Can I do my own air sampling and assessments for the COSHH regulations?

In essence, there is nothing in the Control of Substances Hazardous to Health (COSHH) Regulations 2005 to say that you cannot carry out risk assessments and air sampling yourself (Local Exhaust Ventilation – LEV – being a notable exception), provided you are competent to do so, although the chances of missing something if you do not have the necessary skills and depth of knowledge, is quite high!

Competent Person or Service

The Approved Codes of Practice (ACOP) under Regulation 6 in the HSE guidance booklet, L5 say that if you do want to use outside assistance, you should ensure that they are competent to carry out the work and that one way to ensure this is the use the directory held by the British Institute of Occupational Hygiene (BIOH), which in 2003 merged with the British Occupational Hygiene Society (BOHS). There are usually around 40 companies listed here.

To qualify as an occupational hygienist and be eligible for the directory, you must complete various modules from the directory of BOHS courses, as well as several years of practice in the field. The higher the level you want to get to, the more modules and the more practical experience.

It is for good reason that there is such a stringent requirement, as lives may depend on the correct identification and assessment of hazardous substances in the workplace, and this can often involve a deep understanding of complex chemistry and biology, along with the ability to understand industrial processes and the impact they may have on the working environment.

Local Exhaust Ventilation (LEV) Testing

Regulation 9 of The Control of Substances Hazardous to Health (COSHH) Regulations 2005 covers the use, maintenance and testing of local Exhaust Ventilation (LEV) systems and unlike risk assessments and monitoring, the person conducting this work must be accredited by the United Kingdom Accreditation Service (UKAS). Some BOHS Occupational Hygienists can carry out this work, alternatively, the Building Engineering Services Association (BESA) has a directory of LEV engineers.

The Annual Survey!

Most larger companies with industrial processes engage the services of an occupational hygiene consultancy firm, who will conduct annual surveys and assessments, perhaps including LEV testing. The question many companies ask, however, is what can be done between visits. How do you fully implement the recommendations from such a report and what do you do in the meantime if you need to check that nothing has changed, carry out some supplementary sampling or keep your risk assessments up to date? It may be that during the annual visit, there were processes not running or tasks not performed, so how do you catch up with these?

The Solution

The solution is to gain enough skills, knowledge, and practice in-house to be able to work more effectively with your occupational hygiene provider, supplement the sampling between visits and keep your risk assessments up to date should anything significant change within your organisation. The next full survey should then pick up on anything missed and provide another baseline for the next year’s work. Being more informed will also mean you get more out of the testing and reports provided by the consultants.

The Castle Training Academy has 2 courses covering COSHH risk assessments and air sampling, which are designed specifically to provide enough knowledge and practical insight to be able to support the work of your external OH provider and ensure that you remain complaint with the Regulations all of the time.

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