COSHH Regulations 2002 – Hazardous Substance Storage

 

What does COSHH require for hazardous substance storage?

The Control of Substances Hazardous to Health Regulations 2002 (COSHH) require employers in Great Britain to assess and control risks from substances hazardous to health. The assessment must include risks arising from storage, handling and disposal. Safe storage measures should reflect the substances, quantities, exposure routes and foreseeable incidents involved, and should form part of the employer’s wider COSHH risk assessment.

 

What is COSHH?

COSHH stands for the Control of Substances Hazardous to Health Regulations 2002.

The Regulations require employers to protect employees and others who may be exposed to substances hazardous to health as a result of work activities.

COSHH applies in Great Britain – England, Scotland and Wales. Northern Ireland has separate Control of Substances Hazardous to Health Regulations.

The principal COSHH duties include assessing risks, preventing or adequately controlling exposure, maintaining control measures, monitoring exposure where required, providing health surveillance where appropriate, providing information and training, and preparing for relevant accidents and emergencies.

 

Does COSHH apply to the storage of hazardous substances?

Yes. HSE guidance specifically states that a COSHH assessment must include the health and safety risks arising from the storage, handling and disposal of substances hazardous to health.

Storage should therefore be considered as part of the complete work activity rather than treated separately from the COSHH assessment.

The level of control required will depend on factors such as:

  • The hazardous properties of the substances.
  • The quantities stored.
  • The type and condition of containers.
  • How frequently substances are accessed or handled.
  • Potential routes of employee exposure.
  • Transfer, dispensing or decanting activities.
  • Potential leaks, spills and releases.
  • Ventilation and workplace conditions.
  • The effectiveness of existing control measures.

 

What substances are covered by COSHH?

COSHH covers a wide range of substances capable of causing harm to health at work.

These can include:

  • Chemicals and chemical products.
  • Dusts.
  • Fumes.
  • Vapours.
  • Mists.
  • Gases.
  • Biological agents.
  • Substances generated by work activities or processes.

A substance does not necessarily need to arrive on site with a hazard label to fall within COSHH. Hazardous substances can also be generated by activities such as welding, cutting, sanding or other industrial processes.

 

Are any hazardous substances excluded from COSHH?

Yes. Some hazardous substances are principally controlled under separate legislation rather than COSHH.

HSE identifies three important examples:

  • Asbestos – covered by specific asbestos legislation.
  • Lead – covered by specific lead-at-work legislation.
  • Radioactive substances – covered by specific radiation legislation.

Other workplace requirements may also apply alongside COSHH depending on the substance and activity involved.

 

What must a COSHH risk assessment consider?

Before work involving substances hazardous to health is carried out, the employer must make a suitable and sufficient assessment of the health risks and identify the steps needed to comply with COSHH.

The assessment should consider matters such as:

  • The hazardous properties of the substance.
  • Information provided by the supplier, including the Safety Data Sheet.
  • How, where and why the substance is being used or stored.
  • The level, type and duration of potential exposure.
  • How workers could be exposed, including inhalation, skin contact or ingestion.
  • The quantity of hazardous substances involved.
  • Relevant Workplace Exposure Limits.
  • The effectiveness of existing or proposed control measures.
  • Activities such as maintenance, cleaning, transfer and disposal.
  • Potential accidents, incidents and emergencies.

The assessment should reflect what actually happens at the workplace rather than relying solely on generic chemical information.

 

Is a Safety Data Sheet the same as a COSHH assessment?

No. A Safety Data Sheet is an important source of information, but it is not a COSHH risk assessment.

Safety Data Sheets provide information about matters including:

  • Hazard classification.
  • Health effects.
  • Exposure controls.
  • Handling and storage.
  • Stability and reactivity.
  • Accidental release measures.
  • Personal protective equipment.
  • Emergency measures.

Employers should use this information together with their knowledge of the workplace, activities and potential exposure to produce a suitable and sufficient COSHH assessment.

 

How should exposure to hazardous substances be controlled?

The objective of COSHH is to prevent exposure to substances hazardous to health or, where prevention is not reasonably practicable, to control exposure adequately.

Employers should first consider whether exposure can be avoided altogether, for example by eliminating a hazardous substance or replacing it with a safer substance or process where practicable.

Where exposure cannot be prevented, suitable control measures may include:

  • Enclosing a process or source of exposure.
  • Local exhaust ventilation.
  • General ventilation where appropriate.
  • Reducing the number of people exposed.
  • Reducing the duration or frequency of exposure.
  • Safe systems of work.
  • Spillage capture and clean-up procedures.
  • Suitable hygiene measures.
  • Appropriate personal protective equipment where other controls do not provide sufficient protection.

Control measures should be proportionate to the health risk and should address all relevant routes of exposure.

 

What does COSHH mean for chemical storage areas?

COSHH does not prescribe one universal chemical store design. The storage controls required should follow from the substances, exposure risks and activities identified in the assessment.

Depending on the substances and workplace, appropriate measures may include:

  • Keeping containers securely closed when not in use.
  • Maintaining clear and appropriate labelling.
  • Separating substances where incompatibility creates additional risk.
  • Providing suitable ventilation where required.
  • Providing appropriate spill containment.
  • Protecting containers against damage.
  • Controlling access to hazardous substances.
  • Keeping quantities at an appropriate level for the work being carried out.
  • Providing arrangements for safe transfer or dispensing.
  • Maintaining spill-response and emergency equipment.

Other legislation and guidance may impose additional requirements where the substances are flammable, explosive, environmentally hazardous or present another specific risk.

 

Do incompatible chemicals need to be segregated?

Chemical compatibility should be considered as part of safe storage and the workplace risk assessment.

Information on incompatible materials can normally be found in the Safety Data Sheet, particularly the sections dealing with handling and storage and stability and reactivity.

Where contact between incompatible substances could create a harmful reaction, release or other hazard, suitable separation or segregation measures should be established.

For packaged dangerous substances, HSE guidance such as HSG71 may provide additional storage and segregation information.

 

Does COSHH require secondary containment or bunding?

COSHH does not establish one universal bund-capacity rule for every hazardous substance store.

However, preventing or controlling exposure can require appropriate arrangements for containing and dealing with spills or releases.

Secondary containment such as bunded storage, spill pallets or other containment systems may therefore form part of the controls identified through the risk assessment.

Separate environmental requirements, permits, guidance or other legislation may also affect the containment capacity and design required at a particular site.

 

What are Workplace Exposure Limits?

Workplace Exposure Limits, commonly known as WELs, are limits on airborne concentrations of certain hazardous substances in workplace air.

Current Great Britain Workplace Exposure Limits are published by HSE in EH40.

Where a substance has a WEL, employers must ensure that exposure is adequately controlled and does not exceed the applicable limit.

For substances such as carcinogens, mutagens and asthmagens, exposure must be reduced to as low a level as is reasonably practicable in addition to meeting any applicable Workplace Exposure Limit.

 

Do COSHH control measures need to be maintained?

Yes. Control measures used to prevent or control exposure must be properly used and maintained in an efficient state, in efficient working order, in good repair and in a clean condition where relevant.

Certain engineering controls, including local exhaust ventilation systems, require thorough examination and testing at specified intervals.

Employers should also ensure that procedures and other non-engineering controls continue to operate effectively.

 

When is exposure monitoring required?

Exposure monitoring may be required where it is necessary to ensure that employees are adequately protected or where COSHH specifically requires monitoring for particular substances or processes.

Monitoring can involve measuring airborne concentrations of hazardous substances and comparing the results with relevant Workplace Exposure Limits or other appropriate exposure criteria.

The need for monitoring should be determined through the COSHH assessment and the nature of the exposure involved.

 

When is health surveillance required under COSHH?

Health surveillance is required in specified circumstances where employees are exposed to substances hazardous to health and the conditions set out by COSHH are met.

Its purpose is to identify signs of work-related ill health at an early stage and check whether workplace controls are adequately protecting employees.

Examples can include circumstances involving substances capable of causing occupational asthma, dermatitis or other identifiable occupational diseases.

The appropriate health-surveillance arrangements should be determined from the substance, exposure and applicable HSE requirements.

 

What information and training must employees receive?

Employees who may be exposed to substances hazardous to health must receive suitable and sufficient information, instruction and training.

This should enable employees to understand:

  • The hazardous substances they may encounter.
  • The risks to their health.
  • The control measures in place.
  • How to use those controls correctly.
  • Relevant Workplace Exposure Limits where applicable.
  • Required personal protective equipment.
  • Safe handling and storage procedures.
  • What to do if a spill, release or other emergency occurs.

Training should be appropriate to the work being performed and updated where significant changes affect the risks or control measures.

 

What does COSHH require for spills and emergencies?

Where the nature of the work creates a foreseeable risk of an accident, incident or emergency involving a substance hazardous to health, appropriate arrangements should be established to protect employees and others who could be affected.

Depending on the hazards involved, arrangements may include:

  • Emergency procedures.
  • Suitable spill-control materials.
  • Emergency washing or decontamination facilities.
  • First-aid arrangements.
  • Means of raising an alarm.
  • Appropriate protective equipment.
  • Employee training and emergency drills where appropriate.

The measures required should be proportionate to the substances and foreseeable consequences involved.

 

What is the difference between COSHH and DSEAR?

COSHH and DSEAR can both apply to the same substance, but they address different types of risk.

  • COSHH principally addresses risks to health from exposure to hazardous substances.
  • DSEAR addresses safety risks arising from dangerous substances, particularly fire, explosion and similar energetic events.

For example, a solvent may create a health risk from inhalation that must be controlled under COSHH while its flammable vapour also creates a fire or explosion risk requiring consideration under DSEAR.

Employers should therefore avoid treating a COSHH assessment as a substitute for a DSEAR assessment where both sets of requirements are relevant.

 

Does COSHH 2002 apply in Northern Ireland?

The Control of Substances Hazardous to Health Regulations 2002 discussed on this page apply in Great Britain.

Northern Ireland has separate legislation: the Control of Substances Hazardous to Health Regulations (Northern Ireland) 2003.

Businesses operating in Northern Ireland should refer to guidance from the Health and Safety Executive for Northern Ireland and confirm the legislation applicable to their activities.

 

How can Chemstore support hazardous substance storage?

Chemstore provides hazardous material storage solutions that can support the control measures identified through a site’s COSHH and wider workplace risk assessments.

For drums and IBCs, the Hazvault range provides bunded chemical storage in a range of capacities and configurations.

For smaller quantities and indoor applications, Chemstore also supplies safety storage cabinets for different hazardous material storage requirements.

Storage equipment should be selected according to the substances, quantities, compatibility, workplace conditions and findings of the risk assessment. No individual storage product replaces the employer’s duties under COSHH.

 

Where can I read the official COSHH requirements?

The Health and Safety Executive and UK legislation website provide the primary sources for COSHH requirements in Great Britain.

 

Important information

This page provides general information about the Control of Substances Hazardous to Health Regulations 2002 and hazardous substance storage in Great Britain. It does not replace the Regulations, HSE guidance, Safety Data Sheets, a COSHH assessment or advice from a competent person.

The controls required for an individual workplace should always be determined from the substances, quantities, activities, exposure risks and site-specific conditions involved.