HAZARDOUS SUBSTANCES RISK ASSESSMENT

Plymouth City Council Health & Safety Performance Standard (HSPS 04) April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council

CONTENTS
Section Page

A B C D E F

Introduction Who should do Hazardous Substances risk assessment? Guidance on assessment requirements & training How to get started initial inventory Recording assessments Hazardous substances risk assessment form Assessment procedure: step-by-step approach
Step 1: Assess the risks by process/activity Step 2: Identify relevant legislation/standards/best practice Step 3: Prevent or adequately control exposure Step 4: Ensure that control measures are used/maintained Step 5: Monitor exposure Step 6: Carry out appropriate Health Surveillance Step 7: Prepare plans/procedures for accidents/emergencies Step 8: Inform, train & supervise staff Step 9: Evaluate risk and decide what further action is needed Step 10: Record and review assessments

2 5 5 6 8 10
10 11 12 14 14 15 15 16 16 19

G H I

Informing others of assessment findings Monitoring health and safety performance Further information and guidance

20 20 21

Appendix 1 Inventory checklist 24 Appendix 2 Hazardous Substances Risk Assessment Form (HSRA1) 25 Appendix 3 Register of RISK Assessments Completed 27 Appendix 4 Example of generic hazardous substances risk assessment 28 Appendix 5 Risk phrases (file attached) 32 Appendix 6 Safety phrases (file attached) 36 Appendix 7 Hazard symbols (file attached) 38 Appendix 8 Dangerous Substances and Explosive Atmospheres Regulations (file attached) 41 Appendix 9 COSHH Principles of good practice (hierarchy of controls) (file attached) 46

HSPS04 April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council

Hazardous Substances Risk Assessment Health & Safety Performance Standard. A. Introduction
1. Summary 1.1 Many substances or products used, stored, generated or disposed of at work can present risks to the health and safety of employees, non-employees and the environment. Therefore, Plymouth City Council workplaces where substances are used or stored should have an up-to-date inventory of all potentially hazardous substances on site (or used by staff), and hazardous substances risk assessment records describing the risks and control measures for safe working (this is more than just a safety data sheet). 1.2 Hazardous substances include: substances used directly in work activities (eg adhesives, paints, cleaning agents); substances generated during work activities (eg wood dust and fumes from soldering/welding); naturally occurring substances (eg grain/flour dust); biological agents (such as bacteria and fungi or moulds). 1.3 The types of substances covered by health and safety requirements of the Control of Substances Hazardous to Health (COSHH) Regulations 2002 (as amended), are: Substances or mixtures of substances classified as dangerous to health under the Chemicals (Hazard Information and Packaging for Supply) Regulations 2002 (CHIP). These can be identified by their warning label and the supplier must provide a safety data sheet for them. Many commonly used dangerous substances are listed in the HSE publication Approved Supply List. Information approved for the classification and labeling of substances and preparations dangerous for supply, as part of the CHIP package. Suppliers must decide if preparations and substances that are not in the Approved Supply List are dangerous, and if so, label them accordingly as very toxic, toxic, harmful, corrosive or irritant. Substances with workplace exposure limits are listed in the HSE publication EH40/2005 Workplace exposure limits. Biological agents (bacteria and other microorganisms), if they are directly connected with the work, such as with farming, sewage treatment, or healthcare, or if the exposure is incidental to the work (eg exposure to bacteria from an air conditioning system that is not properly maintained). Any kind of dust if its average concentration in the air exceeds the levels specified in the COSHH Regulations. Any other substance which creates a risk to health, but which for technical reasons may not be specifically covered by CHIP including: asphyxiants (ie gases which can cause suffocation such as argon and helium, which, while not dangerous in themselves, can endanger life by reducing the amount of oxygen available to breathe), pesticides, medicines, cosmetics or substances produced in chemical processes. Note Hazardous substances include those with chronic or delayed effects eg substances that are carcinogenic (cancer causing), mutagenic (can cause mutations in genetic material which may be heritable) or teratogenic (can cause non-heritable genetic mutation or malformation in a developing foetus), allergens (can cause asthma

HSPS04 April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council or skin reactions such as dermatitis), mixtures of compounds, and by-products or contaminants of processes. 1.4 The COSHH Regulations apply to virtually all substances hazardous to health except: asbestos and lead, which have their own regulations; substances which are hazardous only because they are: - radioactive; - at high pressure; - at extreme temperatures; or - have explosive or flammable properties (other regulations apply to these risks); biological agents that are outside the employers control, eg catching an infection from a workmate. (If in doubt, please contact H&S Team or Occupational Health for advice.) For the vast majority of commercial chemicals, the presence (or not) of a warning label will indicate whether COSHH is relevant. For example, there is no warning label on ordinary household washing-up liquid, so if its used at work you do not have to worry about COSHH; but there is a warning label on bleach, so COSHH does apply to its use in the workplace. 1.5 Using chemicals or other hazardous substances at work can put peoples health at risk, so the law requires employers to control exposure to hazardous substances to prevent ill health. They have to protect employees, and others who may be exposed, by complying with health and safety legislation. Examples of the effects of hazardous substances include: skin irritation or dermatitis from skin contact; asthma from contact with allergens or sensitisers; loss of consciousness from breathing toxic or asphyxiant fumes or gases; infection by micro-organisms; and burns from fires or explosions. 1.6 The legislation requiring specific actions to be taken to work safely with hazardous substances includes: Control of Substances Hazardous to Health Regulations 2002 (COSHH), Chemicals (Hazard Information and Packaging for Supply) Regulations 2002 (CHIP), Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR), Control of Lead at Work Regulations 2002 (CLAW) Control of Asbestos at Work Regulations 2002 (CAWR) The Control of Major Accident Hazards Regulations 1999 (COMAH) Regulatory Reform (Fire Safety) Order 2006 Confined Spaces Regulations 1997 Control of Pesticides Regulations 1996 The Special Waste Regulations 1996 The Health and Safety (First aid) Regulations 1981 Ionising Radiations Regulations 1999 2. Health & Safety Performance Standard for Hazardous Substances Risk Assessment (HSPS 04) 2.1 For the sake of simplicity this guidance document will use the same general term Hazardous Substances Risk Assessment for all risks related to the use of hazardous substances at work (except asbestos and radiation), regardless of whether or not those risks are covered specifically by the COSHH Regulations or other legislation.

HSPS04 April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council 2.2 To conduct a Hazardous Substances Risk Assessment you need to follow these ten steps: Step 1 Step 2 Assess the risks Assess the risks to health and safety from hazardous substances used in or created by your work activities You must not carry out work which could expose employees or others to hazardous substances without first considering the risks and the necessary precautions, and what else you need to do to comply with the law. You must prevent employees and others from being exposed to hazardous substances. Where preventing exposure is not reasonably practicable, then you must adequately control exposure. The advice in this guidance will help you to make correct assessments and to put the appropriate controls into place. Ensure that control measures are used and maintained properly and that safety procedures are followed. (Classify places where explosive atmospheres may occur into zones, and mark the zones where necessary.) Monitor the exposure of employees to hazardous substances, if necessary. Carry out appropriate health surveillance where your assessment has shown that this is necessary or where Regulations make specific requirements. Prepare plans and procedures to deal with accidents, incidents and emergencies involving hazardous substances, and provide equipment where necessary. You should provide employees (and nonemployees where appropriate) with suitable and sufficient information, instruction and training, to work safely and without risk to health. Identify further actions to reduce risk so far as is reasonably practicable (for carcinogens and biological agents the controls must prevent exposure risk so far as is reasonably practicable). Record significant findings of the assessment process and amend as knowledge and experience improve. Review assessments regularly and revise as necessary. Page 10 Page 11

Identify relevant legislation, standards, and best practice

Step 3

Prevent or adequately control exposure

Page 12

Step 4

Ensure that control measures are used and maintained

Page 14

Step 5 Step 6

Monitor the exposure Carry out appropriate health surveillance

Page 14 Page 15

Step 7

Step 8

Step 9

Prepare plans and procedures to deal with accidents, incidents and emergencies Ensure employees are properly informed, instructed, trained and supervised Decide what further action is needed

Page 15

Page 16

Page 16

Step 10

Record and review assessments

Page 19

HSPS04 April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council

B. Who should do Hazardous Substances Risk Assessment?

Legal responsibility for all types of risk assessment rests with the employer, but it is common for most of the work involved in doing risk assessments to be devolved down the line management chain to staff in service units. Except in very simple cases, whoever carries out the hazardous substances risk assessment will need to: have access to, and understand, the COSHH Regulations and other legislation/codes of practice/guidance, or to someone else who does; be able to get all the necessary information and have the knowledge and experience to make correct decisions about the risks and the actions needed; understand their own limitations, and know where to get help. Employees often have the most knowledge of what really happens in the workplace, and in groups can often contribute much of the information needed for hazardous substances risk assessment. This knowledge should be used before deciding whether outside help is required. If there is insufficient expertise available to assess more complex risks, competent assistance should be sought from a Trade Association, or professionally qualified Health and Safety Adviser, or Occupational Hygienist. Employees, their elected safety representatives and safety committees must be informed of the results of hazardous substances risk assessments, and should be consulted during the process. Heads of service and Head teachers may wish to appoint one or more staff to co-ordinate or specialise in hazardous substances risk assessment. Specific training courses are available from the Corporate Health & Safety Team for these risk assessments see the next Section.

C. Guidance on risk assessment requirements and training

In addition to the general requirement for risk assessment under the Management of Health and Safety at Work Regulations 1999, risk assessment of specific hazards is often required to be carried out in a specific way indeed, risk assessment is now a common theme of all new health and safety legislation. To make the Hazardous Substances Risk Assessment process easier, the Corporate Health & Safety Team have designed specific hazardous substances risk assessment forms and checklists (see appendices 1 and 2; all forms are available on the Health, Safety and Wellbeing Document Library on the Council Intranet). However, hazardous substances are seldom used in isolation, and a hazardous substances assessment may be required as just part of a wider reaching activity risk assessment so, the two assessment records will need to be cross-referenced. Council health and safety guidance and Performance Standards have been produced for some of the hazards that relate to the work of the Council, and additional guidance is continually being developed. Also, within Departments, local or national guidance may be available on specific risks and activities such as School Science and Design &

HSPS04 April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council Technology (D&T) safety guidance from the CLEAPSS School Science Service. In Schools this guidance should be followed for science and design & technology teaching activities, and Council guidance should be applied to all other teaching activities using hazardous substances (eg art), and non-teaching activities, e.g. cleaning, caretaking, grounds keeping, volunteer work, off-site activities, etc. Before embarking on a risk assessment you should check what guidance exists, and familiarise yourself with legal requirements and relevant standards. The Corporate Health, Safety & Wellbeing Team provide an annual programme of training, including courses on how to carry out both general risk assessments and hazardous substances risk assessments. A full list of courses can be found in the current edition of the Councils Programme of Scheduled Training Courses, available from the Corporate Learning & Development Team (Human Resources) and the Councils intranet. Alternatively, please contact the Health, Safety & Wellbeing Team.

D. How to get started Initial inventory

i. Start by involving all staff who use (or regularly come into contact with) substances in the course of their work and use existing lists/inventories of substances/products/materials that might be hazardous. Then walk around the premises looking for other substances that may not be recorded (especially stored and unused substances, and those brought in unofficially). Create comprehensive inventories, listing substances/materials by - product name, supplier name, total amount held, location(s), date of delivery, etc (see example in appendix 1). Ensure that up-to-date safety data sheets (or CLEAPSS HAZCARDS for science/D&T substances in schools) are available for all substances on the premises. If you do not have them, contact the suppliers and request new ones. If substances are old and the supplier is no longer in business, gather information about products/ingredients from product labels, chemistry texts or web sites, or ask the Health, Safety and Wellbeing Team (in schools ask the science staff for help). If you cannot get hold of adequate safety information, then the substance cannot be used or stored, and will have to be disposed of via a specialist hazardous waste disposal contractor. Identify and list all the processes/activities that use or produce hazardous substances, and arrange for appropriate disposal of all hazardous substances that are no longer used or should not be used/stored on the premises. Now you can begin hazardous substances risk assessment of processes/activities (not just single substances, unless they are used alone), and storage areas.

ii.

iii.

iv.

v.

vi.

HSPS04 April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council PREDICTIVE OR DYNAMIC HAZARDOUS SUBSTANCES RISK ASSESSMENT? All employers are required by law to carry out risk assessments for substances that can harm their staff and any other people who might be affected, so when visiting other work premises, staff should ask for any hazardous substances risk assessment information for substances that might affect them. (Council staff must tell other people who might be affected, when they take hazardous substances onto other premises in the course of their work). Where Council staff regularly have to visit small business or domestic premises in the course of their work, and they can anticipate (through experience) whether they might be exposed to hazardous substances, they will need to make predictive hazardous substances risk assessments for such circumstances. If they can predict in advance, the general types of substance that they are likely to encounter, they can prepare appropriate control measures. Where staff cannot predict in advance what hazardous substances they might be exposed to they will need sufficient information, instruction and training to carry out dynamic hazardous substances risk assessment on the spot. They should know whether they are at any increased risk from particular substances due to health issues, and be prepared to take avoiding action if they cannot prevent exposure. Significant risks identified in this way should be recorded after the event as a record and for future planning. GENERIC OR SPECIFIC HAZARDOUS SUBSTANCES RISK ASSESSMENT? The HSCs Advisory Committee on Toxic Substances has developed COSHH essentials as a generic risk assessment scheme for a wide range of hazardous substances covered by CHIP and COSHH. It leads users to appropriate control advice for a range of common tasks, eg mixing, weighing, spray painting. COSHH essentials is available both in printed and electronic (web-based: www.coshh-essentials.org.uk/) formats, and can be used as a basis for the recording of the COSHH risk assessment. While COSHH essentials has been designed to ensure that a precautionary approach is taken towards control, it is a generic guide and cannot guarantee that in all circumstances it will lead to full compliance with the Regulations assessment and control requirements. Model risk assessments are used in School science and D&T activities, eg CLEAPSS Hazcards; Recipe Cards; the CLEAPSS Laboratory Handbook; Model risk assessments for Design and Technology; Primary Classroom Hazard Cards; and the DfES Safety in Science Education are standard publications of assessments made for a number of workplaces where similar activities are undertaken. Heads of Science or D&T/local managers are expected to review the model risk assessments in these publications and to consider if adaptation is necessary for local conditions. They should normally give references to the Model Risk Assessment, and to any adaptation, and be recorded on texts in daily use, with appropriate warnings. (They should also follow the guidance set out in section A3 of CLEAPSS guide L196 Managing Risk Assessments in Science for special risk assessments and non-curriculum activities in secondary/college science, and the How to use model or general risk assessments - summary section of the D&T model risk assessments.) Specific risk assessments are more appropriate where a more detailed assessment of a person, activity, event or piece of equipment is needed, and the risks involved are not

HSPS04 April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council sufficiently covered by generic assessments. The hazardous substances risk assessment should determine whether there are any substances hazardous to health (including biological agents) at the workplace to which people are liable to be exposed, and in a form in which the substance can be inhaled, ingested or absorbed through the skin. Particular consideration should be given to: Activities that can give rise to the highest exposures, eg cleaning of equipment, work in confined spaces, transporting hazardous substances for work or non-routine or end-ofshift tasks. Any work activity that may expose people to more than one substance hazardous to health, where the possible enhanced harmful effects of combined or sequential exposures must be considered. Biological agents, where the assessment should reflect the ability they may have to replicate and infect (see appendix 7). Substances that are known or suspected carcinogens, where there is a more compelling reason for every effort to be made to substitute a non-carcinogenic alternative (see appendix 6). Particular groups of people who may be at increased risk, eg inexperienced trainees and young persons aged under 18; pregnant (or potentially pregnant) workers; disabled workers; and anyone known to be susceptible to certain illnesses such as dermatitis, asthma, or other diseases which may be caused or exacerbated by exposure to hazardous substances.

E. Recording assessments Hazardous Substances Risk Assessment Forms

It is important to have a means of easily and logically recording the relevant information from your hazardous substances risk assessments, and the format used must meet the requirements of the law. You are legally obliged to carry out a hazardous substances risk assessment, before use/possession of any hazardous substance at work, and record the significant findings of each assessment. While the legislation does not prescribe how hazardous substances risk assessments should be recorded, there are specific requirements about what should be recorded. You should use the forms designed by the Corporate Health, Safety and Wellbeing (HSW) Team that are included in this guide (see appendix 2). With the exception of CLEAPSS Hazcards in schools and HSEs COSHH essentials, if you wish to use different forms, you must discuss this with staff in the Corporate HSW Team who will advise you whether your forms are suitable. Records of hazardous substances risk assessments can be kept electronically, but they must be easily retrievable for use by staff, managers, auditors and external agencies, when required, such as the HSE or insurance assessors. I. HAZARDOUS SUBSTANCES RISK ASSESSMENT FORM (HSRA1) The Revised Council Hazardous Substances Risk Assessment Form (HSRA1) is included in appendix 2. A step-by-step explanation of how this form should be completed is given in the next section. This form is also available from the Health, Safety & Wellbeing section of the Document Library on the Council Intranet. An example of a completed hazardous substances risk assessment form is included in appendix 4.

HSPS04 April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council II. REGISTER OF RISK ASSESSMENTS To keep a record of the activities, projects or work areas that have been assessed, when risk assessments need to be reviewed, and to facilitate auditing a Register of Risk Assessments Completed (see appendix 3) should be kept by each Service Unit or School, and a copy provided to the Corporate HSW Team. You do not need to send copies of every hazardous substances risk assessment record to the Corporate HSW Team, but we will provide feedback on any that you produce. III. KEEPING RECORDS Service Units and Schools should keep hazardous substances risk assessment records for as long as the process or activity, to which the assessment refers, is carried out (or as long as the substances involved are held on the premises), and for 3 years afterwards. As civil claims for injury can be made up to 3 years after an incident occurs, it will still be necessary to demonstrate, retrospectively, that the risks were properly assessed and controlled. Significant accidents or incidents where children are exposed to hazardous substances, can potentially result in personal injury claims up to 3 years after the child reaches the age of 18. So, all records associated with incidents affecting children should be retained until the child is 21. Health surveillance records resulting from hazardous substances risk assessment control and monitoring procedures, must be retained for 40 years. Therefore, it is logical to retain all copies of the associated hazardous substances risk assessment records for that length of time as well.

F.

The Hazardous Substances Risk Assessment Process: A Step-by-Step Approach

When you have compiled your initial inventory (see Section D and appendix 1), and decided: what needs to be assessed; who is going to do it; how you will record assessments; and, ensured that the people involved are competent to do COSHH risk assessment; then you are ready to begin. Who should do the assessment? The employer has legal responsibility for the assessment, but others can do some or even most of the work of preparing it. Except in very simple cases, whoever carries out the assessment will need to: Have adequate knowledge, training and expertise in understanding hazard and risk; Know how the work activity uses or produces substances hazardous to health; Have the ability and the authority to collate all the necessary, relevant information; and Have the knowledge, skills and experience to make the right decisions about the risks and precautions that are needed. The person who carries out the assessment does not always have to be fully familiar with the requirements of the COSHH Regulations and the Approved Code of Practice, and other

HSPS04 April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council relevant legislation and guidance. However, that person should have access to someone who has a firm grasp of those requirements (eg Corporate HSW Team). This pooling of knowledge would allow, for example, a supervisors experience of a process to be combined with technical specialists, and Council health and safety advisers. See the following web sites for further information: HSE COSHH information for various industries and work activities www.hse.gov.uk/coshh/index.htm Some useful HSE leaflets: COSHH A brief guide to the Regulations - www.hse.gov.uk/pubns/indg136.pdf Why do I need a safety data sheet? www.hse.gov.uk/pubns/indg353.pdf Read the label - how to find out if chemicals are dangerous www.hse.gov.uk/pubns/indg352.pdf Idiots guide to CHIP - www.hse.gov.uk/pubns/indg350.pdf Fire and explosion - How safe is your workplace? A short guide to DSEAR www.hse.gov.uk/pubns/indg370.pdf The Hazardous Substances Risk Assessment Form (HSRA1), in appendix 2, takes you through these questions in a logical sequence to enable appropriate control measures to be identified.

Step 1:

Assess the risks by processes/activity

You should have decided which of the risks from your inventory can be covered by generic assessments and where specific assessments will be needed instead. Where exposure to a number of different hazardous substances pose little or no risk to the health of staff or others, then the significant findings of assessments for those substances may be grouped together on a single record. The significant findings for similar substances of low risk, eg lubricants or detergents, may also be grouped together on a single record.
6

You must: identify the hazardous substances present in your workplace; and consider the risks these substances present to peoples health. Identify the hazardous substances present in your workplace Remember to think about substances which have been supplied to you; those produced by your work activity, eg fumes, vapours, aerosols, final products and waste materials; and those naturally or incidentally present in your workplace, eg infectious agents carried by farm animals. Using labels and safety data sheets - list all the substances and their hazards and risk phrases etc. in section 1 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. Consider the risks these substances present to peoples health Assessing the risk involves making a judgment on how likely it is that a hazardous substance will affect someones health. You need to ask yourself the following questions How much of the substance is in use or produced by the work activity and how could people be exposed to it?

HSPS04 April 2006

10

Guide to Hazardous Substances Risk Assessment Plymouth City Council List this information in section 2 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. For supplied substances HSE has developed a generic risk assessment guide to help. It uses information on hazard, amount used and simple definitions of dustiness for solids or volatility for liquids. The guide is called COSHH essentials: Easy steps to control chemicals. The guide also helps you with the next two steps deciding what action you need to take to control risks and controlling exposure. As well as the published version, COSHH essentials can be found free on the Internet at: www.coshh-essentials.org.uk , where you can follow the steps quickly and easily online. Who could be exposed to the substance and how often?

You must remember to include all groups of people who could come into contact with the substance, ie contractors, visitors and members of the public, as well as your employees. Do not forget those involved in cleaning and maintenance tasks high exposures can occur during this type of work - list these in section 2 of the hazardous substances risk assessment form HSRA1 in appendix 2. Also, certain groups of people could suffer more from exposure than others, eg pregnant women, individuals with a suppressed immune system - list these in section 6.2 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. Is there a possibility of substances being absorbed through the skin or swallowed (eg as a result of a substance getting into the mouth from contaminated hands during eating or smoking)? List these risks under routes of exposure in section 3 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. Are there risks to your employees at other locations if they work away from your main workplace? See the HSE guidance Working alone in safety for solitary workers away from their home base this may require a separate hazardous substances risk assessment to describe the additional requirements needed for lone worker safety, unless lone worker use of hazardous substances is prohibited.

Step 2:

Identify relevant legislation/standards/best practice

Find out whether there is any relevant documented best practice, standards or legal requirements, which should be followed for the substance(s)/process/activity being assessed. Examples include Council Policies, guidance or Approved Codes of Practice, British or European Standards, or trade or professional guidance. (Relevant standards/best practice should be listed in section 6.1 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2). For example, if you are assessing the risks from woodworking you should refer to www.hse.gov.uk/pubns/woodindx.htm for Woodworking Information Sheets Nos 1,6,12,14,19,23,24,25,,26,29,30,32, as appropriate. Managers and supervisors are expected to know about the hazardous substances in their workplaces, and the main legal requirements, policies and standards relating to their work (even if only in outline). If you do not know, you must find out. Some additional sources of information are listed below: Health and Safety Executive web sites: www.hse.gov.uk/coshh/index.htm and www.coshhessentials.org.uk Legislation and supporting Guidance available from HSE Books www.hsebooks.com/Books/ (The Corporate HSW Team has access to electronic copies of HSE documents, and many more in a web-based library, but is unable to supply copies to other Council staff for reasons of cost.)

HSPS04 April 2006

11

Guide to Hazardous Substances Risk Assessment Plymouth City Council There are many chemistry texts available which contain COSHH and DSEAR information, such as Croners: Substances Hazardous to Health, Dangerous Substances, and Emergency Spillage Guides; and, Brethericks Handbook of Reactive Chemical Hazards. There may be British/European Standards available from the British Standards Institute (HSW Team does not have access to these, but other departments may have e.g. Building Control, Asset Management). Product safety data sheets, and additional instructions for safe use, from manufacturers and suppliers. Guidance from Council departments e.g. Cleaning/Caretaking safety guidance from the Asset Management Section of Corporate Resources. Guidance from Trade Associations, industry or professional bodies, and Trades Unions. CLEAPSS School Science and D&T Service www.cleapss.org.uk Do not forget to consult those actually doing the work, as they are often the experts.

Step 3:

Prevent or adequately control exposure

The overriding duty and first priority is to consider how to prevent people from being exposed to substances hazardous to health by all routes. Prevent exposure The COSHH Regulations require you to prevent exposure to substances hazardous to health, if it is reasonably practicable* to do so. You might: change the process or activity so that the hazardous substance is not needed or generated; replace it with a safer alternative; use it in a safer form, eg pellets instead of powder. (The HSE guidance booklet Seven steps to successful substitution of hazardous substances advises on how to replace hazardous substances with safer alternatives.)
* So far as is reasonably practicable Balancing the degree of risk against the time, trouble, cost and physical difficulty of the measures needed to avoid or reduce it. The greater the risk, the more likely that it is reasonable to go to substantial expense trouble and intervention to reduce it. However if the risk is small, it would not be considered reasonable to go to great expense. Ultimately, the judgement is an objective one based on the health risks and not the size or financial position of the employer.

Adequately control exposure If prevention is not reasonably practicable, you must adequately control exposure. You should consider and put in place measures appropriate to the activity and consistent with the risk assessment, including, in order of priority, one or more of the following: use appropriate work processes, systems and engineering controls, and provide suitable work equipment and materials eg use processes which minimise the amount of material used or produced, or equipment which totally encloses the process; control exposure at source (eg local exhaust ventilation), and reduce the number of employees exposed to a minimum, the level and duration of their exposure, and the quantity of hazardous substances used or produced in the workplace;

HSPS04 April 2006

12

Guide to Hazardous Substances Risk Assessment Plymouth City Council provide personal protective equipment (eg face masks, respirators, protective clothing), but only as a last resort and never as a replacement for other control measures which are required. List your existing control measures (such as ventilation, training, using small amounts or PPE etc.) in section 5 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. The Hazard warning label and Safety phrases on the Manufacturers/Suppliers Safety Data Sheet may be useful in deciding what control measures are needed see appendices 6 and 7 for details). The COSHH Essentials: Easy steps to control chemicals guide and website www.coshhessentials.org.uk give advice on adequate control measures for supplied chemicals and a number of common industrial operations. For supplied chemicals it is important that you work through the risk assessment process it outlines, to arrive at the right measures for your chemicals and tasks. Meaning of adequate control Under the COSHH Regulations, adequate control of exposure to a substance hazardous to health means: applying the eight principles of good practice set out in detail in appendix 9; not exceeding the workplace exposure limit (WEL listed on safety data sheets and copied into section 1 of the HSRA1 form) for the substance (if there is one); and, if the substance causes cancer, heritable genetic damage or asthma, reducing exposure to as low a level as is reasonably practicable; if the substance is flammable or explosive, complying with the requirements of DSEAR (see details in appendix 8). The HSC has established WELs for a number of substances hazardous to health. These are intended to prevent excessive exposure to specified hazardous substances by containing exposure below a set limit. A WEL is the maximum concentration of an airborne substance, averaged over a reference period, to which employees may be exposed by inhalation. WELs are listed in EH40 Workplace exposure limits and should be available on up-to-date safety data sheets. Correctly applying the principles of good practice will mean exposures are controlled below the WEL. Advice on applying the principles can be found in the COSHH Regulations ACOP and this guidance (see appendix 9). Adequate control of carcinogens, mutagens and asthmagens COSHH acknowledges the particular hazards of substances which cause cancer, heritable genetic damage or asthma by requiring that exposure to these is reduced to as low a level as is reasonably practicable. The HSE website contains guidance on suitable controls. For carcinogens (substances which may cause cancer) or mutagens (substances which may cause heritable genetic damage) special requirements apply - contact the HSW Team for further advice and information. Skin absorption Some substances can damage the skin itself while others can readily penetrate it, become absorbed into the body and cause harm, so you must consider the need to protect skin when deciding on control measures. The guide COSHH essentials: Easy steps to control chemicals, contains useful advice on skin protection.

HSPS04 April 2006

13

Guide to Hazardous Substances Risk Assessment Plymouth City Council

Step 4:

Ensure that control measures are used/maintained

Using the controls COSHH requires users to make proper use of control measures and to report defects. It is your responsibility to take all reasonable steps to ensure that they do so. This is why you must give your employees suitable training, information and appropriate supervision (see Step 8 for a more detailed explanation). Any safety training, supervision and instruction given should be listed as part of the control measures in section 5 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. Maintain controls COSHH places specific duties on you to ensure that exposure controls are maintained. The objective being to ensure that every element of the control measure continues to perform as originally intended. This applies to items of equipment such as local exhaust ventilation and to systems of work, which will have to be regularly checked to make sure that they are still effective. Respiratory protective equipment should also be examined and, where appropriate, tested at suitable intervals. COSHH sets specific intervals between examinations for local exhaust ventilation equipment, and you must retain records of examinations and tests carried out (or a summary of them) for at least five years. Inspection, testing, and maintenance arrangements for control measures should be referred to in section 5 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2.

Step 5:

Monitor exposure

Under COSHH, you have to measure the concentration of hazardous substances in the air breathed in by workers where your assessment concludes that: there could be serious risks to health if control measures failed or deteriorated; exposure limits might be exceeded; or control measures might not be working properly. List any existing monitoring arrangements in section 3 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. However, you do not need to do this if you can show by another method of evaluation that you are preventing or adequately controlling employees exposure to hazardous substances, eg a system which automatically sounds an alarm if it detects hazardous substances. The COSHH Regulations ACOP provides examples of other alternative methods of evaluation. Air monitoring must be carried out when employees are exposed to certain substances and processes specified in the COSHH Regulations. Where it is appropriate to carry out personal air monitoring, the air to be sampled is the space around the workers face from where the breath is taken, ie the breathing zone. You should keep and maintain a record of any exposure monitoring you carry out for at least five years. Where an employee has a health record (required where they are under health surveillance, see Step 6), any monitoring results relevant to them as an individual must be kept with their health record. They should be allowed access to their personal monitoring record. You can find more information on monitoring in the HSE guidance Monitoring strategies for toxic substances.

HSPS04 April 2006

14

Guide to Hazardous Substances Risk Assessment Plymouth City Council

Step 6:

Carry out appropriate Health Surveillance

COSHH requires you to carry out health surveillance in the following circumstances: where an employee is exposed to one of the substances listed in the COSHH Regulations and is working in one of the related processes, eg manufacture of certain compounds of benzene, and there is a reasonable likelihood that an identifiable disease or adverse health effect will result from that exposure; where employees are exposed to a substance linked to a particular disease or adverse health effect and there is a reasonable likelihood, under the conditions of the work, of that disease or effect occurring and it is possible to detect the disease or health effect. Health surveillance might involve examination by a doctor or trained nurse. In some cases trained supervisors could, for example, check employees skin for dermatitis, or ask questions about breathing difficulties where work involves substances known to cause asthma (see the questionnaire in the HSE publication Preventing asthma at work. How to control respiratory sensitisers). You must keep a simple record (a health record) of any health surveillance carried out. Exposure to substances for which health surveillance might be appropriate, include: skin or respiratory sensitisers, eg epoxy resins, isocyanates, styrene, metal working fluids; toxins, eg lead (dust or vapour), mercury or compounds (vapour or dust), organophosphorus compounds; carcinogens or mutagens, eg vinyl chloride. List any existing health surveillance arrangements in section 3 of the Hazardous Substances Risk Assessment form HSRA1 appendix 2. For further information you can refer to the HSE guidance Health surveillance under COSHH: guidance for employers. Biological monitoring can also have a role in health surveillance. You can find further information on setting up a biological monitoring programme in the HSE publication Biological monitoring in the workplace: a guide to its practical application to chemical exposure.

Step 7:

Prepare plans/procedures for accidents/emergencies

This will apply where the work activity or storage arrangement gives rise to a risk of an accident, incident or emergency involving exposure to a hazardous substance, which goes well beyond the risks associated with normal day-to-day work. In such circumstances, you must plan your response to an emergency involving hazardous substances before it happens. That means preparing procedures and setting up warning and communication systems to enable an appropriate response immediately any incident occurs, and ensuring that information on your emergency arrangements is available to those who need to see it, including the emergency services. It also requires these safety drills to be practiced at regular intervals. List all emergency actions (for first aid, spillage, fire and explosion as appropriate) and waste disposal arrangements in section 4 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2. If any accident, incident or emergency occurs you must ensure that immediate steps are taken to minimise the harmful effects, restore the situation to normal and inform employees and others who may be affected. Only those staff necessary to deal with the incident may remain in the area and they must be provided with appropriate safety equipment. However, you do not have to introduce these emergency procedures if:

HSPS04 April 2006

15

Guide to Hazardous Substances Risk Assessment Plymouth City Council the quantities of substances hazardous to health present in your workplace are such that they present only a slight risk to your employees health; and, the measures you have put in place under Step 3 are sufficient to control that risk; but, the requirements described in Step 7 must be complied with in full where either carcinogens, mutagens or biological agents are used.

Step 8:

Inform, train and supervise staff

COSHH requires you to provide your employees with suitable and sufficient information, instruction and training for controlling risks to health and safety, which should include: the names of the substances they work with or could be exposed to and the risks created by such exposure, and access to any safety data sheets that apply to those substances; the main findings of your risk assessment; the precautions they should take to protect themselves and other employees; how to use personal protective equipment and clothing provided; results of any exposure monitoring and health surveillance (without giving individual employees names); emergency procedures which need to be followed. You should update and adapt the information, instruction and training to take account of significant changes in the type of work carried out or work methods used. You should also ensure that you provide information, instruction and training that is appropriate to the level of risk identified by the assessment and in a manner and form in which it will be understood by employees. These requirements are vital. You must ensure your employees understand the risks from the hazardous substances they could be exposed to. Your control measures will not be fully effective if your employees do not know their purpose, how to use them properly, or the importance of reporting faults. (These arrangements should be referred to in section 5 of the Hazardous Substances Risk Assessment form HSRA1 in appendix 2).

Step 9:

Evaluate risk and decide what further action is needed

Once you have identified all the control measures that are already in place, you need to assess the level of remaining risk of exposure to hazardous substances arising from the activity or process that you are assessing. This is where knowing how your current arrangements compare with best practice and legislative requirements is important, as is reviewing your incident and ill health history, and talking to staff about continuing risks. Evaluating current risk levels is not always easy, and can be very subjective. Assessments can vary considerably, from one person to another, between high and low. Greater objectivity can be introduced into the process if a common system of evaluation is used by all hazardous substances risk assessors, which takes into consideration the factors that contribute to risk level, including: The severity (S) of the harm that exposure to a hazardous substance can cause; The probability (P) of exposure happening in your circumstances. You can then do a simple calculation to produce a risk rating, which corresponds to a risk level of low, medium, high or very high. Simply decide on the severity (S) of the hazardous substance in question, using the categories and examples in Table 1 below, and the probability or likelihood of exposure to the hazardous substance in question (P) using Table 2. Multiply the scores together to

HSPS04 April 2006

16

Guide to Hazardous Substances Risk Assessment Plymouth City Council produce a risk rating (R). On the Hazardous Substances Risk Assessment Form HSRA1 in appendix 2, space is provided in section 5 to record these scores. Table 1: Risk Severity (S)
If the substance has a risk phrase, a severity score has been allocated in appendix 5. Category Example MINOR Substances not included on the Approved Supply List. Superficial Score

SERIOUS

MAJOR

FATAL

injuries - mild skin irritation, nausea requiring first aid only. Minor property damage from fire/explosion. More serious ill-health/injuries requiring time off work, school, or a hospital visit, e.g. minor burns, nausea and vomiting, diarrhoea. Moderate property damage from fire/explosion. Acute illness/injury requiring medical treatment. Loss of consciousness or loss of sight. Major property damage from fire/explosion. Exposure which leads to death either at the time or soon after the incident, or eventually, as in the case of certain occupational diseases such as asbestos-related cancers. Chronic illness. Mutagenic, teratogenic and carcinogenic effects. Death resulting from fire/explosion.

Table 2. Risk Probability (P) - the likelihood of the hazard causing harm.
Category
VERY UNLIKELY

Example (for guidance only - some or all may apply for each category)

Score

UNLIKELY

POSSIBLE

LIKELY

Good control measures are in place. Controls do not rely on a person using them (i.e. personal compliance). Controls are very unlikely to break down. People are very rarely in this area or very rarely engage in this activity. Under DSEAR - not classified as a place in which an explosive atmosphere is likely to occur. Reasonable control measures are in place but they do rely on a person using them (some room for human error). Controls are unlikely to breakdown. People are not often in this area / do not often engage in this activity / this situation is unlikely. DSEAR classification Zone 2 or 22. Inadequate controls are in place, or likely to breakdown if not maintained. Controls rely on personal compliance. People are sometimes in this area or sometimes engage in this activity / this situation sometimes arises. DSEAR classification Zone 1 or 21. Poor or no controls are in place. Heavy reliance on personal compliance (lots of room for human error). People are often in this area / engage in this activity on a regular basis / this situation often arises. DSEAR classification Zone 0 or 20.

The scores can be represented in a matrix, shown as in Table 4 below.

Risk scores correspond to a risk level very high, high, medium, low.

Table 3. Risk Score Matrix

RISK SCORE = S X P
Minor

SEVERITY OF OUTCOME (S)

Serious Major Fatal

Risk Level 4 Low

P R

Very Unlikely

HSPS04 April 2006

17

Guide to Hazardous Substances Risk Assessment Plymouth City Council

O B A B I L I T Y (P)
Medium High Possible 3 6 9 12 Very High 4 8 12 16

Unlikely

Likely

What about the number of people at risk? Another risk factor that should be considered when evaluating the level of risk is the actual number of people at risk at any one time (sometimes known as the extent of risk). In general, for risks at a similar level, a higher priority should be given to actions that reduce risks affecting a greater number of people. Why use a quantitative (numerical) system of categorising risks? Expressing risk levels as scores can be very useful when making decisions about prioritising action and allocating resources. Scores derived using a common method will enable comparisons to be made between one activity or part of the organisation, and another. Deciding what further action is required to reduce risk If you discover that the existing risk control measures are not adequate to prevent or sufficiently reduce exposure to hazardous substances, for whatever reason, you must establish what further action is needed to reduce risks so far as is reasonably practicable (and list these in section 5 of the hazardous substances risk assessment form HSRA1 in appendix 2), and by when this should be done. If action can be taken immediately to improve risk controls, then this should be done without delay (and recorded in section 7 of the Hazardous Substances Risk Assessment Form HSRA1 in appendix 2). When considering what further control measures should be adopted, you should always follow the hierarchy of risk controls (detailed in appendix 9). Priority should be given to collective protective measures, over individual protective measures. The use of PPE should only be a last resort, in combination with other control measures, if there is no other way of reducing exposure risks to a reasonable level. Using the same technique as that outlined in Step 9, you should estimate the reduced risk level that will be achieved when any further improvements identified have been implemented. This can be used to demonstrate the cost benefits of investment in new controls. You should obviously aim to reduce all risks to the lowest level reasonably achievable (this does not necessarily require the elimination of all hazards remember the difference between hazard and risk). The values for Severity (S), Probability (P) and Risk (R) that you anticipate will be achieved by the additional controls should be entered into section 5 of the HSRA1 in form in appendix 2 in the columns headed Reduced Risk. Action plans implementing risk controls

HSPS04 April 2006

18

Guide to Hazardous Substances Risk Assessment Plymouth City Council If further action is required you should draw up a health and safety action plan to ensure that improvements needed are prioritised according to the level or risk identified. This should be recorded in Section 7 of the HSRA1 form in appendix 2. Remember to include realistic time scales in your action plan and identify who will be responsible for checking that the objectives of the plan have been met. It is up to you to decide on appropriate time scales for action, but some typical timescales, according to risk are given as a guide in Table 4. Table 4: Scores and Typical Action Plan Time Scales SCORE RISK LEVEL TYPICAL TIME SCALES FOR ACTION REQUIRED 1 23 46 8 10 12 16 Insignificant Low Medium High Very high
No further action needed

Action within 12 months if improvements are reasonably practicable Action within 6 months based on reasonable practicability Action within 1 month to reduce risk (immediate action may be needed in some circumstances) Immediate action required work should stop / not commence until risk has been reduced to acceptable levels

Step 10:
Recording

Record and review assessments

The Councils Hazardous Substances Risk Assessment form HSRA1, in appendix 2, should be used for recording the significant findings of risk assessments (a Manufacturers/Suppliers Safety Data Sheet does not constitute a hazardous substances or COSHH risk assessment), and these should then be listed on the Register of Risk Assessments Completed for each Service Unit/School (see appendix 3). Review Hazardous substances risk assessments should be reviewed regularly and amended or annotated as necessary. They should not be a once-and-only record to be filed away somewhere for bureaucratic purposes, but a living document that evolves with experience and forms a useful part of the work process. They do not need to be re-written every year, but they should at least be checked for accuracy and re-dated and signed. Assessments should be reviewed: When significant changes are made to workplaces, work activities, control measures, substances or equipment, to the degree that the original assessment is no longer valid; When new/amended legislation/guidance/codes of practice or national standards are introduced; Following monitoring/test results, incidents or ill health which highlight deficiencies in existing control measures or previously unidentified risks; When new or temporary (eg agency, or work experience) members of staff are employed who may be at increased risk due to inexperience, age or physical/mental health conditions and disabilities. In these circumstances a personal Hazardous Substances Risk Assessment may be required;

HSPS04 April 2006

19

Guide to Hazardous Substances Risk Assessment Plymouth City Council When a female member of staff informs you that they are pregnant, and their work exposures could give rise to risks to the mother or unborn child (women of reproductive capacity may be advised not to work with certain substances that can cause inherited defects, ie teratogens and mutagens); On a regular basis every 12 months is recommended (although 24 months would be acceptable for infrequent use/small amounts of low risk substances).

G. Informing others of Hazardous Substances Risk Assessment Findings

Induction, at Service Unit or School level, for all new/trainee/work experience/temporary/agency workers must include information about risks to their health and safety and control measures associated with their work and workplace(s). For hazardous substance risks they must also be informed of any Health Surveillance requirements attached to their work before they start. This will be made easier with the keeping of risk assessment records, which should be copied to employees in a format that is comprehensible (for instance, not everyone has good eyesight, or English as a first language), so that everyone understands the reasons behind safe working practices. This should improve compliance with the use of control measures, and ensure co-operation. Staff should be asked to sign a record to confirm their receipt and understanding of health and safety information provided to them. Contractors (and volunteer workers and premises hirers) must be informed about any risks to health and safety that they may be exposed to when using/working in or on Council premises. They must also provide risk assessment information on any hazardous substances that they might use or produce on Council premises, before starting work. Trade Union Safety Representatives also have a right to be informed about the findings of all risk assessments affecting the health and safety of their Union members.

H. Monitoring Health and Safety Performance

Proactive monitoring It is important to have a system in place to maintain health and safety standards, by regularly checking that risks are adequately managed and controlled in the workplace on a day-to-day basis. It is, therefore, essential that health and safety performance is monitored, in the same way as other aspects of management performance, by the Head of Service/Head teacher. One form of proactive monitoring, required by the Council (in line with HSE recommended good practice) is for managers to ensure that regular health and safety inspections are carried out in their work areas. The frequency of such inspections will depend on the level of risk in the premises/work activities, but at least once every 6 months is recommended. Ideally, these inspections should be undertaken using a health and safety checklist. And, as workplace inspections should monitor that the controls listed in hazardous substances risk assessments are in place, effective and relevant risk assessment records should be used to develop the inspection checklist. For example if regular inspection and testing of

HSPS04 April 2006

20

Guide to Hazardous Substances Risk Assessment Plymouth City Council Local Exhaust Ventilation (LEV/fume cupboards) is one of the risk controls, then this should be checked during the inspection. Another form of proactive monitoring required by the Council, in accordance with recommended good practice, is health and safety management system auditing. This is a formal process of examination of management systems including: policies, organisation structure, arrangements, and records; to identify strengths and weaknesses in compliance with legislation, Council/national standards and best practice. This form of monitoring will be carried out annually on a percentage of service units/schools by the Corporate HSW Team. Reactive monitoring Reporting and investigation of incidents involving hazardous substances (unplanned or uncontrolled events with the potential to cause significant harm or losses), and work-related ill health, should be carried out by managers in service units/schools. This should be done to check whether risk controls are adequate and risk assessments suitable and sufficient, and should always prompt a review of hazardous substances risk assessments. Analysis of accident reports across the Council will be carried out by the Corporate HSW Team to look for trends which may require further investigation and additional guidance, and they or the Occupational Health Service will also investigate serious incidents and report them to the HSE where appropriate. Further guidance and training for health and safety inspection and performance monitoring is available from the Corporate HSW Team.

I. Further Information and Guidance

Advisors Further advice and guidance is available from the Health, Safety & Wellbeing Team, or the Document Library (on the Council Intranet) which contains policies, health and safety guidance, risk assessment forms and some example risk assessments. Contacts: Health & Safety Team Human Resources Civic Centre, Floor 4 Plymouth PL1 2EW Tel: (01752) 304917 Email: [email protected] Occupational Health Service Human Resources Civic Centre, Floor 4 Plymouth PL1 2EW Tel: (01752) 307978 Email: [email protected] Training

HSPS04 April 2006

21

Guide to Hazardous Substances Risk Assessment Plymouth City Council The Corporate Health & Safety Team provides Hazardous Substances and other risk assessment training courses for Council staff (charges will be made to service units/schools with devolved budgets). A list of available courses can be found in the Councils Programme of Scheduled Training Courses, available from the Learning and Development Team in Human Resources (Tel: 01752 307293/307652), and on the Council Intranet or from the Health & Safety Team. Publications and web sites: The Health and Safety Executive (HSE) web site www.hse.gov.uk/coshh/index.htm Legislation and supporting Guidance available from HSE Books www.hsebooks.com/Books/ o The Control of Substances Hazardous to Health Regulations 2002 (as amended), Approved Code of Practice and Guidance L5; o The Chemicals (Hazard Information and Packaging for Supply) Regulations 2002; o The Dangerous Substances and Explosive Atmospheres Regulations 2002, Approved Code of Practice and Guidance L138; o Approved supply list. Information approved for the classification and labelling of substances and preparations dangerous for supply. CHIP Regulations 2002. Approved list L129; o The safe use of pesticides for non-agricultural purposes. COSHH Regulations 1994. Approved Code of Practice L9; o Legionnaires disease. The control of legionella bacteria in water systems. Approved Code of Practice and guidance L8; o Preventing asthma at work. How to control respiratory sensitisers L55; o A step by step guide to COSHH assessment HSG97; o COSHH Essentials: easy steps to control chemicals HSG193; o Health Surveillance at work HSG61; o Seven steps to successful substitution of hazardous substances HSG110; o Monitoring strategies for toxic substances HSG173; o Health risk management: A guide to working with solvents HSG188; o Biological monitoring in the workplace: A guide to its practical application to chemical exposure HSG167; o The selection, use and maintenance of respiratory protective equipment: A practical guide HSG53; o Fit testing of respiratory protective equipment facepieces Information Document HSE 282/28; o An introduction to local exhaust ventilation HSG37; o Maintenance, examination and testing of local exhaust ventilation HSG54; o General ventilation in the workplace HSG202; o Assessing and managing risks at work from skin exposure to chemical agents: Guidance for employers and health and safety specialists HSG205; o Workplace Exposure Limits: for use with COSHH Regulations 2002 (as amended) EH40. o (The Corporate HSW Team has access to electronic copies of these documents, and many more in a web-based library, but is unable to supply copies to other Council staff for reasons of cost.) continued o There are many chemistry texts available which contain COSHH and DSEAR information, such as Croners: Substances Hazardous to Health, Dangerous

HSPS04 April 2006

22

Guide to Hazardous Substances Risk Assessment Plymouth City Council Substances, and Emergency Spillage Guides; and, Brethericks Handbook of Reactive Chemical Hazards. There may be British/European Standards available from the British Standards Institute (HSW Team does not have access to these). Product safety data sheets, and additional instructions for safe use, from manufacturers and suppliers. Guidance from Council departments e.g. Cleaning/Caretaking safety guidance from the Asset Management Section of Corporate Resources. Guidance from Trade Associations, industry or professional bodies, and Trades Unions. CLEAPSS School Science (and D&T) Service www.cleapss.org.uk , Laboratory Handbook, Model Risk Assessments, HAZCARDS, Recipe cards, student safety sheets, bulletins, newsletters, guides.

HSPS04 April 2006

23

Product/ substance name

Guide to Hazardous Substances Risk Assessment Plymouth City Council

Appendix 1. Hazardous Substances Inventory Checklist

Manufacturer/ supplier Total amount Location(s) used Storage location Date delivered/ produced Process/ activity Safety data sheet up-to-date Product of reaction/process

Waste disposal requirements

HSPS04 April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council

Appendix 2. Hazardous Substances Risk Assessment Form (HSRA1)

Activity/ process or Area assessed:

Hazardous Substances Assessment Reference No. Assessment date Persons who may be affected by the activity (i.e. are at risk) Emergency contact details: Form
(solid, liquid, gas etc.) From safety data sheet

Total no. of sheets used:

SECTION 1. Identify Hazardous Substances and hazards related to them Hazard(s) Number Substance very toxic, toxic, harmful, corrosive, irritant, flammable, explosive etc. WEL 8hr limit 15 min limit

Flash point +
explosive limits

R phrases

SECTION 2: Who might be exposed, how often, and how much? and identify any secondary hazards from mixing substances. Substance Staff group/other + how many Frequency + length of exposure Level of exposure Secondary hazard from mixtures? High, med, low No. exposed

SECTION 3. How might exposure occur? - routes of entry and injuries or health effects that could result. Route of exposure if yes Substance Consequence of exposure No. Inhalation Ingestion Absorption Injection Skin Eyes Other

Health Surveillance/ Monitoring arrangements

HSPS04 April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council

SECTION 4. Emergency procedures and waste disposal arrangements Substance No. Emergency procedures First aid actions, spillage procedures, fire/explosion etc. Waste disposal arrangements

SECTION 5. Risk Controls - For each substance identified in Section 1, list existing control measures. (Repeat form for continuation sheets) Further action needed to reduce risks Reduced Risk
S P R

Substance No.

Existing controls in place to reduce risk you must check Residual Risk that these controls are actually working: eg general ventilation; LEV; fume cupboard; gloves (specify S P R type); eye protection (specify); RPE (specify); protective clothing (specify); DSEAR zone; no ignition sources; minimise amounts; training; other (specify).

Name of Assessor(s)

SIGNED Department Service Unit

(S) Severity of health effect : Minor = 1; Serious = 2; Major = 3; Fatal = 4 (P) Probability of exposure: Very unlikely = 1; Unlikely = 2; Possible = 3; Likely = 4

(R) Risk Rating = SxP: Low = 1-3; Medium = 4-6; High = 8-10; Very high = 12-16

HSPS04 April 2006

26

Guide to Hazardous Substances Risk Assessment Plymouth City Council

SECTION 6 List these: 6.2 Vulnerable Staff List these:

6.1 Best Practice Standards

Are there any relevant best practice Are there any staff who may be standards or legal requirements which particularly vulnerable and at risk. should be followed for the hazards being If so, a personal risk assessment assessed? e.g. Council Policies, or should be carried out. guidance (corporate or departmental), legislation, HSE guidance or Approved e.g. young persons (under 18); Codes of Practice, British or European new and expectant mothers, staff Standards, professional or trade with disabilities or health guidance. conditions that might increase risk. SECTION 7. Action Plan list how the further action required, as identified in Section 2, will be undertaken. Costs / resources required Target Date Action by whom? Completion Date

Hazard

Action Required

I confirm that this hazardous substances risk assessment is an accurate reflection of the risks and controls in place YES / NO The further action required, as outlined in the Action Plan above, will be achieved by the target dates YES / NO see below*

*Managers comments (if further resources are required etc.)...

..

Signed by responsible manager: NAME.Signature..Date....

Review date

For guidance on completing this form, please refer to Council Health & Safety Performance Standard HSPS04 Hazardous Substances Risk Assessment available on the Health, Safety & Wellbeing Document Library, where further copies of this form can also be obtained.

HSPS04 April 2006

27

Guide to Hazardous Substances Risk Assessment Plymouth City Council

Appendix 3. Plymouth City Council REGISTER OF RISK ASSESSMENTS COMPLETED

DEPARTMENT/ SCHOOL SERVICE UNIT / SECTION
Ref. no. Work activity / hazard assessed Date of
assessment

Risk Level
Low/Med/High/, V.High or Risk Score

Review date

SIGNED: Head of Service/ Head teacher

NAME: (please print)

DATE:

A copy of this Register should be maintained by the Head of Service / Head teacher. A copy should th also be sent to Corporate Health, Safety & Wellbeing Team. HR, 4 Floor, Civic Centre.

HSPS04 April 2006

Guide to Hazardous Substances Risk Assessment Plymouth City Council

Appendix 4. EXAMPLE Hazardous Substances Risk Assessment

Dev/Highway XX 21/12/05 KEYGRIP EPOXY 924 HIGH-FRICTION SURFACING SYSTEM (Trustseal Ltd). 2 component epoxy binder, heated to 22C and mixed before application to bituminous surfaces, and graded (1-3mm) Chinese calcined Bauxite aggregate is added. Activity/ process or Area assessed:

Hazardous Substances Assessment Reference No. Assessment date

Total no. of sheets used: 4

Persons who may be affected by Highways operatives the activity (i.e. are at risk) (refuse operatives near store) Emergency contact details:

Trustseal Ltd, 10 Southfield Lane Industrial Estate, Whitwell, Worksop S80 4NW. Tel: 01909 722662

Form
(solid, liquid, gas etc.)

WEL
From safety data sheet

Flash point + explosive

limits

SECTION 1. Identify Hazardous Substances and hazards related to them Number Substance Hazard(s) very toxic, toxic, harmful, corrosive, irritant, flammable, explosive etc. 8hr limit

R phrases 15 min limit 100-105C 36/37, 43,45, 48/21, 50,53

Binder Part A Epoxy resin

Liquid

Binder Part B Epoxy resin

Irritant/harmful danger of serious damage to health by prolonged contact with skin, very toxic to aquatic organisms + may cause long term adverse effects to aquatic environment. Toxic/corrosive may cause harm to unborn child, may cause long term adverse effects to aquatic environment. N/a

Liquid

91C

21/22, 24/25,34, 36/37, 39, 43, 45,48/21,53,61 10 mg/m -105C 2-9.5% 12

Bauxite

Propane heating fuel

Extremely flammable, heavier than air, gas/air mixtures are explosive, asphyxiant at high concentrations.

Granul es (dusty) LPG

HSPS04 April 2006

29

Guide to Hazardous Substances Risk Assessment Plymouth City Council

SECTION 2: Who might be exposed, how often, and how much? and identify any secondary hazards from mixing substances. Substance Staff group/other + how many Frequency + length of exposure Level of exposure Secondary hazard from High, med, low No. exposed mixtures? 1,2,3,4 6 Highways operatives Daily for 2 operatives, occasional for Up to 44 Kg epoxy resin, None others. + up to 1000 Kg Propane. 4 Refuse staff near store at Prince Daily Up to 4xfull 47 Kg None Rock depot cylinders + 4 x empty SECTION 3. How might exposure occur? - routes of entry and injuries or health effects that could result. Route of exposure if yes Substance Consequence of exposure Health Surveillance/ No. Monitoring arrangements 1,2,3,4, 1,2-Irritant/harmful. 3 nuisance.4 Headache, vomiting, None Inhalation
disorientation. Toxic/corrosive None

Ingestion

Absorption Injection Skin

1,2 sensitisation. 1,4 irritant. 2 toxic, corrosive, may cause cancer. 1,2- irritant. 3 nuisance.

1,2

Eyes

1,2

HSE guidance on dermatitis for operatives. Visual checks by supervisor/OH. N/a

Other SECTION 4. Emergency procedures and waste disposal arrangements Substance/No. Emergency procedures First aid actions, spillage procedures, fire/explosion etc.

Waste disposal arrangements

1,2, (3 - inhalation, eyes + ingestion) 4 inhalation.

First aid Inhalation: remove to fresh air. Seek medical attention if symptoms persist. Eyes: flush thoroughly with lots of water. If irritation persists, seek medical attention. Skin: wash with plenty of soap + water. Ingestion: dont induce vomiting. Give water + seek medical attention.

1,2

3 4

React 1+2 to form inert polymer, then dispose via Chelson Meadow transfer station as controlled waste. 2 same disposal route as 1,2. 4 return cylinders to supplier. Dispose as hazardous waste to a specialist contractor do not allow spillages to contaminate watercourse/sewers. Remaining waste must be treated as hazardous.

1,2,3 4

Spillage/leak absorb in inert material (sand or vermiculite) + sweep into suitable containers for disposal as hazardous waste by specialist contractor (dispose of brushes etc. as contaminated waste). N/a Eliminate sources of ignition + ventilate thoroughly. Fire Use CO2, foam, dry powder or water fog only. Fire fighters must wear BA. Water fog only clear area due to risk of explosion.

HSPS04 April 2006

30

Guide to Hazardous Substances Risk Assessment Plymouth City Council

SECTION 5. Risk Controls - For each substance identified in Section 1, list existing control measures. (Repeat form for continuation sheets) Residual Risk S P R Further action needed to reduce risks Reduced Risk S P R

Substance No.

1,2,3,4

12

Use of alternative Keygrip Thermoplastic Type 1+3 system - heated to 225C.

Tool box talks, staff training refreshers and questionnaires. 4 1 3 3 1 3 12 3 4

1,2

4 2 2

2 3 3

8 6 6

3 4

Existing controls in place to reduce risk you must check that these controls are actually working: eg general ventilation; LEV; fume cupboard; gloves (specify type); eye protection (specify); RPE (specify); protective clothing (specify); DSEAR zone; no ignition sources; minimise amounts; training; other (specify). Good general ventilation in storage area, work in open air. Smoking, eating, drinking banned + hand/eye wash facilities provided at store/on vehicle. Training in system use to BS/EN/ISO 9002 and ADR. First aid kit on vehicle + all work within City boundary close to emergency services. 2 man working at all times on the vehicle/highways. Epoxy resins delivered in ready to use 22Kg packs (x6 in storage, x2 in use per month). 1Propane cylinder 47 Kg on vehicle, (up to 8 in external store). PPE = pvc gloves, face shield/goggles (chem./impact resist), overalls (close woven cotton, non -porous). PPE as for 1,2 + nuisance dust mask FFP3 (disposable). PPE = None Propane is handled + refilled by delivery tanker driver.
SIGNED

Name of Assessor(s)

K.Paull, J.Morgan, P.Godsall, A.Rickard

Regular laundry service needed for overalls. Visual inspection by operatives/supervisor/OH for skin damage. First-aid training. Development + HR

Department Service Unit

Highways + H&S (R) Risk Rating = SxP: Low = 1-3; Medium = 4-6; High = 8-10; Very high = 12-16

(S) Severity of health effect : Minor = 1; Serious = 2; Major = 3; Fatal = 4 (P) Probability of exposure: Very unlikely = 1; Unlikely = 2; Possible = 3; Likely = 4

HSPS04 April 2006

31

Guide to Hazardous Substances Risk Assessment Plymouth City Council 6.2 Vulnerable Staff Are there any staff who may be particularly vulnerable and at risk. If so, a personal risk assessment should be carried out. e.g. young persons (under 18); new and expectant mothers, staff with disabilities or health conditions that might increase risk. List these: None known, but could include asthmatics.

SECTION 6. 6.1 Best Practice Standards List these: Trustseal Ltd. BBA Certificate method statements, Safety Data sheets + instructions for safe use. COSHH Regs 2002, DSEAR 2002, CHIP 2002, ADR and the Carriage Regs 2004. PCC H&S Policy, and COSHH Assessment Performance Standard. HSE RR079 An assessment of skin sensitisation by the use of epoxy resin in the construction industry 2004. See HSE web site www.hse.gov.uk

Are there any relevant best practice standards or legal requirements which should be followed for the hazards being assessed? e.g. Council Policies, or guidance (corporate or departmental), legislation, HSE guidance or Approved Codes of Practice, British or European Standards, professional or trade guidance.

SECTION 7. Action Plan

list how the further action required, as identified in Section 5, will be undertaken.
Target Date Jan 2006 Jan 2006 Completion Date Action by whom? K.Paull to arrange

Hazard

Action Required

Epoxy resins A+B

Specialist laundry service weekly for overalls. Monthly visual inspection of exposed skin for sensitisation reaction.

Hot + cold materials

Emergency first aid training for Gangers + Lead Hands (1/2 1 day)

Costs / resources required ? brief instruction/ training for supervisor contact OH provider. Eg PCFE Appointed person course 24p.p

Mar 2006

K.Paull to arrange

I confirm that this Hazardous Substances Risk Assessment is an accurate reflection of the risks and controls in place YES / NO The further action required, as outlined in the Action Plan above, will be achieved by the target dates YES / NO see below* *Managers comments (if further resources are required etc.)...

..

Signed by responsible manager: NAME.Signature..Date....

For guidance on completing this form, please refer to Council Health & Safety Performance Standard HSPS04 Hazardous Substance Risk Assessment available on the Health, Safety & Wellbeing Document Library, where further copies of this form can also be obtained.

Review date

HSPS04 April 2006

32

Guide to Hazardous Substances Risk Assessment Plymouth City Council

Appendix 5 Risk Phrases

Appendix 6 Safety Phrases

Appendix 7 Symbol, abbreviation, description of hazard

Appendix 8 Dangerous Substances and Explosive Atmospheres Regulations Appendix 9 Principles of good practice for the control of exposure to substances hazardous to health

HSPS04 April 2006

33