Health and Safety is complex, sometimes counter-productive and costly. Legislation can be overbearing and often misinterpretted. Is this true? Yes, I believe so, though we still have to do it nonetheless. Whether or not you agree with this statement does not matter, what we can all agree with is that a practical and common sense approach must be taken. This is where our perception of what the Health and Safety Executive requires and what people generally believe can differ greatly.
The first part of my Director's diary is going to look at the reasons I wish to comply with the HSE CoSHH regulations and what the HSE might expect from me as a person responsible for the health and safety of others. There are three reasons off the top of my head that I feel that I need to comply with the CoSHH regulations for, these are one - the health and safety of my employees, two - so that Mr. HSE Inspector doesn't see fit to close me down, and three - I have no wish to receive free accommodation at Her Majesty's pleasure (prison).
So what exactly did I have to do? Well, it helps if you start with the basics. I'm not talking about the 'nitty gritty' of the regulations, I'm talking about looking after a human being that is doing something I have asked under the reasonable expectation that I would not put them at any significant peril. If I am buying chemicals and asking a worker to use them then it makes common sense that I must make that task safe. For today we can sit the regulations to one side whilst we concentrate on the safety of my workforce. We Director's already have our most powerful allie in our plight for CoSHH compliance - common sense.
It makes perfect sense to me that if I find out what the hazards are with the use of a chemical, train my worker appropriately and give them any personal protection, such as gloves and goggles that I'm told they need, then I've done a pretty good job already. In fact, I'm of the sound belief that I would only expect someone else to do a job that I'd do myself - but that's just me. At a meeting with a senior representative of the HSE I was told that health and safety is not about paperwork, it's about doing the job properly and by that he meant safely. If you don't believe me give the HSE help line a call and ask them "Which is more important, collecting paperwork for an inspection or doing something safely?". This might seem a simple answer but only when you put it so plainly does it dawn on most people that paperwork is only there as evidence if something goes terribly wrong, not discounting training aids and work instructions. Ideally a CoSHH assessment should be a work instruction which identifies the hazards of a chemical and the task it is used in.
So where did I start? In order to make a safe process we need knowledge, resources and leadership. Let's look at the first aspect, knowledge. I know that I buy chemicals and that some of them may or may not be hazardous. I know my staff use them and so they would most likely know something about them and I know we already have CoSHH assessments somewhere but I'm not sure when they were last updated or who's looking after them. I also know the hazard and safety information is contained with Safety Data Sheets which are freely available from manufacturers although sometimes difficult to obtain.
The first thing that springs to mind now is that in order to make my company a safe place to work where chemicals are concerned, I need to find out what's being done. My first job was to instruct my line managers to start building a register of all the chemicals that are being used and a list of the ones that are not (those left lying around). This list would then be my focal point to start with collecting all the Safety Data Sheets from the manufacturers. I believed they where in the office somewhere, probably covered in dust and was pretty sure they would be out-of-date. It made sense to start from fresh with my new list of used and unused chemicals. I have given my line managers one week to collate the necessary data so that they may prepare for collecting the Safety Data Sheets. If the HSE visit at any point between now and then I can show that I'm already putting the wheels in motion towards a safer workplace and for now business must continue. Although this initial exercise is a timely and therefore costly process it is important to understand the chemicals we are using and their hazards. It will also be nice to clear out those chemicals that are no longer being used or those that are 'unidentified'.
Next week I will continue my diary with how I practically implemental a common sense approach to CoSHH assessment and CoSHH compliance.
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Dale Allen has developed an online
CoSHH assessment tool to help companies comply with the CoSHH regulations. Find out more about producing compliant CoSHH assessments with access to a managed Safety Data Sheet library with the UK's leading
CoSHH compliance authority, COSHH365.
