Policy, Organisation and Arrangements
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POLICY, ORGANISATION AND ARRANGEMENTS
References
-The Health & Safety at Work Act 1974
-The Management of Health & Safety at Work Regulations 2002
-The Control of Substances Hazardous to Health (COSHH) Regulations 2002
-Approved Codes of Practice for Biological Agents, Carcinogens, and General COSHH (L5)
10.20Definitions
Assessment / -A written record detailing the hazards, an evaluation of the risks to health and of any control measures necessary to remove or reduce risk.Hazardous Substance / -Any substance capable of causing adverse health effects or disease.
Risk / -The risk from a substance is the likelihood that it will cause harm in the actual circumstances of use. The degree of risk will vary depending on the potential severity of the harm that could be caused.
Substance / -A substance may be a solid, liquid, gas, fume vapour or a micro-organism.
10.30Legislative Requirements
The Control of Substances Hazardous to Health (COSHH) Regulations 2002 require that no work must be undertaken with any substance that may cause a hazard to health unless a full assessment of the health effects has been undertaken and the controls necessary for safe working have been identified and put in place.
The Regulations require that the assessment must be carried out by a competent person, taking into account which substances employees are liable to be exposed to, what effects the substance could have and the ways in which any person may come into contact with it.
Following assessment, the competent person, in consultation with the employer, should make a decision as to what control measures are necessary to eliminate, reduce or adequately control the risks.
Employers are then responsible for ensuring that all necessary control measures to eliminate, reduce or adequately control exposure are put in place and are required to regularly review assessments and control measures, in any case where:
-There is any evidence to suspect that they are no longer valid
-There has been a significant change in work activities to which the assessment relates
Employers must ensure that employees, and others who may be affected by work activities involving the use of hazardous substances, are provided with suitable and sufficient information, instruction and training on:
-The hazards
-The nature and degree of the risk to health
-The required control measures and how to use them properly
-The reasons for Personal Protective Equipment (PPE) and clothing, and the jobs where these are necessary
-The measures to be taken in emergency
10.40Organisation and Arrangements
The Company Safety Manager at Slough is appointed to act as the lead manager for the implementation of the COSHH Regulations 2002 and Company Policy and Procedures for effecting COSHH compliance, within Hygiene Group Limited.
The Company Safety Manager will liaise with management throughout the Company to ensure that adequate arrangements are in place to enable Hygiene Group Limited to meet its legal obligations under the COSHH Regulations 2002.
Responsibilities relating to the implementation of Company COSHH Policy and Procedures, for all managers and staff, are detailed in Paragraph 1.6 below.
Hygiene Group Limited has nominated and trained, Company COSHH Assessors for each Branch and/or Region, who will be responsible for undertaking new and/or local COSHH assessments. A list of COSHH Assessors is shown in Appendix One to this Section.
Only Company approved substances are to be used during work activities at Hygiene Group sites and other locations where Hygiene Group employees operate. A list of Company approved substances is detailed in Section 20.00 of this Manual.
A full assessment of all substances on the list of Company approved substances has been carried out in accordance with the requirements of the COSHH Regulations 2002. Copies of all completed COSHH assessments are contained in Section 30.00 of this Manual along with copies of Material Safety Data Sheets (MSDS) for all substances.
Company employees will be provided with suitable and sufficient information, instruction and training on the safe use, handling and disposal of hazardous substances. In addition, a summary of safety data relating to substances is contained in the Chemical Cards issued to all relevant employees during Induction training.
Company Safe Working Practices contain detailed information on the safe use of hazardous substances. Wherever possible, generic information relating to a range of substances having similar uses and common hazards is supplied, in order to simplify the process.
A summary of points for safe working with hazardous substances is shown at Appendix Three to this Section.
10.50Introduction of New Substances to the Inventory
Before any new substance in introduced for use anywhere within the Company, a full assessment of the risks to health must be undertaken. The Manager for the area concerned is responsible for ensuring that the following procedure is followed with regard to the procurement and use of new substances:
-Obtain Material Safety Data Sheet (MSDS) for substance(s);
-Clearly identify how the substance is to be used, stored, transported and disposed of;
-Require Branch/Regional Company COSHH Assessor to undertake full assessment;
-Establish Safe System of Work; Compile Safety information for users;
-Pass all information including MSDS and completed COSHH assessment to the Company Safety Manager at Slough, for approval and allocation of a unique reference number;
-Where appropriate, arrange for any protective equipment and clothing to be provided, make provision for emergency situations and spill clean-up procedures, and train employees who will use the substance(s) during work activities, in safe working practices;
-Inform first-aiders and/or clients(s) of new chemical hazard;
-Introduce new substance into service; add to inventory.
N.B. A process flow-chart outlining the requirements and responsibilities for the introduction of new substances to the inventory, is shown at Appendix Two to this Section.
10.60Responsibilities
The Joint Managing Directors of Hygiene Group Limited are ultimately responsible for ensuring that the Company has in place, the necessary organisation and arrangements to satisfy the requirements of the COSHH Regulations 2002.
Business Managers are responsible to the Joint Managing Directors of Hygiene Group Limited, for ensuring that Company Policy and Procedures relating to the requirements of the COSHH Regulations 2002 are effectively applied in all areas under their control.
Regional Managers are responsible to their respective Business Managers for ensuring that arrangements for compliance with the Company COSHH Policy and Procedures are in place at all locations within their sphere of influence.
The Company Safety Manager (Slough) is responsible for ensuring that adequate arrangements are in place to enable the Company to meet its legal obligations under the COSHH Regulations 2002. This will include:
-Regular review of the Policy and Procedures relating to the implementation of COSHH
-The nomination and training of sufficient numbers of COSHH Assessors to meet Company needs, through consultation and co-operation with Line Managers throughout the organisation
Managers are responsible for the implementation and effective day-to-day management of Company Policy and Procedures for ensuring compliance with the requirements of the COSHH Regulations 2002. This will include as a minimum, the need to ensure:
-That the correct procedure for the introduction of new substance(s) to the inventory (paragraph 1.5 above), is strictly applied
-That a current and valid COSHH assessment and Material Safety Data Sheet is available for all substances in use
-That employees are given suitable and sufficient information, instruction, training and supervision, to enable them to follow safe systems of work
-That employees are provided with, and use, any necessary personal protective equipment and clothing before being required to undertake any work activities involving the use of hazardous substances
-That safe systems of work are followed by all employees, through adequate supervision
-That redundant hazardous substances are correctly and safety disposed of via a licensed contractor for hazardous waste
-That the correct procedures are followed in any emergency situation involving hazardous substances (e.g. spillages), in accordance with Section 40.00 of this Manual
Supervisors and Chargehands are responsible for overseeing the day-to-day arrangements for COSHH in areas under their control. In particular:
-To ensure that employees understand what they should do, what precautions they should take and when they should take them
-To ensure that employees properly use any personal protective equipment and clothing that is provided by the Company for their health and safety
-To ensure that employees do not endanger themselves or others, through exposure to hazardous substances
-To ensure that they fully familiarise themselves, and the employees under their control, with the procedures to be taken in any emergency situation (e.g. spillages)
Employees are responsible for using all control measures put in place, or provided, by the employer. In particular, employees should:
-Not endanger themselves or others, through exposure to hazardous substances
-Use/wear in a proper manner, personal protective equipment (PPE) or clothing provided by the employer for their health and safety
-Practice a high standard of personal hygiene, and make proper use of facilities provided for washing, showering or bathing and for eating and drinking
-Remove any protective equipment or clothing which could cause contamination, before eating, drinking or smoking
-Report promptly to management, any defects discovered in any control measure, device or facility, or any item of PPE
Appendix One
AUTHORISED COMPANY COSHH ASSESSORS
Region / Name / PositionHead Offices / Helen Millership / Group HR/Safety Manager
North / Iain Devine / Technical Manager
South / Siân Thomas / Regional Manager
South / Dave Maxwell / Account Manager
South / Helen Haigh / Contract Manager
South / Trevor Horne / Account Manager
Appendix Two
Appendix Three
A SUMMARY OF POINTS FOR SAFE WORKING WITH HAZARDOUS SUBSTANCES
General
-Never work with a substance unless you know the precautions required
-If you are unsure about the hazards associated with the substance – ASK
-Always read labels and safety data sheets
-Ensure all PPE and RPE is looked after and used properly – report concerns immediately
-Ensure you know how to use the PPE/RPE provided
-Know how to deal with spillages – where to get help, and who to contact
-Always practice good house-keeping
-Know emergency procedures and what to do if you have been exposed
-Know where your nearest first aider can be contacted
-Keep your supervisor informed of any concerns
-Always take training seriously and follow the guidance provided
-Always follow procedures
-Store all hazardous substances in the correct, designated place – do not allow the accumulation of hazardous substances, or empty containers in your work area
-Never mix substances unless you have been authorised to do so
-Never transfer a substance to another container without labelling the container – ensure the containers are of an approved design
-If you have to dilute substances, ensure the correct dilution is achieved -higher than planned concentrations may pose additional hazards
-Report any medical conditions to your supervisor – they could have an influence on your safety while working with hazardous substances.
Skin Protection
-Avoid contact with the substance if possible
-Always use the correct protective gloves and inspect for holes and tears before use
-Use barrier and skin conditioning creams
-Always cover cuts and abrasions
-Never wash your hands with solvents
-Check your hands on a regular basis
-Change soiled clothes as soon as practical
-Always wash hands after handling hazardous substances and dry on a clean towel – even if you have worn gloves
Ingestion Protection
-Always practice good hygiene habits – never eat or drink after handling hazardous substances unless your hands have been washed.
Protection from Substance Inhalation
-Avoid breathing vapours, gases and fumes if possible
-Use extraction equipment where provided
-Ventilate the area
-Use Respiratory Protective Equipment (RPE) where provided
-Never sniff substances to find out their identity
-Never smoke when using solvents
-Keep all containers tightly closed when not in use
N.B.: This list is neither exhaustive nor exclusive.
Author: H.M. / Approved: SMT / Date: 19.05.06