Hazardous Materials Not Regulated by COSHH
Understanding which hazardous substances fall outside COSHH regulations is a compliance challenge businesses face. While COSHH (Control of Substances Hazardous to Health) covers standard workplace hazardous materials like cleaning materials and solvents, other, potentially harmful substances are regulated under different legislation.
This guide explores these exceptions and their specific regulatory requirements.
What Is COSHH and Its Purpose?
COSHH regulations form the cornerstone of chemical safety management in UK workplaces. Implemented in 2002 [1] and regularly updated, these regulations protect workers from health risks associated with hazardous substances.
However, the Health and Safety Executive (HSE) confirms that some hazardous materials fall outside COSHH’s scope due to their unique risks and control requirements.
Which Materials Fall Outside COSHH Regulations?
The following hazardous materials have dedicated regulations separate from COSHH due to their specific risks and control requirements:
Asbestos
Regulated under the Control of Asbestos Regulations 2012, asbestos requires specialist handling and removal procedures. Asbestos still causes over 5,000 deaths annually [2] in the UK, highlighting the importance of its dedicated regulatory framework.
Lead
The Control of Lead at Work Regulations 2002 governs lead exposure in workplaces. This separate legislation addresses the risks associated with lead exposure, including specific medical surveillance requirements and exposure monitoring protocols.
Radioactive Substances
The Ionising Radiations Regulations 2017 cover radioactive materials, providing comprehensive controls for radiation protection. These regulations mandate specific risk assessments, designated radiation protection supervisors, and detailed exposure monitoring.
Why Are Certain Materials Excluded?
These materials require separate legislation due to the following:
- Unique Risk Profiles
- Complex exposure pathways.
- Long-term health effects.
- Specific control measures.
- Specialist handling requirements.
- Historical Context
The development of separate regulations reflects the historical understanding of these materials’ dangers and the evolution of workplace safety legislation.
Each set of regulations addresses specific challenges identified through years of industrial experience and scientific research.
What Regulations Cover Non-COSHH Materials?
Understanding the regulatory framework for non-COSHH materials assists with comprehensive compliance:
Control of Asbestos Regulations 2012
Requirements include:
- Mandatory asbestos surveys before work begins.
- Licensed contractor requirements.
- Specific waste disposal procedures.
- Detailed record-keeping obligations.
Control of Lead at Work Regulations 2002
Key elements involve:
- Regular blood-lead monitoring.
- Specific workplace exposure limits.
- Medical surveillance programmes.
- Designated control areas.
Ionising Radiations Regulations 2017
Essential components include:
- Radiation risk assessments.
- Appointed radiation protection advisers.
- Controlled and supervised areas.
- Emergency procedures.
How Do You Identify If COSHH Applies?
Determining which regulations apply requires careful assessment of material properties and workplace activities. The HSE provides detailed guidance, but professional hazardous waste disposal expertise is invaluable for complex cases.
Consider these factors:
- Material composition and properties.
- Intended use and exposure scenarios.
- Workplace activities involving the material.
- Potential risks to workers and the environment.
What Are the Practical Implications for Businesses?
Managing non-COSHH-regulated materials requires specific approaches and expertise. Solutions from HSE data reports that businesses handling these materials spend more on compliance than companies dealing only with COSHH-regulated substances.
Effective management requires:
- Specialist training programmes.
- Dedicated control measures.
- Regular monitoring systems.
- Comprehensive documentation.
- Professional waste management solutions.
How Can You Ensure Proper Management of All Hazardous Materials?
Successful hazardous material management requires an integrated approach that addresses COSHH and non-COSHH-regulated substances. The HSE recommends developing extensive hazardous substance management systems encompassing all applicable regulations.
Important components should include:
Material Inventory Management
- Regular updates and reviews.
- Clear identification of applicable regulations.
- Detailed risk assessments.
Control Measures
- Engineering controls.
- Administrative procedures.
- Personal protective equipment.
- Emergency response plans.
How Can Professional Services Support Your Compliance Needs?
We understand the complexities of managing materials regulated outside COSHH. Our specialist team at PRD Services provides professional support for businesses handling these substances.
Our expertise includes:
- Material-specific risk assessments.
- Compliant storage solutions.
- Safe transport arrangements.
- Professional disposal services.
- Complete documentation support.
Our experience handling hazardous materials and waste, including the ones not covered by COSHH, makes us ideal for working with. We also help with industrial package disposal within our fully compliant plant process and include services for other surplus products, such as secure destruction.
Contact our team today to discuss how we can help you manage your non-COSHH-regulated materials safely and effectively.
Sources:
