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Employers must provide adequate and suitable training to ensure that people working at their premises (i.e. workers and contractors, etc) can effectively apply and use the control methods, the personal protective equipment (PPE) and the emergency procedures put in place to protect workers from hazards.
They must also provide sufficient and appropriate supervision and instruction to ensure that people at work do not endanger themselves or others by not knowing what they should do, what precautions they should take, and when to do so. They must ensure that workers understand the risks.
Biological agents include bacteria, parasites, cell cultures and other micro-organisms. They are classified into four groups according to their severity, the risk of infection, how easily and quickly they can pass from one person to another, and the availability of treatment.
The Control of Substances Hazardous to Health Regulations (COSHH) applies to biological agents where the exposure may cause ill-health effects and the exposure arises out of the deliberate intention to use or work with them, or is incidental to the work activity as may be the case with refuse disposal, sewage purification and healthcare. COSHH does not apply to biological agents where exposure is not directly nor incidentally related to the work activities, such as catching a cold from a colleague.
It must be emphasised that biological hazards do not just apply to hospitals and labs. In London a council worker died from TB (Tuberculosis) after coming into contact with some of the poorest and most vulnerable people (who are at high risk from TB). The trade union advised the employer in this case that it must manage the problem by identifying staff at risk, screening them, and offering vaccinations to those not immune. Residential homes' staff face a similar problem from MRSA (Methicillin Resistant Staphylococcus Aureus).
COSHH imposes specific requirements when dealing with biological agents. These requirements include:
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For Northern Ireland, see the guidance notes on the HSENI website
A carcinogen is any substance which CHIP (The Chemical (Hazard Information and Packaging for Supply) Regulations) or COSHH recognise as having a potential to cause cancer. Hardwood dust is one example. A mutagen is a substance which can alter chromosomes or genes.
Risk assessment is especially vital when considering carcinogens or mutagens because the development of noticeable ill-health effects may take place many years after the first exposure, there may not be any early warnings of adverse effects, and treatment options may be limited. The risk assessment should identify if carcinogens or mutagens are present and if so, the nature and extent of the risk, and ensure that effective control measures and other precautions are planned and taken. If possible, carcinogens or mutagens should not be used, or produced as waste or by-products.
COSHH applies to carcinogens and mutagens as it does to other hazardous substances, except that where it is not reasonably practical to completely prevent exposure by using alternative substances or processes, COSHH has other requirements. If possible, the employer must totally enclose the process and handling systems; if this is not possible, the employer must do the following:
If the control measures fail and carcinogens and mutagens may have escaped into the workplace, the employer must immediately inform workers and others who may be affected, and only allow those carrying out repairs and other necessary work into that area. These personnel must be provided with suitable PPE, including respiratory protective equipment (RPE).
Due to the potential serious health effect, air monitoring is normally necessary. Health surveillance is appropriate in all cases of exposure unless exposure is so adequately controlled that there is no reasonable likelihood of an identifiable disease or adverse health effect. The risk of cancer from exposure generally cannot be presumed to be reduced to zero unless exposure is prevented, and as there may be no short-term indications of adverse effects, it is especially important to ensure that information, training and instruction is of an appropriately high standard.
CHIP requires suppliers of dangerous substances and preparations (mixtures), including chemicals and animal and vegetable matter, to provide information about the hazards on labels (if supplied in a package), and to package the chemicals safely so that the contents won't escape during normal handling. An example already used is household bleach which has a warning label, so when used at work COSHH applies, and household washing-up liquid which is not as harmful, has no label, and therefore is not covered by COSHH.
The warning label must include the name, address and telephone number of a supplier within the EU, Norway or Iceland; the name of the substance and trade name if it is a preparation; an indication of the danger and corresponding symbol, risk and safety phrases; any EC or EINECS number.
Under COSHH and CHIP, when hazardous substances such as chemicals are poured through pipes, etc. or into smaller containers (for example into a cleaner's spray bottle), employers are required to ensure that the contents, their nature, and any associated hazards are clearly identifiable on the pipes and containers, etc. This is to prevent substances bought by employers in bulk being supplied to workers in smaller amounts without adequate labelling and information about what they are using, since this could lead to their misuse or put the worker at extra risk.
Obtaining material on dangerous substances should be easy as the law requires all suppliers to provide specific information on hazards. However, in practice the law is often abused and very rarely enforced.
CHIP requires that safety data sheets be supplied with all substances classified as dangerous, including the 2,500 on the HSC's approved supply list, and any other substances if likely to be harmful even if they do not appear on that list. There are some exceptions, such as if a substance is bought in a shop and intended for the general public, but general safety information still needs to be provided.
Safety data sheets must be in English, even where a substance is supplied from abroad, but safety reps might want to agree for them also to be available in another language if there are workers who do not have English as a first language.
Safety data sheets must contain 16 headings. One problem is that safety data sheets supplied from outside the EU often do not comply with EU law. Many chemicals are imported from countries such as the USA where the information required on the sheets is very different. However, if a substance is imported into the UK the supplier has a responsibility to provide a data sheet which complies with the EU law.
Safety data sheets can be invaluable in helping employers carry out a COSHH risk assessment, but are not a substitute for an assessment, and employers cannot rely solely on information given within them. They vary considerably in quality, and many are inaccurate or incomprehensible. Further information on the hazards should be sought, and there are a wide range of independent sources of information available both commercially and free on the internet.
There is no obligation under CHIP for employers to provide safety data sheets directly to workers. However, the Health and Safety at Work Act (or Health and Safety at Work (Northern Ireland) Order) requires employers to give all necessary information to their workers where it is necessary to ensure their health and safety at work. The HSE's and HSENI’s Approved Code of Practice (ACoP) on safety data sheets, states that "safety data sheets should be regarded as open documents and they, or the information they contain, should be available to workers".
Within the safety data sheets, the supplier must give "sufficient" information under the headings listed below so that the user can decide how to protect people at work. The safety data sheets must include:
Identification of the substances/preparation and company - the name or trade name of the substance. A trade name, such as "Safety Cleaner" is the brand name given by the manufacturer. It does not tell you what chemicals are in the product or whether it is a mixture or a single chemical. The same chemical may be used in a variety of products with different trade names. The name that is given here should be the same as that used on the label. The name and address of the supplier, along with an emergency telephone number should also be given.
Composition/information on ingredients - of the substance or preparation. It is not necessary to always give the full composition and their actual concentrations, but sufficient information must be given to allow the employer to readily identify the risks.
A generic name for a chemical describes a family or group of chemicals. For example "chlorinated hydrocarbons" is the generic name for thousands of different chemicals. Sometimes a generic name is listed but this is not sufficient as different chemicals within the same family may have very different effects. The actual chemical names must also be given. For example, methyl chloroform is one of the many chlorinated hydrocarbons. The chemical name is the easiest name to use when trying to get information on its health effects and how to protect against them.
A CAS and EC or EINECS number should also be given. The CAS number is useful when searching for information because different chemicals may have the same name, but never the same CAS number. About 23 million chemicals have been assigned a CAS number. The EINECS is the European Inventory of Existing Commercial Chemical Substances, a list of 100,000.
Hazard identification - Hazard identification of the most dangerous hazards that the substance or preparation presents, the specific hazards, the likely effect on health, and the symptoms relating to uses and possibly misuses. Usually it will describe how the substance is likely to be hazardous (inhalation, touch or swallowing,) and is likely to use a number of specific risk and safety phrases. Examples of risk phrases include "may cause cancer" or "toxic by inhalation". Safety phrases tell the user what and what not to do, such as "do not empty into drains" or "wear suitable gloves". In some cases, a supplier will only give a number instead of the phrase. Perform a Google search on it or have a look at the list on the HSE's or HSENI’s websites.
First aid measures - Brief and easy to understand information on what first aid or medical attention is required in the event of exposure to the substance, subdivided according to the type of exposure (inhalation, skin contact, swallowing or eye contact). Both the symptoms and effects should be given including whether any may develop later. What is to be done immediately and whether professional medical assistance is likely to be required should be indicated.
Fire fighting measures - How to extinguish any fire involving the substance, what kind of extinguisher should not be used, whether any additional hazards are likely in a fire, such as an explosion or creation of toxic gases.
Accidental release measures - The personal and environmental precautions needed if such were to happen, including how to clean up any spillage.
Handling and storage - Whether any special precautions are needed including technical advice on matters such as ventilation, humidity, temperature and time limit for storage, and whether special precautions are required for packaging and containers for this substance.
Exposure control - The ACoP on safety data sheets makes it clear that PPE is a secondary line of defence. All other methods of control and prevention must first be considered. If PPE is necessary, specify the type that will provide adequate and suitable protection; this might include eye, skin or hand protection and breathing apparatus (RPE).
Physical and chemical properties - Of the chemical including appearance (solid, liquid or gas), colour, description of any smell, boiling, melting and flash-point (the temperature at which it will ignite), disposal properties, vapour pressure, relative density, solubility and pH (whether it is an acid or alkaline (and its strength) or if it is neutral).
Stability and reactivity - Any conditions and materials to avoid such as light, pressure, acids, water or anything likely to make the substance unstable or hazardous, and any dangers if the product decomposes.
Toxicological information - A "concise but complete and comprehensive" description of the various health effects which can arise if someone is exposed to the substance, including for the different types of exposure, the symptoms, and the immediate and long-term effects including the possibility of cancer or effects on any future children.
Ecological information - The likely effects the substance may have on the environment, including how it degrades, the long and short-term effect on plants, animals and other organisms, and whether it is likely to affect the ozone layer or contribute to global warming.
Disposal consideration - How to dispose of the substance safely, including reference to any specific EU or UK laws.
Transport information - Any special precautions for transportation both inside and outside the employer's premises.
Regulatory information - The health and safety information on the label that is required by law, any specific EU or UK law that relates to the substance, and any Occupational Exposure Limit values (OELs). OELs are set by competent national authorities or other relevant national institutions as limits for concentrations of hazardous compounds in workplace air. OELs for hazardous substances represent an important tool for risk assessment and management, and valuable information for occupational safety and health activities concerning hazardous substances.
Other information - The ACoP recommends that information here could include training advice, how to get further information, and any sources of data used to compile the data sheet, plus the date of publication or revision of the sheet unless stated elsewhere.
Remember that many data sheets are inaccurate or incomplete. If you suspect this, try to get an accurate and complete sheet and ensure that you do a full COSHH risk assessment.
The HSE and HSENI websites have a lot of useful information including specific pages on:
Hazard symbols and risk and safety phrases
These web pages also include the user-friendly guides:
Alternatively, just go to the HSE home page or HSENI homepage and select from the list of health and safety topics.
To ensure that they are fulfilling their legal duties, where employers are not able to prevent exposure to harmful substances but are having to control exposure to harmful substances then they should have a copy of the following publications:
Other useful websites for safety data sheets include:
