Last week in my CoSHH diary I explained my reasons why I wished to comply with the HSE CoSHH regulations for my business and to start producing compliant CoSHH risk assessments. This week I will be looking at what I discovered in my investigation which focused on producing a list of chemicals my business was using and what we knew about them. My line managers reported on the lists of chemicals on Monday morning and we discussed their findings together.
So what did I find out? Well I was shocked to find that of the fifty or so chemicals we had, we could only account for roughly thirty being used or identifiable. It was my suggestion that we should try to dispose of any of the chemicals we did not use or to try to recycle them elsewhere. The chemicals must be removed appropriately for which we would speak to the local council to start moving things forward. I asked for the name of the line manager and the chemical (if available) to be recorded for each and every disposal. My main purpose here was to ensure that if something was disposed of that we needed then I knew where to point the finger. This was a straight forward and reactive response which almost halved the amount of work we had to do and gave the additional benefit of opening up more space on our shop floor and in our storage bay areas.
I spent a good while on Tuesday reviewing the information on the chemicals. I decided to have a walk round the shop floor and speak with some of my staff. It occurred to me that if we could not account for the use of roughly fifty percent of our chemicals then it would be fair to say that we would have pretty limited knowledge of the one's that we did. Consider this a surprise inspection from a HSE health and safety inspector. I asked two simple questions of each of my staff, one - "do you know where the CoSHH assessments are for the chemicals you are using?", and two - "do you have access to the Safety Data Sheet for that?". Could you take a guess at how many CoSHH assessments and Safety Data Sheets I actually saw? Zero. This would be the type of person that I would feel like if we had a real inspection from a real HSE inspector. I urge you to get up out of the comfort of your own chair and do the same, hopefully you'll have a better result than I did. This task if nothing else confirmed the need for an overhaul of our health and safety policy and in particular our CoSHH compliance.
One of my more forward thinking line managers came to see me on Wednesday afternoon to say that he thought the chemical clearout was a great success. One of his team had come to see him and had said that some of the people in his team had been ordering different brands of the same chemical and that one type of chemical could be purchased at a reduced cost to do all of the activities. They even went as far as to find a more suitable non hazardous alternative. Well, immediately upon finding this information out a light bulb flicked on in my brain! Can you guess what I was thinking? Hopefully! I asked my line manager to do another job for me. This time, knowing that we had a good list of what we were using I wanted him to go through all the chemicals our business used and rationalise the list. His objective was to group all the chemicals that we used into their appropriate applications/uses and then look for the safest and economical alternative to cover the variety of applications.
As I did not want to create more unnecessary work it made perfect sense to wait to see the results of this new task before producing any health and safety documentation. In the meantime I decided to nominate my line managers for CIEH certification in the principles of risk assessment. I invited a training provider to give a one day group training session on Tuesday of next week. This would give me the confidence that my team would be able to sufficiently identify risks and adopt safer working practices.
My diary will continue next week with my way forward for investigating tasks and producing compliant CoSHH risk assessments.
Dale Allen develops systems and online software to help you succeed in HSE CoSHH compliance. Find out more about how to effectively manage and produce a compliant CoSHH assessment free with the UK's leading CoSHH compliance authority, COSHH365. by Dale Allen |
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