2.9 Substance Assessment For Practical Work

Under the COSHH (Control of Substances Hazardous to Health Regulations) the University is obliged to carry out an assessment of any procedure that is likely to expose employees (and including students) to substances that could be harmful in any way to their health.

In addition under DSEAR (Dangerous Substances and Explosive Atmosphere Regulations) employers are required to assess the risks associated with their work involving dangerous substances. It is appropriate to assess dangerous (flammable, oxidising and explosive) substances together with hazardous substances.

What Is A Substance Hazardous To Health?

There Are Essentially Four Definitions:

• A substance (or a mixture of substances) classified as dangerous to health that is required to be labelled very toxic, toxic, harmful, corrosive, or irritant. Note that lead and asbestos are not covered by COSHH, however the potential to their exposure at Bath Spa University needs to be considered according to this Code of Practice;
• A substance with an occupational exposure limit - as noted in the current edition of the Health and Safety Executive document EH40;
• A biological agent (bacteria and other micro-organisms, e.g. legionella.);
• A dust of a substance present in substantial concentrations (as defined by the COSHH Regulations), where there is no indication of the need of a lower limit.

What Is A Dangerous Substance?

A dangerous substance or preparation is legally defined in the DSEAR.

The Three Types Are:

1. A substance or preparation that is required to be classified as explosive, oxidising, extremely flammable, highly flammable or flammable;
2. A substance or preparation which because of its physico-chemical or chemical properties and the way it is used or is present creates a safety risk;
3. Any dust which can form explosive mixtures with air or an explosive atmosphere.

What Is Required To Be Done?

The Head Of A Department / School Must Ensure The Following Requirements Are Carried Out:

• A substance health and safety risk assessment needs to be carried before the start of work involving hazardous substances;
• The precautions needed to protect persons adequately from exposure to hazardous substances needs to be decided;
• The potential exposure must be prevented or adequately controlled and effective arrangements set up to ensure the control measures are used and maintained;
• Health surveillance is required where it is shown to be necessary;
• All the employees and students who may be affected by the substances need to be properly informed, trained and supervised.

The hazard and the associated risk of using all substances need to be considered. The substances present in an area should be listed in a Substance Inventory.

If the work is easily repeated and explained, straightforward, of short duration and in accordance with the supplier's instruction, then a complete written substance risk assessment is not necessary. However a written Substance Risk Assessment is required for all substances that are required to be labelled as toxic or very toxic, sensitising, carcinogenic, mutagenic, toxic for reproduction. Occupational health department should be notified for this type of substance.

When a complete substance risk assessment is not necessary, there is still a requirement to record that the use of the substance has been considered. This can been achieved by a note in the general risk assessment for the work (HS/RA1,see 2.5) involving the substance (s). This provides evidence that the risk requirements have been fulfilled.

For full Substance Risk Assessments, form HS/SRA1 is provided.

The results of the Substance Risk Assessment must be reviewed at least every five years. Reviews should be made whenever the assessment is no longer relevant due to new information or changes in techniques/procedures/substance composition. Specialist member (s) of staff involved with the assessment should sign assessments.

The completed Substance Risk Assessment needs to be signed by an appropriate representative of the Head of Department/School.

A list of the substances that are available in a department/school should be maintained up to date. A Substance Inventory form (HS/S101 in Appendix A) is provided for this purpose

Substance Risk Assessments

A substance risk assessment is a special kind of risk assessment and the requirements to be suitable and sufficient, as noted in 2.5 A Guide to Risk Assessment, apply. A form for a Substance Risk Assessment is available, HS/SRA1 (Appendix B).

Hazard Of Substance

Information On The Hazard Or The Harmful / Dangerous Characteristics Of A Substance (Including Mixtures / Proprietary Products) Can Be Found From A Variety Of Sources.

These Should Include:

1. Supply label on the container. Harmful substances should be labelled as toxic, harmful, corrosive or irritant. (Note: all temporary containers for harmful/dangerous substances must be correctly labelled.);
2. Substance safety data sheets provided from the manufacturer or supplier of the substance. It is a legal requirement that the supplier to provide this data without charge;
3. Health and Safety Executive Guidance Notes and other publications, notably EH40 - a list of statutory exposure limits;
4. Technical reference sources;
5. Professional institutions/trade associations.

Exposure

The likely exposure to harmful substances must be assessed by appropriate analysis. Guidance and advice are available from the Safety Office.

The control of exposure should be based on containment, foremost is by means of apparatus and equipment (the best option is total enclosure of the substance). Safe systems of working (e.g. procedures that restrict numbers exposed and period of exposure) are important. The use of personal protective equipment (PPE), including respiratory protective equipment (RPE), is the last option.

Health Surveillance

Health surveillance is watching out for early signs of work-related ill health in those exposed to health risks, such as exposure to substances hazardous to health. This is achieved by setting up an appropriate procedure. An example of health surveillance is the monitoring of the hands etc of individuals for skin damage arising from the use of certain chemicals.

The health surveillance should be recorded, see Appendix C for a health surveillance form.

• Appendix A - Substance Inventory Form (HS/SI01)
• Appendix B - Substance Risk Assessment Form (HS/SRA1)
• Appendix C - Health Surveillance Form