Last week in my first CoSHH diary entry I explained my reasons for wanting to comply with the HSE CoSHH regulations for my business. This week I will be looking at what I found in my initial investigation which focused on finding out which chemicals my business was using and what we knew about them. My line managers delivered various lists of incomplete data to me on Monday morning as I had asked them to do the week before.
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. My simple suggestion here was to dispose of anything we were not using in any of our processes or recycle them to other businesses. 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. If the finger of blame needed to be pointed in the future then I would have the information I needed to do so. 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 took a walk around the shop floor to speak with 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?". Can you guess how many CoSHH assessments and Safety Data Sheets I 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! Do you know what my thoughts were? 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.
It now made sense to wait for the results of these findings before producing any health and safety documentation as I did not want to create unnecessary work. 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.
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