LETTERS TO THE EDITOR |
Evaluation of COSHH Essentials for Vapour Degreasing and Bag-Filling Operations
Internationally, there has been much interest and take-up of COSHH Essentials as a risk management tool, and we welcome its continued evaluation by different stakeholders. We continue to seek further information on whether users select the correct control approach, whether they correctly implement the approach and whether use of COSHH Essentials reduces ill-health. It would seem that none of the workplaces surveyed by Jones and Nicas (2006) had used COSHH Essentials in selecting control measures and that the authors are unable to access the information about the range or quality of the control measures in place that would allow an evaluation. Contrary to its title, the paper focuses on whether the control measures in place are effective. It is not clear from the paper whether these controls are the same as those described in COSHH Essentials.COSHH Essentials is not intended as a predictor of exposure; it is a package of measures that identifies an approach that will provide adequate control. These measures include hardware, such as ventilation or containment, and software, such as systems of work and the training and supervision of the workers. An evaluation of COSHH Essentials needs to assess the effectiveness of the package as a whole. Unfortunately, this contextual information is not available for this study. In their conclusions, the authors set out a series of questions that should be answered for a suitable evaluation. Such a study would be extremely valuable and we look forward to their future work in this area.
While this paper does not deliver on its title, it supports the findings of HSE's research that few businesses carry out a formal risk assessment before selecting controls (Chambers et al., 2002). This research indicates that businesses usually follow the ‘control culture’ of their industry and take the lead from their suppliers or their competitors. Businesses tend not to carry out exposure monitoring (Topping et al., 1998). These are the principal drivers for practical tools such as COSHH Essentials that provide control solutions using readily available information.
Health and Safety Executive 4N.3 Redgrave Court, Bootle L20 7HS, UK
*E-mail: paul.evans{at}hse.gsi.gov.uk
Received May 11, 2006;
REFERENCES
1 Chambers H, Weyman A, Keen C. (2002) Identification of reasons for failure of control. strategies. HSL Report FSSU/02/02 (Health and Safety Laboratory, Buxton).
2 Jones RM and Nicas M. (2006) Evaluation COSHH Essentials for vapour degreasing and bag filling operations. Ann Occup Hyg 50:137–47.
3 Topping MD, Williams CR, Devine JM. (1998) Industry's perception and use of occupational exposure limits. Ann Occup Hyg 42:357–66.
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