New COSHH Measures; New Risks
The development of effective processes and new COSHH measures are essential to a safe and happy workplace.
They also involve substantial investment in time, energy and money. However, the temptation to shoe-horn process revisions into an existing system, without examining the potential for undermining the safety of the process, should be resisted. Furthermore, consideration should also be made to related processes.
Fine Balance
The balance of an effective system can easily be disturbed by the introduction of a seemingly innocuous process change.
The introduction of ear defenders into a system might on the face of it appear to be a simple and uncontroversial matter. However, if this reduces hearing sensitivity and, as a consequence, warning buzzers or alarms are made redundant, clearly this exposes an operator to an extra, unintended risk. Systems need to be reviewed in the context of even minor revisions.
Consequential Impacts
Considering a system in isolation should be avoided. When reviewing a process system, care should also be taken to avoid the potential for risk to related processes.
An example would be the modification of a system that increases the levels of aerosols in an LEV (Local Exhaust Ventilation) system. If, in a subsequent maintenance process, that equipment cannot then be fully decontaminated before maintenance-staff are given repairs to do, there may well be a consequential increased risk of explosion.
Rigorous System Review
When introducing further steps in a process system, careful consideration should be made in order to maintain the levels of energy and rigour that were committed to the initial process system.
Regulation 3 of HSE Management Regulations require that: “Any assessment shall be reviewed by the employer or self-employed person who made it, if — (a) there is reason to suspect that it is no longer valid; or (b) there has been a significant change in the matters to which it relates. Where, as a result of any such review changes to an assessment are required, the employer or self-employed person concerned shall make them.”
Long Term Solutions
All process systems should be considered as a whole. All process solutions need to retain currency and remain viable at all times. In order for systems to be safe they should be carefully followed but when processes are altered, improved or updated they should then be considered to be fluid enough to adapt to those changes and mitigate any consequential unintended risks.
Summary
Whilst COSHH measures are a substantial and demanding part of modern working practice they needn’t be overly onerous. A good balance between the review of potential risks and costs can be found.
Workplace Exposure is on hand to help you find that balance. New measures can expose workers to new risks. We will help you to identify and then to mitigate those risks. Often a simple and cost-effective process solution can be found with a careful process review.
We’re here to help
If you need any help or advice, we’re happy to assist. Our experienced occupational hygienists have many years experience covering a wide range of industries. We can carry our air monitoring to assess the exposure levels, give advice on any control measures and provide recommendations to help you comply with the COSHH Regulations and the new limits.
Our approach
Get in touch with Workplace Exposure, either give us a call on 0800 689 4386, or fill in our enquiry form to discuss your monitoring or consultancy requirements.
We’ll then provide you with a no-obligation proposal, we can often give an initial idea of fees whilst we discuss your needs.
Once you’ve accepted our proposal we can then schedule the work.
Following our site visit we’ll provide you with a comprehensive report giving you advice, recommendations and control measures where appropriate.
Implement the outcomes for compliance and a happier healthier workplace.