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Boosts to Manufacturing in Key Industries Can Lead to Shortfalls in COSHH Compliance.

Updated: Apr 17, 2020

The fight against #COVID19 has impacted heavily on manufacturing organisations. Some having to upscale production to meet the demand to put onto them. But what does this mean for businesses from a health and safety standpoint? Some questions have been raised here and we are here to provide the answers..

  • Due to the emergency crisis that we face, are the HSE looking to relax your duties under COSHH?

  • Can you exceed your 14-month LEV thorough examination and test because of the crisis?

  • Can we become more reliant of PPE and relax our approach to the hierarchy of control?

  • Do we still need to undertake a COSHH risk assessment on new and existing chemical agents brought on-site?

Make no mistake about it... you are still expected to comply with COSHH and the HSE are still enforcing against non-compliance.

Now more than ever, your workforce needs you to step up and keep investing in their health, safety and wellbeing.

Think about this, by relaxing your requirements under COSHH you could be putting your workforce at an increased risk of exposure to hazardous substances. The moral, financial and legal implications of this are severe and despite the pandemic, these workers are owed a duty of care under the law.

Examples of a key industry which is still operating on a mass scale is the food industry. Flour dust or Grain Dust are two of the main culprits for causing work-related illness through exposure across the food production sector. So why should suitable and sufficient controls be maintained?

"Flour dust is a known human sensitiser and can have devastating effects on health, even at low concentrations. Not only is it explosive, it is capable of causing acute and chronic asthma through inhalation."

The food industry is booming at the moment. Especially following the spell of panic buying which was eventually clamped down on by the supermarket chains. Demands were set high to restock the shelves and as a result, more staff were brought in, production lines were added and more materials were brought in. So if you work in the food industry, what are you legal and moral obligations? Let's take a look.

COSHH Regulation 6: Assessment of the Risk to Health Created by Work Involving Substances Hazardous to Health

Some of our clients are facing shortages of key materials or ingredients. That said, they're having to find alternatives to continue producing. When this is the case, a suitable and sufficient COSHH Risk Assessment is a must. Undertaking the assessment on any new hazardous substance should be prioritised prior to use.

Under Law, a suitable assessment of risk should be undertaken, and that goes for existing substances. Reviewing your COSHH Assessments is necessary. To comply with your legal obligations, simply revise and review new and existing material safety data sheets, revisit current processes and access control measures. From this, you can make the required changes to reduce risk.

COSHH Regulation 7: Prevention or Control of Exposure to Substances Hazardous to Health

Controlling exposure to substances hazardous to health is a key part of ensuring the health and safety of your workforce. Here we can reflect on the Hierarchy of Control which sets out various levels of control in order of prioritisation and effectiveness.

A combination of all of the above can lead to residual risk, which will ultimately protect the worker from unnecessary and harmful exposures through inhalation, ingestion, injection and absorption.

COSHH Regulation 8: Use of Control Measures

The application of control measures can save lives. Preventing ill health, whichever route of exposure, should be a primary focus in any COSHH risk management program.

Control of hazardous substances can be in-depth. If you are unsure how to approach this, consult with a professional occupational hygienist. In this article, we'll touch on the basics which is fine initially. However, some substances may need managing differently. Remember, choosing the right method of control at the design phase will prove to be the most cost-effective approach.

Further to eliminating or substituting a hazardous substance, suitable and sufficient engineering controls can be applied. For example, enclosures, extraction systems, barriers, ventilation and so on. The more common method of engineering control is the use of a Local Exhaust Ventilation (LEV) System, often combined with an enclosure of some kind.

The primary function of an LEV system is to capture or remove the contaminant at the source of emission. Which is important for controlling a hazardous substance.

Take welding for example. The process is found in most workplaces and poses a great level of risk, if not managed sufficiently. Local extraction in the form of a capture system can be placed close to the weld pool, maximising its ability to extract the fume at the source. These are often the preferred method of controlling welding fume, however, it can be argued that they're rather ineffective on their own. Particularly due to their low capture distance and impracticability during welding. On-tool extraction has proven effective in minimising exposures by extracting at source.

The application of administrative or management controls, such as task rotation, permit to work systems, training then the further application of Personal Protective Equipment, or Respiratory Protective Equipment can also combine with the use of engineering controls to achieve lower levels of exposure.

Remember, controlling hazardous substances is not optional, it is a legal requirement and failure to do so may result in prosecution.

COSHH Regulation 9: Maintenence, Examination and Testing of Control Measures

We've heard of many businesses attempting to cut the costs during the COVID-19 pandemic. This is understandable, considering the uncertainty around the economic climate. However, the HSE has made it clear that if work commences during the outbreak, and a foreseeable risk of exposure still exists, then a suitable and sufficient maintenance, examination and testing program should remain in place.

An example of this is what we call a Thorough Examination and Test of an LEV system. In addition to these, routine inspections and the regular upkeep of a maintenance and checking schedule or logging system should still remain in place.

All LEV system maintenance, examination and testing should meet the standards outlined in the HSE Guidance HSG258.

COSHH Regulation 10: Monitoring Exposure in the Workplace

Exposures to chemical agents can be measured using various methods. Quantitative data can be obtained by undertaking Workplace Air Monitoring or Biological Monitoring. Exposures can be measured by testing the air quality during a specific process, or by obtaining biological samples from the worker to measure metabolites to determine exposures. Biological sampling can take into consideration exposures through various routes of entry to the body. Whereas, air monitoring is concerned with the inhalation of a hazardous substance.

Exposures concentrations are compared with the legal limits set out by various occupational hygiene standards. Primarily, the UK focuses on the limits set by the HSE in the EH40: Workplace Exposure Limits Document.

COSHH Regulation 11: Health Surveillance

Implementing a suitable and sufficient Health Surveillance Program is key to ensuring workers are not suffering any ill health effects as a result of being exposed to hazardous substances.

Many companies employ a professional occupational health provider to undertake and manage their health surveillance programs. This way, the desired level of competency can be applied to undertaking such assessments whereby accurate information can be obtained to evaluate things such as Lung Function by spirometry.

Let's Keep the Standards High

Despite the epidemic, many businesses are continuing to manage their COSHH programs effectively. However, it's evident that there are many businesses who are struggling to keep up with their legal obligations or choose not to during these difficult times.

This article is a reminder of what is STILL expected of you when it comes to managing COSHH. We understand that times may be difficult, however we are still here to help and support new and existing customers by offering free, professional advice.

Where possible, Workplace Scientifics are still undertaking assessments among facilities that continue to operate as a key workforce during the COVID-19 pandemic. Although the way we approach things will inevitably differ due to government guidelines, we are still passionate about supporting you through this challenging time by helping you manage and control workplace exposure.

Despite the issues we currently face, Workplace Scientifics continues to send out the same message. Let's reduce work-related illness by building partnerships, creating safer working environments, together.

In these trying times, support is often needed. We are here to help! Contact us for free, honest and professional advice today.

(T) 01709 931299

Feel free to visit our website for more information at

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