Code of Practice

See also the University's Policy on CoSHH.

In this Code of Practice:

3 Duties under the law

3.1 Relevant Statutory Provisions are given in depth in Appendix (1).

3.2 Summary

(a) The Health and Safety at Work (HSW) Act (1974) imposes a duty upon the University to ensure that its members can work with safe equipment and materials, in a safe environment. In the case of work with substances hazardous to health, this duty is further reinforced by the requirements of the Control of Substances Hazardous to Health (COSHH) Regulations (1999).

(b) The key requirement of the COSHH Regulations is Regulation 6 (Risk Assessment): “An employer shall not carry on any work which is liable to expose any employees to any substance hazardous to health unless he has made a suitable and sufficient assessment of the risks created by that work to the health of those employees and of the steps that need to be taken to meet the requirements of these Regulations”.

(i) prevent or control exposure to hazardous substances (Regulation 7);
(ii) use, maintain, examine and test control measures (Regulation 8 & 9);
(iii) monitor exposure at the work place (Regulation 10);
(iv) provide suitable health surveillance (Regulation 11); and
(v) provide information, instruction and training (Regulation 12);

(d) Employees must co-operate fully with the provisions made by the Employer to comply with the COSHH Regulations.

4 Responsible Parties

4.1 Policy

The Safety Committee is responsible for determining the University policy on COSHH.

4.2 Advisory

(a) The Health & Safety Office is responsible for advising the Safety Committee and members of the University on the statutory requirements of COSHH and their implementation.

(b) The College / Divisional / Departmental Safety Officer, where appointed by the College Dean / Head of Division / Department, is responsible for implementing arrangements for COSHH.

4.3 Executive

(a) The Registrar and Secretary has the ultimate responsibility to ensure that the University of Exeter complies with all statutory health and safety requirements. He may share this responsibility with :

(b) College Deans / Heads of Divisions/ Departments who are responsible for statutory compliance in their areas of responsibility, eg their College, but they may share this responsibility with:

(c) Supervisors who are responsible for statutory compliance in their areas of responsibility, eg of technical staff, students.

(d) All Staff have a duty to take reasonable care for the health and safety of themselves and others who may be affected by their work. They also have a duty to comply with the University's arrangements for health and safety.

(e) Students, although not employees of the University, are offered the same health and safety protection as employees with respect to COSHH and are similarly required to comply with its arrangements.

5 Arrangements

5.1 Introduction

All processes using substances hazardous to health must be assessed to ensure that no member of the University, visitor or member of the public is exposed to amounts above the allowable limits, and that exposure below these limits is, in all cases, as low as is reasonably practicable.

5.2 Definitions

(a) A Substance Hazardous to Health is one that, on intake into the body, can cause damage to human health. Explosives, flammables, radioisotopes, lead, asbestos etc, although undoubtedly hazardous to health, are not considered under the COSHH regulations, since they are covered by other legislation.

(b) A Carcinogen is any substance known or suspected to induce or promote the development of neoplasm (cancer) in the human body. Such substances are listed in Schedule 8 of the Chemicals (Hazard Information and Packaging for Supply) Regulations 1994 (CHIP 2).

(c) A Biological Agent means any micro-organism, cell culture, or human endoparasite, including any which have been genetically modified, which may cause any infection, allergy, toxicity or otherwise create a hazard to human health.

(d) A Micro-organism means a microbiological entity, cellular or non-cellular, capable of replication or of transferring genetic material.

(e) Hazard, in the context of COSHH, is the potential that a substance has to do harm.

(f) Risk is a combination of the likelihood of a substance will cause harm and the outcome, if harm occurs.

5.3 The assessment

(a) Summary of the assessment process:

Before working with a substance hazardous to health,

(i) Identify the hazardous substance;
(ii) Identify its hazards, physical and chemical properties and;
(iii) Identify the work activities (amounts of substance, physical form, number of those exposed and length of exposure, etc);
(iv) Assess the risk of harm occurring and the outcome;
(v) Reduce the risk by using suitable and sufficient control measures;
(vi) Determine the effectiveness of the control measures;
(vii) Consider health surveillance;
(viii) Consider training needs;
(ix) Record the assessment; and
(x) Inform those involved in the activity (and others who may be affected by the activity, eg other members of the University, contractors and members of the public)

(b) Recording the assessment

The assessment is recorded on a:

University COSHH Assessment Form (Appendix (2))

with the aid of :

Guidance Notes for Scientific Assessment (Appendix (3)); or
Guidance Notes for Non-Scientific Assessment (Appendix (4)).

Assessment forms and Guidance Notes are available from the Health & Safety Office.

Although the assessment is carried out on behalf of the University it is best done by the person or persons who will carry out the work process (or in the case of undergraduate students, their supervisors). They will have, or can acquire, knowledge of the specific hazards and risks involved. The person(s) must be considered competent to make the assessment, by their supervisors (and ultimately the College/Head of Division/Department). This judgement is based on the assessor’s knowledge, experience and training (ie competence). Training courses in COSHH assessment for both scientific and non-scientific staff, are provided by the Health and Safety Office.

(d) Storage of assessment forms

Each University College/Division/Department will be responsible for making its own assessments and for the secure storage of the final forms.

(e) Frequency of assessment

A new assessment must be made before a process is carried out for the first time and whenever the process is altered (eg change of substances, location, worker, etc), or when the previous assessment is considered to be no longer valid.

(f) Review of assessments

All assessments must be reviewed regularly, and in any case every twelve months, to ensure that they are still valid.

(g) Monitoring

A list of assessments made must be supplied to the Health & Safety Office, annually, for monitoring purposes. The forms provide evidence that the University is complying with the COSHH Regulations and, as such, may be inspected by the Enforcing Authorities such as the Health and Safety Executive.

5.4 Schedule of Testing and Maintenance of Control Measures

(a) All fume-cupboards will be tested to ensure that they have an inflow of air with a velocity of at least 0.5 m sec-1, when the sash (the sliding window) has a gap below it of 300 mm.

(b) All ventilated cupboards must have sufficient airflow though them to ensure that any fumes within them are prevented form escaping into the building.

(c) All biological containment facilities (eg biological cabinets) must operate at or above the criteria appropriate to the level of containment specified for them.

(d) All Local Exhaust Ventilation (LEV) systems must operate in such a way as to draw fumes, dusts and vapours away from the face and body of the operators they are protecting and exhaust them safely.

(e) All Personal Protective Equipment (PPE) must be suitable for the purpose for which it is intended, readily available and, where appropriate, regularly tested and maintained.

(f) Requests for qualitative aerial monitoring for hazardous substances may be made to the Health & Safety Office .

5.5 Frequency of Testing of Control Measures

(a) Containment facilities (Fume-cupboards, biological cabinets, etc) must be tested for efficacy every 14 months. Biological cabinets must be checked by a competent person, experienced in their use.

(b) The sash of each fume-cupboard will be labelled as to whether it has passed or failed its flow test, and a report of all test results passed to the College/Divisional/Departmental Safety Officer as soon as possible.

(d) Local Exhaust Ventilation (LEV) systems must be checked for efficiency by velocity or air-current visualisation (smoke) tests at least annually, and preferably more often, by their users.

(e) All LEV systems must be checked and maintained at least once every 14 months by Buildings & Estate maintenance staff.

(f) All defects found in LEV systems will result in a reduction or loss of the control measure and an increase in risk. They must thus be remedied before further use. In all cases contact: Buildings & Estate Division for Emergency Maintenance (4552)

5.6 Schedule of Health Surveillance

(a) All incidents (“near misses”) and accidents involving hazardous substances must be recorded in the accident book and reported (on green University Incident/Accident forms) to the Health & Safety Office.

(b) Health surveillance may be required when working with certain substances (eg carcinogens). If you consider that you may require health surveillance contact the University’s Occupational Health Adviser, based in the Health, Safety and Environment Office (3049).

(c) An Occupational Health Physician visits the University twice per term. Appointments for consultation may be made through the University’s Occupational Health Adviser.

5.7 Information

(a) Material Safety Data Sheets (MSDSs) are the best source of information on hazardous substances. MSDSs must to made available by the manufacturer or supplier of the item, on request of the customer. This is a legal obligation under the CHIP2 Regulations. The World Wide Web also offers an invaluable source of up-to-date information and a selection of sites is given in the Reference Section (s7, p9).

(b) Other information and guidance on making assessments and on the hazards of substances may be obtained through the Health & Safety Office .

5.8 Training

(a) The Health & Safety Office runs periodical training courses on COSHH awareness and the making of COSHH assessments. Requests for information on training courses should be made to the Health & Safety Office .

(b) Videos on the COSHH Regulations may be borrowed from the Health & Safety Office Library, or viewed using its permanent viewing facilities (5th floor, Physics Building).

6 References

Publications*

The Health and Safety at Work (Etc) Act (1974);
Control of Substances Hazardous to Health Regulations (COSHH)(1999)(S I 437);
General COSHH Approved Code of Practice (ACoP) (Control of substances hazardous to health) and Carcinogens ACoP (Control of carcinogenic substances) and Biological Agents ACoP (Control of biological agents);
EH40, Occupational Exposure Limits (published annually by the Health and Safety Executive);
The Chemicals (Hazard Information and Packaging for Supply) Regulations 1994 (CHIP 2) and its various amendments (CHIP 96, 97, 98 and 99);
The Management of Health and Safety at Work Regulations (1992);
The Use of Personal Protective Equipment at Work Regulations (1992);
Health & Safety Office Training Diary;

*All available from the Health & Safety Office

Internet sites

Health & Safety Office home page
Health and Safety Executive home page;
Material Safety Data Sheets (MSDSs) may be found at;

http://physchem.ox.ac.uk/resources.html
http://ilpi.com/msds/
http://www.msdssearch.com/