Implementing CoSHH Management - A Director's Diary (Part 1 of 4)
Published Date: 10th August 2009
If you run a business you will already know that Health and Safety is complex, sometimes counter-productive and holds little or no return for your investment. Is this true? Yes, I believe so, though we still have to do it nonetheless. There may be people that may frown upon this statement and suggest that in some way I do not care about the health of my employee's. This is where our perception of what the Health and Safety Executive requires and what people generally believe, differ greatly.
The first part of my Director's diary is going to look at the reasons why 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. So it stands to reason that if I buy a certain hazardous chemical and ask that person to use it then I must do something to make sure it is used safely. Again, let's put the regulations and paperwork to one side for a different day when I know my workforce is already safe. Let's talk about something we Director's should all have already and be putting into good practice - 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? To do something safely requires knowledge, resource 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 that I need Safety Data Sheets that contain most of the hazard and safety information I need on the chemical and these can be obtained from manufacturers and suppliers.
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 knew we had some around the offices and had no idea if they where up-to-date. It made sense to start from fresh with my new list of used and unused chemicals. I have set a date for next week to have this list put together and then I can set my managers to work collecting the Safety Data Sheets from manufacturers. 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. This first exercise is a time consuming and therefore costly process but I need to make sure my workers understand the chemicals they are working with and then we can decided what is safe and what needs further risk assessment. It will also be nice to clear out those chemicals that are no longer being used or those that are 'unidentified'.
My diary will continue next week with how I put my resources together and made a start towards practical and compliant CoSHH assessment.
Link to Diary Week Two.