Assess before you start — COSHH Practice

Sample questions

1. 01A self-employed electrician with no staff is booked to chase walls on a construction site. Does the regulation 6 duty to assess apply to their own work?

   • AOnly if the main contractor asks for it in writing
   • BOnly if the job lasts for longer than one week
   • CNo, the duty only applies to firms that have staff
   • DYes, they are treated as both employer and employee

   Why: Construction work is a prescribed undertaking, so the electrician is a relevant self-employed person and COSHH treats them as both employer and employee, with only regulations 10 and 11 not applying. The duty to assess before the work therefore applies. It does not depend on having staff, on a contractor asking, or on how long the job lasts.

2. 02An electrician says there is no point reading the SDS for a new sealant, because the firm writes its own COSHH assessment anyway. What does regulation 6(2) say?

   • AThe SDS only matters if the product has a WEL
   • BThe SDS is only for the supplier’s own workers
   • CThe assessment must consider the supplier’s SDS
   • DThe SDS replaces the need for the firm’s assessment

   Why: Regulation 6(2)(b) lists information on health effects provided by the supplier, including information in any relevant safety data sheet. So the firm’s own assessment must take the SDS into account; the SDS is an input to the assessment, not a replacement for it. That applies whether or not the product has a WEL.

3. 03An assessment covers chasing with on-tool extraction, but says nothing about emptying the extractor and changing its filter at the end of each day. Why is that a gap?

   • AOnly the manufacturer may empty the extractor
   • BIt is not a gap, as emptying is outside COSHH
   • CIt is not a gap, as the filter traps all of the dust
   • DMaintenance like this can give high exposure

   Why: Regulation 6(2)(e) says the assessment must consider activities such as maintenance where there is the potential for a high level of exposure, and the ACOP says exposure during maintenance may be foreseeably higher than normal. Emptying a full dust extractor puts collected dust back within reach of the operative. It is squarely within COSHH.