In order to meet their legal obligations, under the Control of Substances Hazardous to Health Regulations 2002 (COSHH), companies have their LEV systems thoroughly examined to meet the requirement of COSHH regulation 9 and undergo Air or Personal Monitoring to meet the requirement of COSHH regulation 10.
These two activities are inextricably linked as both are crucial to ensure effective control of a substance is being achieved. If companies employ a specialist provider such as SML then the LEV thorough examination and the air monitoring will both be undertaken at the same time. This enables both sets of results to be scrutinised by the competent person to positively declare the substance is being effectively controlled.
However, many companies choose to have their LEV thorough examinations and air monitoring carried out by separate providers. Legally, this presents no issue as both activities are carried out by specialist within their individual field.
This, however, places the scrutiny of the individual reports more with the responsibility of the end client to compare the results of the two and determine if control of a substance is being achieved. It also has to be said, competent persons undertaking LEV thorough examinations should be requesting sight of the results of air monitoring in order to supplement their examinations. However, in practice this is not always the case, sometimes because they simply fail to ask, or, as Air Monitoring is usually managed by Health and Safety teams, and LEV thorough examinations by Engineering teams, they simply do not know where to find them.
In situations such as this, a more collaborative approach is needed by end users, to cross reference results. An LEV system may perform sufficiently to pass a thorough examination, but due to its design or how it is used, control of the substance may not be achieved. On the flip side, results of Air Monitoring may be at or just below the WEL, but an LEV system may be underperforming or defective so control could be improved. Remember the general requirement after prevention is always to adequately control exposure.
High levels of defects on LEV systems are a common occurrence. As a result, most systems do not perform to their optimum. Maintenance of LEV systems is an integral requirement of COSHH regulation 9, but maintenance under PUWER regulation 5 also applies. Therefore, it is imperative that a robust maintenance program is in place for LEV equipment sufficient to satisfy the legal requirements, but also to ensure exposure levels are kept to a minimum within the workforce.
Has Covid distracted your day-to-day Health & Safety?
Over the past 12+ months everyone’s focus has quite rightly been on the control of Covid; ensuring, where permittable, that business has been able to continue whilst suitable arrangements are implemented to manage the risks.
While the pandemic has certainly interrupted some scheduled and regular Health and Safety activities, such as training courses, it is important that businesses are not distracted from ‘normal’ day to day Health & Safety responsibilities. The competency of our workforces needs to be maintained to make sure that complacency is not allowed to develop.
This is where Toolbox Talks come in. Originating in the Construction sector, a Toolbox Talk is a short presentation to the workforce on a single aspect of Health and Safety. They only need to be 10 – 20 minutes long and delivered by a Supervisor or Manager to their team.
Examples of Toolbox Talks that we have supplied for our clients include:
Toolbox Talks are a flexible method of engaging with the workforce. Even during Covid restrictions, it is possible to effectively deliver these talks to small groups of workers in the right environment.
It is imperative that the content of the talks are:
- Relevant to work activities and the work environment
- Delivered verbally by the appropriate personnel
Poor examples of Toolbox Talks are when safety updates are printed out and left in a communal space for workers to sign that they have read them. This isn’t engaging or a responsible enough approach.
SML can support your business activities in providing Toolbox Talks to suit your undertakings. If required, we can also support your Management team in the delivery of these. Contact us today to find out more.