Annals of Occupational Hygiene Advance Access originally published online on July 14, 2006
Annals of Occupational Hygiene 2006 50(6):642-644; doi:10.1093/annhyg/mel044
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LETTERS TO THE EDITOR |
Evaluation of the Utility and Reliability of COSHH Essentials
COSHH (Control of Substances Hazardous to Health) Essentials was developed with the intention of providing practical, reliable advice to users of chemicals, especially those without access to developed occupational hygiene skills. At the forefront of the development was the recognition that traditional forms of exposure control advice are neither accessible to nor understood by many small to medium-sized businesses (Russell et al, 1998; Hudspith and Hay, 1998; Walters and Grodzki, 2006). What was needed was a tool that did not demand detailed technical knowledge yet provided practical solutions to the challenge of successfully managing workplace chemical risks. Furthermore, it was recognized that for such an approach to succeed, it would need to operate in a screening mode; that is, it would have to be both inherently conservative and identify situations where access to more specialized approaches were advisable. These elements have already been described elsewhere (Maidment, 1998; HSE, 1999). The technical basis followed in COSHH Essentials was developed by a working group set up by the UK Health and Safety Executive and involved social partners from industry and the trade unions. Robustly derived occupational exposure limits set in the UK were used to validate the approach.The papers by Jones and Nicas (2006a,b) have sought to critically review aspects of COSHH Essentials. Specifically, they highlight the fact that aspects of the COSHH Essentials advice is more robust for some activities than for others; that the approach is inherently conservative for many activities (when compared with empirical occupational hygiene approaches); and that some activities are not readily amenable to the application of COSHH Essentials advice. These findings are not new and have been highlighted previously (Tischer et al, 2003; Money et al, 2003; ECETOC, 2004). Indeed, the process of development explicitly sought to identify and account for such artefacts. However, as Jones and Nicas point out, the most important consideration is the extent to which the correct risk control advice can be accessed, chosen and implemented by users in practice. In this respect it must be recognized that significant user evaluation trials have identified COSHH Essentials type approaches as having a far greater likelihood of meeting such an objective compared with those that provide information in a context in which it cannot be readily accessed or understood (Briggs and Crumbie, 2000; Wiseman and Gilbert, 2002; O'Hara et al., 2003). It would be wrong, therefore, to judge the integrity of COSHH Essentials by viewing elements in isolation. COSHH Essentials is an integrated approach that provides ready access (particularly by users of chemicals in smaller enterprises) to valid occupational hygiene advice on appropriate control measures (that cover both hardware and software systems) and, hence, complements other, more traditional, occupational hygiene strategies by identifying where access to professional skills is particularly pertinent.
The authors are non-HSE members of the COSHH Essentials WG of the Health and Safety Commission's Advisory Committee on Toxic Substances.
1 ExxonMobil Petroleum and Chemical Machelen, Belgium
2 GlaxoSmithKline Worthing, UK
3 Bayer CropScience Norwich, UK
4 University of Leeds Leeds, UK
5 Amicus London, UK
6 London Borough of Tower Hamlets London, UK
7 Innovene Sunbury, UK
8 Sypol Aylesbury, UK
*E-mail: chris.money{at}exxonmobil.com
Received May 23, 2006;
REFERENCES
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ECETOC. (2004) Targeted risk assessment. Technical Report No. 93 (ECETOC, Brussels).
Health and Safety Executive. (1999) COSHH Essentials. (HSE, London, UK).
Jones RM and Nicas M. (2006a) Evaluation of COSHH essentials for vapour degreasing and bag filling operations. Ann Occup Hyg 50:13747.
Jones RM and Nicas M. (2006b) Margins of safety provided by COSHH Essentials and the IKLO chemical control toolkit. Ann Occup Hyg 50:14956.
Hudspith B and Hay AWM. (1998) Information needs of workers. Ann Occup Hyg 42:4016.
Maidment SC. (1998) Occupational hygiene considerations in the development of a structured approach to select chemical control strategies. Ann Occup Hyg 42:391400.
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