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					                                                                 Control of Substances
                                                                  Hazardous to Health,
                                                                        COSHH, Policy

SETTING THE POLICY STATUS

1.1      This is the Council’s corporate policy on the control of substances hazardous
         to health, COSHH. The policy sets minimum standards that all stakeholders
         must meet. This includes:
         •    Chief Officers
         •    managers. This means anyone who has responsibility for managing
              employees, including school-based staff
         •    employees
         •    health and safety representatives
         •    the Corporate Health and Safety Advisory Service.

1.2      Departments can adopt higher standards and adapt the guidance that
         supports this policy to meet their operational needs and arrangements.

1.3      The policy is based on the Council’s ‘Health and Safety Risk Assessment
         Policy’, which is the basis for all health and safety compliance. COSHH
         assessments support the general risk assessments carried out by managers
         by assessing the risks of hazardous substances, if these have been
         highlighted as a hazard in the general assessment.

         Departmental arrangements

1.4      Departments are responsible for:
         •    formally adopting this policy
         •    devising arrangements that meet corporate COSHH standards
         •    producing written evidence outlining their practical arrangements for
              implementing the corporate policy. These will include:
              −      details of the people with specific responsibilities
              −      implementation action plans, with timescales
              −      performance measures and the ways of monitoring them.

         Approval

1.5      Departmental arrangements and guidance must go through the Council’s
         normal consultation process. They must be approved by the:
         •    departmental management team
         •    departmental Joint Consultative Committee, JCC
         •    Corporate Personnel Adviser - Occupational Health, Safety and Welfare.

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DEMONSTRATING COMMITMENT

2.1      The Council is committed to protecting its employees’ health, safety and
         well-being. We believe that the best way to do this is through a proactive
         health and safety management system based on risk assessment. This
         includes ensuring employees are not put at risk, so far as is reasonably
         practicable, by any substances or chemicals used or produced as a result of
         work activities.

2.2      The Council is committed to meeting its legal obligation to do ‘suitable and
         sufficient’ COSHH assessments for all work activities involving hazardous
         substances.

ASSURING MINIMUM STANDARDS

3.1      We will base our approach to controlling the risks from substances on the
         requirements of current law and the latest guidance from the Health and
         Safety Executive, HSE. Eight principles of good practice have been
         introduced for controlling the risks from hazardous substances, which are…

         •    Processes and activities must be designed and operated to minimise the
              release and spread of hazardous substances.
         •    All relevant exposure routes, such as inhalation, skin absorption and
              ingestion, must be taken into account when developing control measures.
         •    Exposure must be controlled by measures that are proportionate to the
              health risk.
         •    The most effective and reliable control measures, which minimise the
              escape and spread of hazardous substances, must be chosen.
         •    Where adequate control of exposure cannot be achieved by other means,
              suitable personal protective equipment, PPE, should be provided.
              However, this must be done in combination with other control measures.
         •    Control measures must be checked and reviewed regularly for their
              continuing effectiveness.
         •    All employees must be informed and trained on the hazards and risks from
              the substances they use at work, and the control measures developed to
              reduce those risks.
         •    The use of control measures must not increase the overall risk to health
              and safety.

3.2      The adequate control of exposure to hazardous substances will require us to:

         •    apply the eight principles of good practice
         •    make sure that Workplace Exposure Limits are not exceeded for any
              substances that have them
         •    make sure that exposure to substances that can cause occupational
              asthma, cancer or damage to genes is reduced as low as is reasonably
              practicable.



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3.3      The eight principles must be taken into account when developing
         departmental arrangements for COSHH. These can be broken down into five
         main elements:

         •    identifying hazardous substances and exposures
         •    assessing and evaluating the risks from them
         •    developing and implementing control measures to reduce the risks
         •    providing information and training
         •    monitoring and checking the effectiveness of the control measures.

         Identification

         • identify all hazardous substances linked to work activities and the hazards
           that these substances have. Substances will include those generated by
           work activities and biological agents, such as micro-organisms.
         • determine how much of each substance is used or produced by the work
           activity. This includes dusts and fumes generated, from example,
           soldering and welding.
         • identify who might be exposed to the substances and how that could
           happen. This will include how often the substances are used.
         • encourage employees and their health and safety representatives to be
           actively involved in COSHH assessments and risk management.

         Assessment and evaluation

         • evaluate the risk of harm occurring taking into account:
           −      the chance of exposure happening
           −      how often exposure is likely to happen
           −      what level of exposure could happen and for how long.
         • involve the Occupational Health Service. This is to make sure any health
           risks are adequately covered, and health surveillance programmes can be
           set up when necessary.
         • record the significant findings of COSHH assessments and use them to
           devise clear written safe working procedures.
         • make sure assessments are reviewed regularly and revised when
           necessary.

         Development and implementation

         • make sure positive action is taken to deal with any risks identified. The
           aim is to prevent exposure to hazardous substances, if it is reasonably
           practicable to do so. Actions will include assessing the effectiveness of
           existing precautions, such as local exhaust ventilation.
         • develop and implement measures to control the exposure, such as general
           ventilation or containment if appropriate.




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         • prepare plans and procedures to deal with accidents, incidents and
           emergencies, if the assessment highlights that these are necessary.
         • monitor the exposure of employees to hazardous substances, if the
           assessment highlights that this is necessary.

         Information and training

         • provide clear information for employees.
         • provide training, instruction and supervision for employees.

         Monitoring

         • monitor preventative and control measures to make sure they’re effective,
           and take urgent steps to improve them if they’re not.

3.4      Guidance on implementing COSHH is given in the ‘Control of Substances
         Hazardous to Health Policy - Managers’ Guide’.

SHOWING ACCOUNTABILITY - ROLES, RIGHTS AND RESPONSIBILITIES

4.1      Policies only work when they make things happen. It helps if everyone’s clear
         about what they need to do…

         Chief Officers

4.2      Chief Officers and their senior management teams are responsible for making
         sure their department meets the requirements of this policy. This means they
         must:

         •    oversee the development and implementation of departmental
              arrangements and action plans
         •    make sure significant issues highlighted by COSHH assessments are
              used to help shape business planning processes, and resources are
              prioritised for managing any risks identified by the assessments
         •    show their positive and visible commitment to making sure that employees
              are not exposed to risks from hazardous substances
         •    actively check that their managers do COSHH assessments and monitor
              the results.

         Managers

4.3      The Council believes that risk assessment is a key management responsibility
         of equal importance with other business activities. Managers should have the
         detailed knowledge of their employees, workplaces and activities that is vital
         for the risk assessment process. Part of this includes preventing potentially
         harmful exposure to hazardous substances to employees and other people,
         such as contractors and members of the public.


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4.4      Managers are responsible for:

         •    doing COSHH assessments for any activities they control that involve the
              use of hazardous substances
         •    making sure substances specified for work activities present the least risk
              to the health of employees and other people
         •    making sure employees and their health and safety representatives are
              involved in the risk assessment process
         •    devising, implementing and reviewing safe working procedures
         •    monitoring health and safety performance by doing regular workplace
              inspections, spot checks and audits
         •    making sure employees use the control measures needed to control or
              prevent exposure to hazardous substances
         •    making sure only specified, risk-assessed substances are used in work
              activities
         •    setting up systems to make sure control measures are checked and
              maintained
         •    identifying their employees’ health and safety training needs through
              COSHH assessment and task monitoring.

         Officers who commission or specify work

4.5      Officers have COSHH assessment duties if they:

         •    design work for others to do
         •    specify how a task has to be done, the materials, substances or equipment
              to be used. This will include any substances generated by work tasks,
              such as welding fumes
         •    commission work from contractors.

4.6      These duties include:

         •    assessing the risks linked to the use of hazardous substances through
              their designs, instructions or specifications before they’re finalised
         •    adjusting their designs, instructions or specifications after their
              assessment to eliminate or reduce risks. This will include making sure that
              any substances specified for work activities present the least risk to the
              health of employees and other people
         •    passing their findings, especially details of any residual risks, to the person
              or contractor doing the work
         •    working with contractors to develop COSHH assessments and
              preventative measures for contracted work, if hazardous substances are
              used. This will be a joint exercise between the specifying officer and the
              contractor. This is to make sure that only specified, risk-assessed
              substances are used in work activities.




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         Corporate Health and Safety Advisory Service, CHSAS

4.7      This team’s corporate responsibilities include:

         •    developing and reviewing corporate policy, standards and guidance on
              COSHH
         •    providing a corporate overview and strategic guidance
         •    monitoring and reporting on corporate performance for COSHH
         •    auditing and reviewing COSHH arrangements and performance, as part of
              the Council’s health and safety management system
         •    identifying any trends or problems that require a corporate response
         •    giving specialist advice and assistance to managers on occupational
              health, safety and welfare issues.

4.8      The team’s departmental responsibilities include:

         •    giving support, advice and information to managers, employees and health
              and safety representatives on COSHH
         •    helping managers to:
              −       identify potential risks from using hazardous substances
              −       complete COSHH risk assessments
              −       specify the necessary control and protective measures to minimise
                      these risks
         •    monitoring the ongoing effectiveness of control and protective measures
         •    developing the arrangements and guidance departments need to
              implement this policy. These should include specific monitoring
              arrangements and departmental standards for this policy
         •    developing implementation action plans in conjunction with departmental
              management teams. These will include promotion of this policy and
              identifying employees responsible for its implementation
         •    managing the consultation and approval process for their arrangements
              and plans
         •    checking that arrangements are implemented and COSHH assessments
              are done
         •    monitoring the standard of assessments
         •    reporting progress and problems through the appropriate management
              system. This may include their departmental management team, JCC, or
              the Corporate Health and Safety Committee, CHSC
         •    co-ordinating and monitoring employees’ COSHH assessment training and
              competence.

         Employees

4.9      Employees have a legal right to be consulted about work-related risks and the
         protective measures in place to deal with them. These include the use of
         hazardous substances. The Council believes that employees’ knowledge of
         work tasks is vital to make sure:



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         •    risk and other health and safety assessments, including COSHH, are
              realistic and complete
         •    control and protective measures are practical and effective
         •    any problems are identified and dealt with quickly.

4.10     Employees have responsibilities as well as rights. These include:

         •    reporting any hazards, risks or unsafe situations they identify at work
         •    being co-operative and proactive in all health and safety issues. This
              includes following safe working procedures and using control measures
              introduced to reduce their exposure to hazardous substances
         •    only using specified, risk-assessed products, and not buying or bringing
              into work any unauthorised chemicals
         •    following any training and instructions given to them
         •    reporting any problems or shortcomings in the Council’s health and safety
              arrangements. This includes any concerns they have about COSHH
              assessment and the use of hazardous substances.

         Trade union health and safety representatives, HSRs

4.11     HSRs have legal rights in the workplace. These include the right to:

         •    inspect and take copies of any documents linked to health and safety in
              the workplace, including COSHH assessments
         •    be consulted about any planned changes that could affect their members’
              health and safety
         •    monitor and review COSHH assessments, policies and departmental
              arrangements
         •    investigate hazards, accidents and their members’ complaints
         •    do inspections.

PROGRESS THROUGH PARTNERSHIP

5.1      The Council recognises that a co-operative partnership approach between all
         stakeholders is essential for effective risk management, including controlling
         the risks of hazardous substances. Managers have the primary responsibility
         for getting COSHH assessments done, and managing any identified risks.
         They must work together with employees and their HSRs throughout the
         COSHH assessment process.

5.2      Managers need the support of other stakeholders to help them. This will
         include:

         •    backing and financial support from Chief Officers
         •    help and co-operation from employees
         •    advice and support from HSRs
         •    information, guidance and support from occupational health, safety and
              welfare specialists

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MEASURING PERFORMANCE - AIMING FOR CONTINUOUS IMPROVEMENT

6.1      We need to check that the policy is working, and that the minimum standards
         it sets are being met across the Council. If things aren’t going well, we need
         to know why, so action can be taken. Our aim is for work activities to be as
         safe and healthy as possible.

6.2      To do this, we will develop a range of monitoring arrangements and
         performance indicators, dovetailed into our health and safety management
         system. These arrangements will include:

         •    reviewing and updating policy and guidance regularly
         •    making sure minimum standards are applied consistently
         •    monitoring the progress of health and safety objectives and tasks against
              agreed timescales
         •    carrying out a planned programme of inspections and audits
         •    producing health and safety performance reports
         •    benchmarking our health and safety performance against comparator
              organisations.

EMPOWERING EMPLOYEES THROUGH TRAINING

7.1      The Council has a legal duty to provide suitable health and safety training for
         its employees. This must be:

         •    adapted to the needs and capabilities of the employees it’s aimed at
         •    provided during normal working hours. If this isn’t possible, then
              employees must be paid, or given time off in lieu, to attend outside their
              normal hours
         •    ‘topped up’ by refresher training at reasonable intervals.

7.2      Suitable training can be provided in a range of ways. Depending on the
         individual circumstances, this might include on-the-job training with another
         experienced employee, ‘toolbox talks’ or team briefing sessions, formal
         accredited courses, practical workshops, mentoring or coaching schemes.

7.3      Departments are responsible for:

         •    organising suitable COSHH assessment and other related training for their
              employees. This will include managers who will be carrying out the
              assessments, and employees who will be using the hazardous substances
         •    making sure all employees attend appropriate training sessions within
              reasonable timescales
         •    keeping adequate training records.




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PROVIDING INFORMATION AND GUIDANCE
8        Stakeholders may need advice and information to help with COSHH
         assessment. Here are some suggested sources…

         Within the Council

         •        The Corporate Health and Safety Advisory Service.

         •        Trade union health and safety representatives.

         Outside the Council

         •        The Health and Safety Executive, HSE.
                   www.hse.gov.uk.
                   www.coshh-essentials.org.uk

         •        The Trades Union Congress, TUC.
                   www.tuc.org.uk

         •        UNISON.
                   www.unison.org.uk

         •        GMB.
                   www.gmb.org.uk

         •         Unite - T&G Section.
                  www.tgwu.org.uk

         •        NASUWT.
                   www.teachersunion.org.uk

         •        NUT.
                   www.teachers.org




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NOTES PAGE




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