undertaken in accordance with the manufacturer s instruction for BA face masks. For all other respiratory protection with tight fitting face pieces a quantitative face fit test must be carried out.
procedure H&S02_03_V4 - Page No.16 3.17.2 A repeat test should be undertaken in the following circumstances: - Where there is a change to the type of RPE provided. When a wearer has significant weight losses or gains. The wearer undergoes any substantial dental work. The wearer develops any facial changes (scars, moles, etc.) around the seal region. In respect of the last three points it is the wearer s responsibility to bring this to the attention of the Service through their line manager. 3.18 Maintenance and Examination of Control Measures Ensure a thorough examination and testing of control measures shall take place: Local exhaust ventilation plant at least once every 14 months Respiratory protective equipment (other than disposable RPE) at suitable intervals in accordance with manufacturer s instructions but at least once every month Where RPE (other than disposable RPE) is used only occasionally at intervals not exceeding 3 months Suitable records of examination shall be retained
H&S02_03_V4 - Page No.17 appendices 4 Appendices Appendix A Appendix B Appendix C Appendix D Hazardous Substances warning symbols Guidance documents on completing COSHH risk assessments General Health and Safety Executive guidance for compliance with COSHH COSHH Pre-Procurement Assessment Document
H&S02_03_V4 Page 18 Appendix A HAZARDOUS SUBSTANCE WARNING SYMBOLS Risk Phrase Hazard Symbol Description of hazard Explosive (E) Extremely rapid decomposition may occur through shock, friction or contact with other substances Oxidising (O) May cause or greatly assist fire Mixtures with combustible materials may be explosive Extremely flammable (F+) Highly flammable (F) Extremely flammable materials can be ignited by brief contact with an energy source, even at temperatures below 0 o C Highly flammable materials can be ignited at temperatures below 21 o C Very toxic (T+) Toxic (T) Small quantities may cause death or serious damage to health when inhaled, swallowed, or absorbed via the skin Harmful Irritant (Xn) (Xi) May cause death/damage to health when inhaled, swallowed, or absorbed via skin Non-corrosive substances which, in contact with skin or mucous membranes, will cause inflammation Corrosive (C) Will seriously damage or destroy living tissue on contact Dangerous for the environment. (N) Highly toxic for aquatic organisms, toxic for fauna or dangerous to the ozone layer
H&S02_03_V4 Page 19 Appendix B Guidance on Completion of COSHH Risk Assessments The following factors should be considered when completing a COSHH risk assessment, but this should not be taken as an exhaustive checklist: Particularly, such assessments should identify: What substance is involved? What information is available e.g. Suppliers Material Data Sheets, etc Do the COSHH Regulations apply? What are the physical characteristics of the substance? What are the routes of entry into the body? What is the potential of the substance to cause harm? What harmful effects does the substance have on the body? In which locations and in what quantities could the hazardous substance be present? How is the substance used? Who might be exposed to the substance? What is the likelihood of exposure occurring? When does exposure occur? What is the degree and extent of the exposure? How frequent is the exposure? Is medical surveillance required? What control measures are in place? How effective are these control measures? Can exposure be reduced further or eliminated? (See section 6 of this manual.) What further control measures are required?
H&S02_03_V4 Page 20 Appendix C General Health and Safety Executive guidance for compliance with COSHH Step 1. Step 2. Step 3. Step 4. Step 5. Step 6. Step 7. Step 8. Assess the risk Decide what precautions are needed Prevent or adequately control exposure Ensure that control measures are used and maintained Monitor the exposure Carry out appropriate health surveillance Prepare plans and procedures to deal with accidents, incidents and emergencies Ensure employees are properly informed, trained and supervised
East Sussex Fire & Rescue Service COSHH Pre-Procurement Assessment SUPPLIER: H&S02_03_V4 Page 21 Appendix D PRODUCT NAME: PRODUCT TYPE: PRODUCT USAGE: How much of the product is used in one working day?.. How long is the product in use during the working day?.. WHERE IS THE PRODUCT USED? OUTSIDE INSIDE WELL INSIDE POORLY SPACE VENTILATED VENTILATED Other location. Please describe- DESCRIBE THE ACTIVITY & METHOD OF WORK:........ INGREDIENTS: STORAGE AND HANDLING: LABEL INFORMATION: (Check label & tick the boxes for every hazard warning on the container) VERY TOXIC TOXIC HARMFUL IRRITANT CORROSIVE DANGEROUS TO HIGHLY FLAMMABLE FLAMMABLE ENVIRONMENT NONE
H&S02_03_V4 Page 22 Appendix D HARMFUL EFFECTS: EYES SKIN INGESTION INHALATION GENERAL FIRST AID: EYES SKIN INGESTION INHALATION OTHER INSTRUCTIONS FIRE FIGHTING PROCEDURES: SPILLAGE PRECAUTIONS: DISPOSAL: COMMENTS: Purchase Approval Print Name Signature Procurement, Contracts & Insurance Manager: Product Owner: Health and Safety: Date: