27 October COSHH – culling chemicals Are you at risk of failing before you start? Many organisations quail when faced with the sheer number of substances to capture with their COSHH Assessments, to the extent that they don’t know where to start. Desmond Tutu once wisely said “there is only one way to eat an elephant: a bite at a time.” By this he meant “everything in life that seems daunting, overwhelming, and even impossible can be accomplished gradually by taking on just a little at a time”. Here are a few simple steps to start the process and make it more manageable. Start with a meaningful COSHH inventory Get an understanding of the scale of the problem, and try to reduce it. Instead of compiling an extensive list of chemicals, assemble an inventory of hazardous substances, taking into account potential straightforward solutions or simplifications as outlined below. Get rid of redundant materials– if materials are no longer required, then arrange for their safe disposal. This way, you no longer need to include them in your COSHH Inventory or in the resulting COSHH Assessments. Don’t waste your time assessing non-hazardous substances – At a very early stage in the process, identify which of the substances in your inventory or non-hazardous, as these do not need to be included in your COSHH Assessments Group very similar materials– It is quite common for similar risks to be posed by similar substances that are used in a similar way. By way of example, different coloured paints may all pose the same risks to the health of the user. Different oils and lubricants may be grouped together if the hazards, uses, and routes of exposure are the same. In such cases, it is extremely likely that all of the like materials used in the same way can be grouped together for the purposes of the COSHH Assessment. Departmental lists– Delegate the responsibility of creating the COSHH inventory to respective departments. This approach offers the advantage of distributing the workload, although it is essential to ensure everyone fulfils their responsibilities. Additionally, this method simplifies the identification of redundant materials and facilitates grouping similar substances. Investing in some training may be necessary, but the time spent will not be in vain. Don’t be fooled by different names – check out some of the substances on your lists that are used for the same thing (such as lubricants, cleaning materials, etc.). This will help to keep the list looking shorter. Need a further culling? Having collated a meaningful, but substantially reduced, list of substances it is may be prudent to perform a second review to reduce the list further. Meet with department heads and request that they actively look to reduce the list size, with a focus on avoiding use of some of the more hazardous materials. Challenge a few of the long held beliefs about whether chemicals are really needed. An Approved List of substances To prevent the COSHH inventory from just growing again, introduce a level of control in the form of an approved list of substances. This should limit what people can purchase without getting further agreement. Anything that is not on this list needs to be authorised to ensure: it is already covered (different name for largely the same thing), or we have agreed to the provision of a new substance, and a preliminary assessment of risks (COSHH and other) has been undertaken. The COSHH Assessment work still needs to be done, but now it is on a reduced number of substances and with less time being wasted on unnecessary work Need help? If you still need assistance, then by all means get in touch as we will try to point you in a sensible direction