How to Comply with COSHH Regulations (Steps 5-6 of 8)

Jessica Clifton

by Jessica Clifton

9th October 2019

In this article, the latest in our series on COSHH (Control of Substances Harmful to Health) regulations, we look at steps five and six of the eight steps necessary to comply. You can read about the first two steps – ‘Risk assessment’ and ‘Decide on which precautions to take’ – here; and steps three and four – ‘Prevent or control exposure to hazardous substances’ and ‘Ensure the controls you put in place are used and maintained’ – here

How to comply with COSHH Regulations: Step 5

Monitor exposure

Once you have put your control measures in place, it is time to monitor these measures. In order to comply with COSHH regulations, you should measure the concentration of hazardous substances in the air your employees breathe. You must investigate and document:

  • Serious risks to health if control measures have malfunctioned or deteriorated
  • When exposure limits have or may be exceeded
  • Control measures may not be functioning correctly

This is not a mandatory requirement if you can demonstrate that you are preventing or controlling exposure in a different way. For example, this could be achieved by putting an alarm system in place that sounds when it detects a hazardous substance.

COSHH regulations mean you have to undertake health surveillance for employees exposed to hazardous substances

In instances where you need to conduct personal air monitoring, sampled air should be taken from the ‘breathing zone’, or the space around your employee’s mouth. Monitoring exposure can also refer to biological samples, such as breath and urine tests.

All documents and records you produce on exposure monitoring should be kept and maintained for a minimum of five years. If an employee has a health record (this is necessary documentation if an employee is health surveillance – see step 6), any results that are directly relevant to them must be kept with their health record, and the employee be able to access their record. 

How to comply with COSHH Regulations: Step 6

Undertake health surveillance where necessary

Certain circumstances related to individual employees make it mandatory under COSHH to carry out health surveillance. These circumstances include when an employee is:

  • Exposed to the substances listed in Schedule 6 of COSHH, including vinyl chloride monomer, potassium or sodium chromate or dichromate, and pitch, plus more
  • Working in a process related to the substances listed in Schedule 6 and there is a reasonable possibility that exposure could lead to an adverse health effect or disease
  • Exposed to a hazardous substance that has a direct link with a specific disease or adverse health effect, there is a possibility that this disease or effect will occur, and it is feasible for it to be detected

What is health surveillance?

Health surveillance includes either an examination by a nurse, doctor or by a trained supervisor in the workplace. A supervisor in the workplace could do skin checks to look for dermatitis, or ask questions about breathing difficulties if an employee is working with hazardous substances which can trigger asthma.

Comply with COSHH regulations - steps 5-6 of 8

The aims of health surveillance are to protect employees’ health through early detection of disease, collect data so you can evaluate health hazards, and so you can easily evaluate your control methods.

You are required to keep a health record of all health surveillance you do, and these records must be kept for a minimum of 40 years. 

Biological monitoring can also be part of health surveillance, and you may be required to set up a biological monitoring programme. A part of this is about protecting employees’ rights and the legalities in the role and use of biological monitoring.

Finally, you should also be aware of general health problems in your industry. If there is information in your industry’s trade press or from the Health & Safety Executive which indicates that there is a problem with a certain health effect such as respiratory or skin disease, you may need to provide special checks for your employees.

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