COSHH – CQC – All businesses must be aware of and take appropriate actions in relation to their responsibilities under COSHH. Recent feedback from clients is that healthcare institutions are increasingly being picked up on COSHH compliance during CQC inspections. COSHH assessments can be very time consuming and complicated, but below are some pointers to consider:-
- COSHH is context specific, the same product could be low risk in one context and very high risk in another. You are responsible for doing your COSHH assessment, you cannot expect the supplier of the product to do it for you, though you can ask them to provide relevant information on the products they supply in the form of a Material Safety Data Sheet where they are available.
- COSHH covers all products used within the organisation, not just stock items. They are likely to include cleaning materials but could also include things like stationary products.
- COSHH assessments should consider the normal use of a product but also reasonably foreseeable circumstances. So if you are a wholesaler of cleaning materials, the products on the shelves in their original packaging are probably low risk, even if they contain quite nasty ingredients, however you would also need to consider the situation if a bottle was broken during handling.
- COSHH generally considers the physical nature of the product, does it contain or is it a substance that could be hazardous to the health of your staff or customers? COSHH runs parallel with Health and Safety assessments and controls. For example, if you wholesale 5ltr bottles of cleaning fluid, there will be a COSHH assessment required to consider the risk of the ingredients causing a hazard but there will also be health and safety considerations relating to the size and weight of the product.
- Many products may appear to pose a potential harm but that does not mean that they are high risk under COSHH. An example would be a syringe needle, from a COSHH perspective these are very low risk as they are made out of inert stainless steel and plastic, however in use they could pose a risk of harm to the user and/or the patient. But this is not a COSHH risk and would need to be addressed by other means.
- You do not need to do a full COSHH assessment of every product, just those that could pose a hazard in your context.