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Spring 2022 31 2. SUBSTITUTION Another way to prevent exposure to a hazardous substance is to substitute it for a less hazardous alternative. An example of this could be changing from oil-based to water- based paints. Or changing from a chemical-based cleaning product to a more natural alternative. You might also substitute or even change a product to a safer form. For example, use a paste rather than a spray. Another example would be to damp down a dust during drilling so that it doesn’t become airborne. With thousands of products available, a review of various suppliers can often result in finding lower hazard alternatives. 3. CHANGE PROCESSES Can the process be changed to reduce exposure to hazardous substances? Reviewing the way you work might highlight COSHH problems. For example, it might be standard practice for operatives to sweep up after they have finished working, and this could cause dust to become airborne again. Changing the process to damp down before sweeping or cleaning up, or to use damp rags to clean up, will help to prevent the particles becoming airborne again. 4. ENGINEERING CONTROLS Engineering controls are the next option. This would involve the design of systems and work equipment to control exposure, ideally at the source, to prevent or greatly reduce people’s exposure to a safe level. You can use engineering controls to enclose the process and prevent the hazardous substance from escaping outside the enclosure. You can also use engineering controls to extract emissions at or near the source. These controls might include: • Segregation of people • Local exhaust ventilation • Dilution • General ventilation 5. SUPERVISORY CONTROLS As the employer, you must make sure that the COSHH control measures keep working properly. You can also put in place certain rules to keep exposure minimised to a safe level. These supervisory controls could include: • Reduced time exposure • Reduced number exposed • Prohibitions and rules For example, you might say that only particular people are allowed within a COSHH enclosure, and they must have certain training and be wearing and using specific equipment. Supervisory controls usually have to be enforced, because unlike engineering controls, they rely on being followed and obeyed. 6. PPE When you think about control measures, personal protective equipment (PPE) is often one of the first things that might come to mind. But actually, it is one of the last items on this because, while an important control, PPE is a last resort control measure. It can only control the risk to one person at a time, and PPE does not reduce the hazard, so a failure of the equipment will expose the wearer to the maximum health risk. It is always best to combat the hazard at the source first to reduce the risk. None the less, PPE is still an important control measure. To be effective it should fit the user and be comfortable and suitable for the risks they are likely to be exposed to. 7. COMBINED CONTROLS A combination of control measures may be used for maximum risk reduction. You might use control equipment in addition to PPE. You might substitute a hazardous substance for a lower risk substance, but there still needs be other controls in place, like dust suppression, enclosures, and PPE. Often the best way to implement COSHH control and get the risk adequately controlled is through combining control measures. When you are using a mixture of control measures, it is important that they all work together. Remember to look at the process as a whole and consider how each control impacts another. For example, if you substitute a powder for a paste to lower the risk of inhalation, then you may also need to change the user’s PPE, to give more protection to skin contact, rather than respiratory protection. << For more advice speak to your Health & Safety Advisor or contact HAE EHA’s BusinessGuard by emailing businessguard@hae.org.uk or call 44 (0)121 380 4612 . “Every employer shall ensure that the exposure of his employees to substances hazardous to health is either prevented or, where this is not reasonably practicable, adequately controlled”