Chapter 10 COSHH


I would like in this chapter to look at hazardous substances or as they are described in the Regulations 'the Control of Substances Hazardous to Health' - which everyone abbreviates to COSHH

I would firstly like you to consider two things:

Firstly: What are the ways a substance can be taken into the body?

There are basically 5 ways, which vary according to work environment, but for Groundsmen/ Greenkeepers they are - in order of likely exposure

  1. inhalation - breathing
  2. skin absorption
  3. splashes in eyes ( the eyes can absorb contaminatuion at 20x the rate of skin!!)
  4. cuts & injections
  5. ingestion - swallowing, eating or drinking

This has obvious implications on work practices and usually we protect ourselves from 1 to 5 by using standard hygiene, but additionally we must consider the use of Personal Protective Equipment for 1, 2 & 3.

Secondly: What is the difference between an acute problem and a chronic problem?

From the dictionary :

ACUTE : a. Having a rapid onset and following a short but severe course: acute disease.
Afflicted by a disease exhibiting a rapid onset followed by a short, severe course:

CHRONIC; having long had a habit or a disease

The effects of both can range from trivial to fatal. However, as you can imagine, it is very easy to see the cause and effect if they are close together - an acute problem - and these are the problems most people, employers & employees, address as far as Health & Safety are concerned.

The chronic problem on the other hand is difficult to see, the cause is so far removed in time from the effect, that most people are 'willing to take shortcuts' about them and perhaps are even unwilling to believe they exist. Witness the problem of trying to convince smokers of the dangers of smoking!!!!!

The COSHH Regulations seek to control both chronic and acute problems that but it is on the chronic problems that COSHH is shedding new light.

What is a substance?

A "SUBSTANCE" means any natural or artificial substance whether in solid or liquid form or in the form of a gas or vapour (Including micro-organisms).

However the regulations go on to explain it more clearly by saying



Let us look the first of these groups: Any substance listed with a Toxic Classification as above.

Look through any workplace and find all the substances which have these on them - you will find many!!! Each of these, in the right, or should it be wrong, circumstances could cause harm i.e. is a HAZARD

HAZARD is the potential to cause harm

It may be that the circumstances at your workplace, control that hazard so that the likelihood of accident or contamination is very low - i.e. low RISK

RISK is the likelihood if it happening in the circumstances of use

Now, many of you will be dismissive of listing every substance with a hazard classification as being trite and a waste of time and ' it couldn't happen at my workplace!'

Let me tell you of the problems which could occur from the use of Error Correction Fluid. If you look at the little bottle you may see an X : Harmful on the side. Everyone says, surely I don't have to make an assessment of risk on that???? Sadly you do - in 1994 a wee lassie in a school classroom stuck the open bottle up her nose to get a high and DIED. If the school had handed it out they would have been guilty under COSHH and liable to severe fines etc. The staff would also have gone to court!!!! In this case she had bought it herself.

In the First World War there was a gas used in the trenches called phosgene - this gas when breathed in quickly rotted the lungs of the soldiers in the trenches - some survivors were so severely affected they were hospitalised for the rest of their lives. What that got to do with Correction Fluid?? Well, if you light a cigarette and breath the fumes of Correction Fluid that has the X Hazard Classification, then as the fumes pass through the flame it turns into phosgene!!!!!! That's right, you breathe in phosgene!!!!!!

So please go now and write down all the substances in your workplace which carry the Toxic Classification as listed above, and that will allow us to begin a COSHH ASSESSMENT


An essential requirement is for EMPLOYERS ( including the self-employed) to make an assessment of health risks created by the work and of the measures that need to be taken, as a consequence, to protect people's health and meet the requirements of the rest of the COSHH Regulations

The duty applies to all sectors of manufacturing, agricultural and service activity.

COSHH requires that after 1 January 1990, no work which is liable to expose anyone to substances hazardous to health shall be carried on unless an assessment has been made.

The assessment should consider -

  2. CONTROL EXPOSURE to acceptable levels
  3. Only after PREVENTION and CONTROL have been properly considered should PERSONAL PROTECTIVE CLOTHING - PPE - be considered

The assessment must be reviewed and, if necessary, updated, if any of the circumstances of the work should change or if it becomes apparent that the original assessment is no longer valid.

Essentially COSHH covers all substances which have POTENTIAL for causing harm to peoples health.

Whether or not they do so in practice is dependent on the form that they are in, on the way they are used and on the precautions that are taken to protect anyone who may come into contact with them