Managing COSHH in the supply chain

COSHH requires employers to prevent or reduce worker, contractor or other people’s exposure to hazardous substances through risk assessment and the implementation of suitable and sufficient control measures. When it comes to managing the effective control of hazardous substances in the supply chain this can be complex, particularly concerning the need to ensure contractors have the necessary skills and knowledge to COSHH risk assess a job correctly. It’s essential to consider how different substances interact, how cumulative exposure to multiple products occurs and the complexities of specifying controls such as Personal Protective Equipment (PPE). Combine this with the fact that contractors often struggle to produce task-specific COSHH assessments and you don’t have to look far to find examples of companies not meeting their obligations under the COSHH Regulations. 

Consequences of non-compliance

The cost of not complying with the COSHH Regulations is on the rise. Aside from the moral obligation companies have to protect their staff and the environment, changes to health & safety sentencing guidelines introduced last year mean that businesses can now face significant fines and prison sentences, not just for causing actual harm but for creating a risk of harm. In addition there is evidence that health and safety inspectors are increasingly identifying incidents where companies have created inadequate risk assessments and readily raising improvement and prohibition notices. These changes have huge implications for businesses operating in high risk environments.

In 2012 an employee of Cappers Industrial Contractors was engulfed in a hot caustic lime dust whilst operating an open fronted vehicle to shovel a mound of hot lime at the Tata Chemicals Europe plant in Lostock. The accident left the employee with a serious chemical burn. Swift investigation by the Health and Safety Executive, found that unsafe work methods meant employees were exposed to extreme levels of dust. Tata Chemical Europe was fined £339,850, with costs of almost £60,000 after pleading guilty to an offence under Section 3(1) of the Health and Safety at Work Act 1974, and an additional offence under Regulation 12 of the Work at Height Regulations 2005. 

If this incident had taken place following the sentencing guidelines change, the fine, undoubtedly, would have been steeper and may have involved a prison sentence for the directors of the business. 

Companies must ensure that their contractors have suitable and sufficient COSHH risk assessments in place. The engagement of management software systems can simplify this process and, as they continue to improve in terms of usability and affordability, they are becoming ever more accessible. 

Ease-of-use

The Alcumus COSHH system, for example, helps users identify, assess and manage hazardous substances in the workplace, and walks them through the process of completing and delivering fully compliant, task-based COSHH risk assessments. Through the simple Alcumus COSHH interface, companies of all sizes – from a small contractor in need of 10 COSHH assessments to a larger company requiring 5000 – can easily obtain a COSHH assessment. These assessments are provided in an easy-to-follow format with pictograms led by international standards that ensure the document is simple to interpret and ensures ownership. 

Access to experts

Interpreting the COSHH Regulations can require expensive expertise and be time consuming. This is another area where online systems can provide value for money. Alcumus can work as a competent body on behalf of employers and contractors to make sure suitable and sufficient COSHH risk assessments are in place for any anticipated workplace exposure to hazardous substances. The Alcumus COSHH service offers access to an experienced team of chemists, toxicologists, occupational hygienists and health & safety consultants providing competent helpdesk support seven days a week.

The Alcumus COSHH service can be used to monitor improvements in areas such as air monitoring survey results where data can be fed back into the system to track progress. Meanwhile if there are updates to documents such as the HSE’s EH40/2005, the list of approved Workplace Exposure Limits (WELs) or to hazard classifications, these are automatically updated on the COSHH assessment and the user informed via the online system.