Title: Critical Response: A balanced approach to reading Type: Assignment – Written AssignmentCriteria & Marking: • Knowledge and understanding of a balanced approach to the teaching of reading • Knowledge and understanding of how language is acquired and developed in the early years • Understanding that the Australian Curriculum: English integrates knowledge and understanding of the strands of language, literature and literacy • Reflection and critique of the implications for the teaching and learning of reading in relation to the selection of content, teaching and learning strategies, and diverse needs of students, supported by reference to academic literature • Demonstration of personal literacy competencies suitable to the nature of the task
Referencing The reference list should follow the APA 7 style. Use the Griffith Referencing Tool for ‘in-text’ and reference lists. https://www.griffith.edu.au/library/study/referencing/apa-7. Your written response for this assignment needs to be referenced to the set readings from this course, and on at least one occasion across the 4 readings, reference the Australian Literacy Educators’ Association (ALEA) Literacy Declaration. https://www.alea.edu.au/about/alea-literacydeclaration/#:~:text=In%20August%202015%20ALEA%20released%20Literacy%20in%2021st,of%20embedding%20th e%20document%20into%20ALEA%27s%20ongoing%20work. Click on this blue link to access the declaration; it is not available on the reading list.
You are to write a series of critical responses on the importance of a balanced approach to the teaching of reading in the early years and its practical application in classrooms. You should also reflect on important considerations for how you would organise the content, plan, structure and sequence a learning program and apply teaching strategies noting that you do not need to prepare and present a plan, but rather discuss possible considerations. Your responses should also consider the extent to which the balanced approach allows for differentiating teaching to meet the specific learning needs of students across the full range of abilities. This response will be broken down into four (4) weekly written journal tasks. The response will reflect on the weekly content addressed in lectures and readings, as well as make links to activities in the tutorials. WeekCritical response 1: Written response (375 words) What is a balanced approach to the teaching of reading in the early years of school? How is a balanced approach reflected in the Australian Curriculum? (Hint: refer to content descriptions) What is the place of oral language and vocabulary in a balanced approach to reading? Reflect on an important consideration for content, planning and catering to the diverse needs by relating to one practical activity undertaken during the week 1 tutorial. 2: Written response (375 words) What is the place of phonological awareness in a balanced approach to reading? Define what is meant by the term phonological awareness. Reflect on an important consideration for content, planning, and catering to the diverse needs by relating to one practical activity engaged in during the week 2 tutorial. What is the place of phonemic awareness in a balanced approach to reading? Define what is meant by the term phonemic awareness. Reflect on an important consideration for content, planning, and catering to the diverse needs by relating to one practical activity engaged in during the week 2 tutorial. 3: Written response (375 words) What is the place of alphabetic knowledge in a balanced approach to reading? Define what is meant by the term alphabet knowledge. Reflect on an important consideration for content, planning, and catering to the diverse needs by relating to one practical activity engaged in during the week 3 tutorial. What is the place of phonics in a balanced approach to reading? Define what is meant by the term phonics. Reflect on an important consideration for content, planning, and catering to the diverse needs by relating to one practical activity engaged in during the week 3 tutorial. 4: Written response (375 words) What is the place of reading fluency in a balanced approach to reading? Define what is meant by the term reading fluency. Reflect on an important consideration for content, planning, and catering to the diverse needs by relating to one practical activity engaged in during the week 4 tutorial. What is the place of comprehension in a balanced approach to reading? Define what is meant by the term comprehension. Reflect on an important consideration
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Substances Hazardous To Health Student’s Name
Institutional Affiliation Date
Introduction
The control of substances hazardous to health (COSHH) provides important clarifications involving identification of substances hazardous to health, activities involving hazardous substances, how they may cause harm and how to mitigate as well as reduce the risk of harm occurring. The COSHH (2002) regulations apply to hazardous health substances that are found in the workplace and place the mandate on employers to ensure the safety of employees and other people from hazardous substances that they interact with at work (Palmer & Freegard, 2006).
Employees must achieve this by conducting a risk assessment, exposure control, and conducting health surveillance at the respective work environments. Hazardous substances in the workplace may take various forms including chemicals, dust, vapors, gases, fumes, nanotechnology or chemical-containing products.
This report provides an analysis of a case involving exposure precautions and preventions to protect employees and others from hazardous substances, as per the COSHH 2002 regulations. In this highlighted case study, employees working as cleaners in an office block protested to their supervisor against a newly introduced cleaning detergent that irritated their throats. Other staff members who worked till late while the cleaning took place also expressed their discomfort, prompting the facilities manager to seek an alternative detergent from their supplier. After reading the new detergent’s safety data sheet, the safety representative realized that the new cleaner was harsher than required, could also clean ovens and was potentially a carcinogen. The ultimate solution was to go back to using the original safer detergent but change its form of usage. It was no longer being sprayed on the cupboards surfaced, releasing some of it to the free air to be inhaled (Garrod, Evans & Davy, 2007). Instead, it was used by being directly sprayed into the cleaning cloth and on the cupboards in this manner.
COSHH Regulation Analysis
Upon identification of significant risks, as highlighted in this case study, the employer must undertake some measures to adhere to the regulation of the COSHH. The regulations COSHH regulations identified in this case generally involve preventing and controlling exposure to hazardous substances. According to COSHH regulation 7, employers should be focused on risk identification by considering prevention measures for exposure if logically practicable minimizing or controlling exposure, as well as considering whether the current control measures are effective in meeting the current COSHH guidelines on best practices (Palmer & Freegard, 2006).
Prevention of exposure to hazardous substances has to be based on reasonable practicability. Elimination of hazardous substance entails not using it, changing the unwanted process within the substance, or not producing the by/waste product. The exposure-causing method can be avoided by changing the process. Substitution may also be used in cases where elimination is not possible. This entails the use of a less harmful alternative such as substituting the irritant detergent with a milder one or brushing using a vacuum cleaner. The before substituting a substance with another, employers should importantly note that all the identified potential risks associated with that other substance are considered, including the risks covered under COSHH, among other regulations (Palmer & Freegard, 2006).
Another measure that can be used where elimination is not possible is the use of the product in the safest form possible; for instance using pellets as opposed to powder, to reduce dust exposure. Any workplace exposure limits (WELs) should not be exceeded for mutagens, sensitizers, and carcinogens. The exposure to these substances has to be reduced to lowly
reasonable and applicable levels. The second COSHH regulation about this case study entails exposure control. When it is not logically practicable to prevent exposure employers may look to control it. Control measures of exposure to hazardous substances have to be sustainable, workable and practicable. Control measures have to be given priority, aligned with the appropriate hierarchy and according to the risk level assessment.
Employers need to ensure designing, provision, and usage of the appropriate systems, processes, materials, equipment and engineering controls during work. There should also be adequate exposure control at various sources such as organizational measures and effective ventilation systems. In addition to these two measures, personal protective equipment has to be ensured. To achieve these standards, employers need to ensure safe storage, transport, and handling of substances, appropriate maintenance procedures, minimum possible substance use, and minimum possible number of workers exposed at the shortest possible duration. Proper hygiene measures such as adequate cleaning facilities also need to be in place.
Legal Provisions
COSHH (2000) contains some legal provisions that have to be applied and adhered, for reliable and effective control of exposure to hazardous substances in references to this case study. The first provision entails designing and operating activities and processes that minimize the disposal emission and spread of hazardous substances, to a reasonable, practical level. This is considered a much cheaper option than a reactive measure. Secondly, all relevant exposure routes such as the skin, breathing, and swallowing should be considered when developing the control measures (Cooke et al., 2011). The chemical, infectious and physical aspects of hazardous substances as these decide how the exposure occurs. Employers must consider the exposure
amount, possible effects on health and how the substance is used. The appropriate measures also need to be used in health risks control. These include important considerations such as the seriousness of the potential effect, the chances of its occurrence, and the stricter the required measures.
The COSHH also provides for decision making between the most reliable and effective control measures for minimizing the spread and escape of harmful substances (Cooke et al., 2011). Some options are more effective and reliable than others. For instance, changing the process to produce a less hazardous substance is more reliable while personal protective equipment relies on proper use and a perfect fit. A hierarchy should be developed; by effectiveness and reliability, hence preference is for the once that are higher in the list. This list includes the elimination of hazardous substances, modification of substance, workplace or process, application of controls to the process, working ways that minimize exposure, and PPE (Personal Protective Equipment) (Cooke et al., 2011).
While other measures of control cannot effectively control exposure, suitable PPE has to be combined with other measures of control. Adequate control is normally achieved through a combination of various measures. Protective personnel equipment has to be the last additional measures to supplement the others. The regular review s and check-ups are requirements in ensuring effective control measures. These include confirming whether the relevant equipment is working, used or maintained properly, all employees are supervised, instructed or trained appropriately, all identified measures of control are used and working appropriately, and whether all the records and checks are appropriately kept. The frequency of the checks and reviews need to be made dependent on the consistency of control and the consequences once they fail.
As another legal provision, employers need to train and inform all their employees on the risks, and hazards within their job environments as well as the respective control measures. For appropriate control of hazardous substances and risks, employees need to be aware of how to and the need of working in particular ways and using specific measures. This is especially so in situations where severe health effects may not occur until after exposure for a couple of years.
There may lack early or immediate warning signs of severe effects such as chemicals exposure which may lead to cancer many years after exposure, despite lack of early warning signs or symptoms.
COSHH requires employers to ensure that no single control measure increases safety or health risks (Palmer & Freegard, 2006). New risks can emerge from the change of processes, control measures as well as PPE. Control measures should, therefore, be analyzed and assessed any potential risks. The control measures should be only administered on the basis that they will control or prevent a more severe and significant risk. All employers should ensure the reasonable maximum protection of all employees from hazardous substances within the job environment.
All hazardous substances need to be adequately controlled at a reasonably practicable level. For employers to comply with their duty of prevention from hazardous substances, substitution should be preferred in the case where the employers avoid as long as it is reasonably practicable. Using of hazardous health substances in the workplace should be reduced by substituting or replacing it with another substance or a process that will reduce or eliminate the health risks to employees, under the manner of its use (Palmer & Freegard, 2006). In cases whereby it is not reasonably practicable to prevent the exposure to hazardous substances, employers may apply the appropriate protection measures about the respective risks identified.
These include measures that will regulate employees’ behavior such as eating habits and movements, or other factors within the work environment such as storage, ventilation or production procedures that are linked to hazardous substances thus increasing health risks.
Recommendations
Based on this case study, the first recommendation would be on more COSHH requirements for biological agents, mutagens, and carcinogens regarding prevention from exposure. These hazardous substances and risks lack early warning signs and may, therefore, take long before their health effects can be felt. It is, therefore, recommendable to conduct a risk assessment to determine whether mutagens and carcinogens are present and if they are; their nature and levels of risk (Simpson & Simpson, 1991). This ensures that precautions and control measures are adequately undertaken. If possible, a safer alternative within the work process should be identified to eliminate or reduce the use or production of mutagens and carcinogens. COSHH applies to mutagens and carcinogens as it is the case for other harmful substances, apart from the situation where it is not possible to prevent exposure on the reasonably practicable basis. In the case whereby employers have to apply the control measures in a priority and best practices order, they should also incorporate other practices to supplement prevention from exposure. These include total enclosure of the procedure and handling of systems, prohibition of eating, drinking or smoking, regular cleaning, designation of areas that may be contaminated, and use of warning signs to signal employees, as well as proper storage, handling and disposal of hazardous substances (Woodward & Atkinson, 1992).
The second recommendation is to ensure minimum exposure limits in the workplace and control exposure through inhalation. The incidence in this case study involves exposure through
inhalation whereby the office cleaner detergent irritated employees. The exposure by breathing hazardous substances in the workplace has to, therefore, be below a certain limit. The employee, in this case, needs to reduce exposure even further to reduce further attacks emanating from the irritation. Employers should ensure that they use substances that have WEL (Work Exposure Limit), which gives further safety guidelines on the handling and use of these substances. For substances that contain a WEL, employees need to be trained on how to incorporate principles of best practice to manage exposure to a specific level whereby almost all employees will be exposed on a regular basis with zero or minimize risks. Employers should, therefore, prioritize on using substances that have a WEL because it becomes easier to control exposure when using them (Hill, 1992).
The third recommendation is on PPE (Personal Protective Equipment) which is an alternative for achieving adequate control where it is not possible to achieve it using appropriate production, operational measures and best practices only. Personal protective equipment should be provided at zero cost to workers and should be used alongside the other control measures. The employer in this case study needs to ensure that all employees have the appropriate PPE which is stored, maintained and checked at regular intervals and repaired when in poor condition. The workers should put on protective clothing and have the right working equipment that ensures minimum exposure and maximum protection from the hazardous office cleaner. The workers need to be properly trained and supervised and consulted during the selection of PPE to ensure that the best is selected.
The fourth recommendation involves changing the process through which the hazardous substance is used (Woodward & Atkinson, 1992). This, however, depends on the identified risks and their potential effects on people. Substances whose effects occur via inhalation should not be
in their gaseous form which increases their hazardous ability. Instead, other forms of using the substance should be considered, such as usage in its liquid form. In this case study, it is recommended for the hazardous detergent to be used in a more friendly less hazardous form. In a similar situation whereby the highest risk occurs through ingestion, protective personal equipment and clothing should be used in designated places specific for this task only (Simpson & Simpson, 1991).
The fifth recommendation entails monitoring and evaluating the control measures. The management and safety department should ensure that the measures of control are installed and working effectively. Apart from monitoring the progress of the exposure reduction measures, the management should also ensure that the physical controls such as protective equipment are in good condition. Other control measures such as work systems, supervisions and procedures should be reviewed and monitored frequently to ensure that they are working.
Conclusion
COSHH generally requires all employees to conduct an adequate risk assessment and ensure that the work environment is comfortable and safe for all employees. Employers can achieve this through a series of activities including identification of the hazards, determining the risk level of each hazard, identifying the workers at higher risks level and the most vulnerable workgroups. They should also identify the appropriate preventive and control measures for the identified risks. Employers should conduct a risk assessment by real-life situations. However, due to a lot of dynamism in the job environment, the process of risk assessment should be done regularly, depending on the hazard and the possibility of causing harm to an employee.
Employers can as well conform to the COSHH requirements through effective planning for incidents, accidents, and emergencies that may occur in the workplace.
References
Cooke, R. A., Gavaghan, S., Hodgson, E. B., & Moore, S. (2011). General practitioners’ awareness of COSHH regulations. BMJ: British Medical Journal, 303(6810), 1132.
Garrod, A. N. I., Evans, P. G., & Davy, C. W. (2007). Risk management measures for chemicals: the “COSHH essentials” approach. Journal of Exposure Science and Environmental Epidemiology, 17(S1), S48.
Hill, E. C. (1992). COSHH regulations and microbial hazards associated with metal-working fluids. Tribology international, 25(2), 141-143.
Hyatt, N. (2003). Guidelines for process hazards analysis (PHA, HAZOP), hazards identification, and risk analysis. CRC press.
Palmer, K. T., & Freegard, J. (2006). Compliance with the Control of Substances Hazardous to Health Regulations (COSHH) 2008 and health and safety awareness in hairdressing establishments. Occupational medicine, 46(1), 49-52.
Simpson, D., & Simpson, W. G. (Eds.). (1991). The COSHH Regulations: a practical guide.
Royal Society of Chemistry.
Woodward, K. N., & Atkinson, K. (1992). The Control of Substances Hazardous to Health (COSHH) Regulations and their application to veterinary medicines. British Institute of Regulatory Affairs Journal, 10, 22-24.
Substances Hazardous To Health Student’s Name
Institutional Affiliation Date
Introduction
The control of substances hazardous to health (COSHH) provides important clarifications involving identification of substances hazardous to health, activities involving hazardous substances, how they may cause harm and how to mitigate as well as reduce the risk of harm occurring. The COSHH (2002) regulations apply to hazardous health substances that are found in the workplace and place the mandate on employers to ensure the safety of employees and other people from hazardous substances that they interact with at work (Palmer & Freegard, 2006).
Employees must achieve this by conducting a risk assessment, exposure control, and conducting health surveillance at the respective work environments. Hazardous substances in the workplace may take various forms including chemicals, dust, vapors, gases, fumes, nanotechnology or chemical-containing products.
This report provides an analysis of a case involving exposure precautions and preventions to protect employees and others from hazardous substances, as per the COSHH 2002 regulations. In this highlighted case study, employees working as cleaners in an office block protested to their supervisor against a newly introduced cleaning detergent that irritated their throats. Other staff members who worked till late while the cleaning took place also expressed their discomfort, prompting the facilities manager to seek an alternative detergent from their supplier. After reading the new detergent’s safety data sheet, the safety representative realized that the new cleaner was harsher than required, could also clean ovens and was potentially a carcinogen. The ultimate solution was to go back to using the original safer detergent but change its form of usage. It was no longer being sprayed on the cupboards surfaced, releasing some of it to the free air to be inhaled (Garrod, Evans & Davy, 2007). Instead, it was used by being directly sprayed into the cleaning cloth and on the cupboards in this manner.
COSHH Regulation Analysis
Upon identification of significant risks, as highlighted in this case study, the employer must undertake some measures to adhere to the regulation of the COSHH. The regulations COSHH regulations identified in this case generally involve preventing and controlling exposure to hazardous substances. According to COSHH regulation 7, employers should be focused on risk identification by considering prevention measures for exposure if logically practicable minimizing or controlling exposure, as well as considering whether the current control measures are effective in meeting the current COSHH guidelines on best practices (Palmer & Freegard, 2006).
Prevention of exposure to hazardous substances has to be based on reasonable practicability. Elimination of hazardous substance entails not using it, changing the unwanted process within the substance, or not producing the by/waste product. The exposure-causing method can be avoided by changing the process. Substitution may also be used in cases where elimination is not possible. This entails the use of a less harmful alternative such as substituting the irritant detergent with a milder one or brushing using a vacuum cleaner. The before substituting a substance with another, employers should importantly note that all the identified potential risks associated with that other substance are considered, including the risks covered under COSHH, among other regulations (Palmer & Freegard, 2006).
Another measure that can be used where elimination is not possible is the use of the product in the safest form possible; for instance using pellets as opposed to powder, to reduce dust exposure. Any workplace exposure limits (WELs) should not be exceeded for mutagens, sensitizers, and carcinogens. The exposure to these substances has to be reduced to lowly
reasonable and applicable levels. The second COSHH regulation about this case study entails exposure control. When it is not logically practicable to prevent exposure employers may look to control it. Control measures of exposure to hazardous substances have to be sustainable, workable and practicable. Control measures have to be given priority, aligned with the appropriate hierarchy and according to the risk level assessment.
Employers need to ensure designing, provision, and usage of the appropriate systems, processes, materials, equipment and engineering controls during work. There should also be adequate exposure control at various sources such as organizational measures and effective ventilation systems. In addition to these two measures, personal protective equipment has to be ensured. To achieve these standards, employers need to ensure safe storage, transport, and handling of substances, appropriate maintenance procedures, minimum possible substance use, and minimum possible number of workers exposed at the shortest possible duration. Proper hygiene measures such as adequate cleaning facilities also need to be in place.
Legal Provisions
COSHH (2000) contains some legal provisions that have to be applied and adhered, for reliable and effective control of exposure to hazardous substances in references to this case study. The first provision entails designing and operating activities and processes that minimize the disposal emission and spread of hazardous substances, to a reasonable, practical level. This is considered a much cheaper option than a reactive measure. Secondly, all relevant exposure routes such as the skin, breathing, and swallowing should be considered when developing the control measures (Cooke et al., 2011). The chemical, infectious and physical aspects of hazardous substances as these decide how the exposure occurs. Employers must consider the exposure
amount, possible effects on health and how the substance is used. The appropriate measures also need to be used in health risks control. These include important considerations such as the seriousness of the potential effect, the chances of its occurrence, and the stricter the required measures.
The COSHH also provides for decision making between the most reliable and effective control measures for minimizing the spread and escape of harmful substances (Cooke et al., 2011). Some options are more effective and reliable than others. For instance, changing the process to produce a less hazardous substance is more reliable while personal protective equipment relies on proper use and a perfect fit. A hierarchy should be developed; by effectiveness and reliability, hence preference is for the once that are higher in the list. This list includes the elimination of hazardous substances, modification of substance, workplace or process, application of controls to the process, working ways that minimize exposure, and PPE (Personal Protective Equipment) (Cooke et al., 2011).
While other measures of control cannot effectively control exposure, suitable PPE has to be combined with other measures of control. Adequate control is normally achieved through a combination of various measures. Protective personnel equipment has to be the last additional measures to supplement the others. The regular review s and check-ups are requirements in ensuring effective control measures. These include confirming whether the relevant equipment is working, used or maintained properly, all employees are supervised, instructed or trained appropriately, all identified measures of control are used and working appropriately, and whether all the records and checks are appropriately kept. The frequency of the checks and reviews need to be made dependent on the consistency of control and the consequences once they fail.
As another legal provision, employers need to train and inform all their employees on the risks, and hazards within their job environments as well as the respective control measures. For appropriate control of hazardous substances and risks, employees need to be aware of how to and the need of working in particular ways and using specific measures. This is especially so in situations where severe health effects may not occur until after exposure for a couple of years.
There may lack early or immediate warning signs of severe effects such as chemicals exposure which may lead to cancer many years after exposure, despite lack of early warning signs or symptoms.
COSHH requires employers to ensure that no single control measure increases safety or health risks (Palmer & Freegard, 2006). New risks can emerge from the change of processes, control measures as well as PPE. Control measures should, therefore, be analyzed and assessed any potential risks. The control measures should be only administered on the basis that they will control or prevent a more severe and significant risk. All employers should ensure the reasonable maximum protection of all employees from hazardous substances within the job environment.
All hazardous substances need to be adequately controlled at a reasonably practicable level. For employers to comply with their duty of prevention from hazardous substances, substitution should be preferred in the case where the employers avoid as long as it is reasonably practicable. Using of hazardous health substances in the workplace should be reduced by substituting or replacing it with another substance or a process that will reduce or eliminate the health risks to employees, under the manner of its use (Palmer & Freegard, 2006). In cases whereby it is not reasonably practicable to prevent the exposure to hazardous substances, employers may apply the appropriate protection measures about the respective risks identified.
These include measures that will regulate employees’ behavior such as eating habits and movements, or other factors within the work environment such as storage, ventilation or production procedures that are linked to hazardous substances thus increasing health risks.
Recommendations
Based on this case study, the first recommendation would be on more COSHH requirements for biological agents, mutagens, and carcinogens regarding prevention from exposure. These hazardous substances and risks lack early warning signs and may, therefore, take long before their health effects can be felt. It is, therefore, recommendable to conduct a risk assessment to determine whether mutagens and carcinogens are present and if they are; their nature and levels of risk (Simpson & Simpson, 1991). This ensures that precautions and control measures are adequately undertaken. If possible, a safer alternative within the work process should be identified to eliminate or reduce the use or production of mutagens and carcinogens. COSHH applies to mutagens and carcinogens as it is the case for other harmful substances, apart from the situation where it is not possible to prevent exposure on the reasonably practicable basis. In the case whereby employers have to apply the control measures in a priority and best practices order, they should also incorporate other practices to supplement prevention from exposure. These include total enclosure of the procedure and handling of systems, prohibition of eating, drinking or smoking, regular cleaning, designation of areas that may be contaminated, and use of warning signs to signal employees, as well as proper storage, handling and disposal of hazardous substances (Woodward & Atkinson, 1992).
The second recommendation is to ensure minimum exposure limits in the workplace and control exposure through inhalation. The incidence in this case study involves exposure through
inhalation whereby the office cleaner detergent irritated employees. The exposure by breathing hazardous substances in the workplace has to, therefore, be below a certain limit. The employee, in this case, needs to reduce exposure even further to reduce further attacks emanating from the irritation. Employers should ensure that they use substances that have WEL (Work Exposure Limit), which gives further safety guidelines on the handling and use of these substances. For substances that contain a WEL, employees need to be trained on how to incorporate principles of best practice to manage exposure to a specific level whereby almost all employees will be exposed on a regular basis with zero or minimize risks. Employers should, therefore, prioritize on using substances that have a WEL because it becomes easier to control exposure when using them (Hill, 1992).
The third recommendation is on PPE (Personal Protective Equipment) which is an alternative for achieving adequate control where it is not possible to achieve it using appropriate production, operational measures and best practices only. Personal protective equipment should be provided at zero cost to workers and should be used alongside the other control measures. The employer in this case study needs to ensure that all employees have the appropriate PPE which is stored, maintained and checked at regular intervals and repaired when in poor condition. The workers should put on protective clothing and have the right working equipment that ensures minimum exposure and maximum protection from the hazardous office cleaner. The workers need to be properly trained and supervised and consulted during the selection of PPE to ensure that the best is selected.
The fourth recommendation involves changing the process through which the hazardous substance is used (Woodward & Atkinson, 1992). This, however, depends on the identified risks and their potential effects on people. Substances whose effects occur via inhalation should not be
in their gaseous form which increases their hazardous ability. Instead, other forms of using the substance should be considered, such as usage in its liquid form. In this case study, it is recommended for the hazardous detergent to be used in a more friendly less hazardous form. In a similar situation whereby the highest risk occurs through ingestion, protective personal equipment and clothing should be used in designated places specific for this task only (Simpson & Simpson, 1991).
The fifth recommendation entails monitoring and evaluating the control measures. The management and safety department should ensure that the measures of control are installed and working effectively. Apart from monitoring the progress of the exposure reduction measures, the management should also ensure that the physical controls such as protective equipment are in good condition. Other control measures such as work systems, supervisions and procedures should be reviewed and monitored frequently to ensure that they are working.
Conclusion
COSHH generally requires all employees to conduct an adequate risk assessment and ensure that the work environment is comfortable and safe for all employees. Employers can achieve this through a series of activities including identification of the hazards, determining the risk level of each hazard, identifying the workers at higher risks level and the most vulnerable workgroups. They should also identify the appropriate preventive and control measures for the identified risks. Employers should conduct a risk assessment by real-life situations. However, due to a lot of dynamism in the job environment, the process of risk assessment should be done regularly, depending on the hazard and the possibility of causing harm to an employee.
Employers can as well conform to the COSHH requirements through effective planning for incidents, accidents, and emergencies that may occur in the workplace.
References
Cooke, R. A., Gavaghan, S., Hodgson, E. B., & Moore, S. (2011). General practitioners’ awareness of COSHH regulations. BMJ: British Medical Journal, 303(6810), 1132.
Garrod, A. N. I., Evans, P. G., & Davy, C. W. (2007). Risk management measures for chemicals: the “COSHH essentials” approach. Journal of Exposure Science and Environmental Epidemiology, 17(S1), S48.
Hill, E. C. (1992). COSHH regulations and microbial hazards associated with metal-working fluids. Tribology international, 25(2), 141-143.
Hyatt, N. (2003). Guidelines for process hazards analysis (PHA, HAZOP), hazards identification, and risk analysis. CRC press.
Palmer, K. T., & Freegard, J. (2006). Compliance with the Control of Substances Hazardous to Health Regulations (COSHH) 2008 and health and safety awareness in hairdressing establishments. Occupational medicine, 46(1), 49-52.
Simpson, D., & Simpson, W. G. (Eds.). (1991). The COSHH Regulations: a practical guide.
Royal Society of Chemistry.
Woodward, K. N., & Atkinson, K. (1992). The Control of Substances Hazardous to Health (COSHH) Regulations and their application to veterinary medicines. British Institute of Regulatory Affairs Journal, 10, 22-24.
Substances Hazardous To Health Student’s Name
Institutional Affiliation Date
Introduction
The control of substances hazardous to health (COSHH) provides important clarifications involving identification of substances hazardous to health, activities involving hazardous substances, how they may cause harm and how to mitigate as well as reduce the risk of harm occurring. The COSHH (2002) regulations apply to hazardous health substances that are found in the workplace and place the mandate on employers to ensure the safety of employees and other people from hazardous substances that they interact with at work (Palmer & Freegard, 2006).
Employees must achieve this by conducting a risk assessment, exposure control, and conducting health surveillance at the respective work environments. Hazardous substances in the workplace may take various forms including chemicals, dust, vapors, gases, fumes, nanotechnology or chemical-containing products.
This report provides an analysis of a case involving exposure precautions and preventions to protect employees and others from hazardous substances, as per the COSHH 2002 regulations. In this highlighted case study, employees working as cleaners in an office block protested to their supervisor against a newly introduced cleaning detergent that irritated their throats. Other staff members who worked till late while the cleaning took place also expressed their discomfort, prompting the facilities manager to seek an alternative detergent from their supplier. After reading the new detergent’s safety data sheet, the safety representative realized that the new cleaner was harsher than required, could also clean ovens and was potentially a carcinogen. The ultimate solution was to go back to using the original safer detergent but change its form of usage. It was no longer being sprayed on the cupboards surfaced, releasing some of it to the free air to be inhaled (Garrod, Evans & Davy, 2007). Instead, it was used by being directly sprayed into the cleaning cloth and on the cupboards in this manner.
COSHH Regulation Analysis
Upon identification of significant risks, as highlighted in this case study, the employer must undertake some measures to adhere to the regulation of the COSHH. The regulations COSHH regulations identified in this case generally involve preventing and controlling exposure to hazardous substances. According to COSHH regulation 7, employers should be focused on risk identification by considering prevention measures for exposure if logically practicable minimizing or controlling exposure, as well as considering whether the current control measures are effective in meeting the current COSHH guidelines on best practices (Palmer & Freegard, 2006).
Prevention of exposure to hazardous substances has to be based on reasonable practicability. Elimination of hazardous substance entails not using it, changing the unwanted process within the substance, or not producing the by/waste product. The exposure-causing method can be avoided by changing the process. Substitution may also be used in cases where elimination is not possible. This entails the use of a less harmful alternative such as substituting the irritant detergent with a milder one or brushing using a vacuum cleaner. The before substituting a substance with another, employers should importantly note that all the identified potential risks associated with that other substance are considered, including the risks covered under COSHH, among other regulations (Palmer & Freegard, 2006).
Another measure that can be used where elimination is not possible is the use of the product in the safest form possible; for instance using pellets as opposed to powder, to reduce dust exposure. Any workplace exposure limits (WELs) should not be exceeded for mutagens, sensitizers, and carcinogens. The exposure to these substances has to be reduced to lowly
reasonable and applicable levels. The second COSHH regulation about this case study entails exposure control. When it is not logically practicable to prevent exposure employers may look to control it. Control measures of exposure to hazardous substances have to be sustainable, workable and practicable. Control measures have to be given priority, aligned with the appropriate hierarchy and according to the risk level assessment.
Employers need to ensure designing, provision, and usage of the appropriate systems, processes, materials, equipment and engineering controls during work. There should also be adequate exposure control at various sources such as organizational measures and effective ventilation systems. In addition to these two measures, personal protective equipment has to be ensured. To achieve these standards, employers need to ensure safe storage, transport, and handling of substances, appropriate maintenance procedures, minimum possible substance use, and minimum possible number of workers exposed at the shortest possible duration. Proper hygiene measures such as adequate cleaning facilities also need to be in place.
Legal Provisions
COSHH (2000) contains some legal provisions that have to be applied and adhered, for reliable and effective control of exposure to hazardous substances in references to this case study. The first provision entails designing and operating activities and processes that minimize the disposal emission and spread of hazardous substances, to a reasonable, practical level. This is considered a much cheaper option than a reactive measure. Secondly, all relevant exposure routes such as the skin, breathing, and swallowing should be considered when developing the control measures (Cooke et al., 2011). The chemical, infectious and physical aspects of hazardous substances as these decide how the exposure occurs. Employers must consider the exposure
amount, possible effects on health and how the substance is used. The appropriate measures also need to be used in health risks control. These include important considerations such as the seriousness of the potential effect, the chances of its occurrence, and the stricter the required measures.
The COSHH also provides for decision making between the most reliable and effective control measures for minimizing the spread and escape of harmful substances (Cooke et al., 2011). Some options are more effective and reliable than others. For instance, changing the process to produce a less hazardous substance is more reliable while personal protective equipment relies on proper use and a perfect fit. A hierarchy should be developed; by effectiveness and reliability, hence preference is for the once that are higher in the list. This list includes the elimination of hazardous substances, modification of substance, workplace or process, application of controls to the process, working ways that minimize exposure, and PPE (Personal Protective Equipment) (Cooke et al., 2011).
While other measures of control cannot effectively control exposure, suitable PPE has to be combined with other measures of control. Adequate control is normally achieved through a combination of various measures. Protective personnel equipment has to be the last additional measures to supplement the others. The regular review s and check-ups are requirements in ensuring effective control measures. These include confirming whether the relevant equipment is working, used or maintained properly, all employees are supervised, instructed or trained appropriately, all identified measures of control are used and working appropriately, and whether all the records and checks are appropriately kept. The frequency of the checks and reviews need to be made dependent on the consistency of control and the consequences once they fail.
As another legal provision, employers need to train and inform all their employees on the risks, and hazards within their job environments as well as the respective control measures. For appropriate control of hazardous substances and risks, employees need to be aware of how to and the need of working in particular ways and using specific measures. This is especially so in situations where severe health effects may not occur until after exposure for a couple of years.
There may lack early or immediate warning signs of severe effects such as chemicals exposure which may lead to cancer many years after exposure, despite lack of early warning signs or symptoms.
COSHH requires employers to ensure that no single control measure increases safety or health risks (Palmer & Freegard, 2006). New risks can emerge from the change of processes, control measures as well as PPE. Control measures should, therefore, be analyzed and assessed any potential risks. The control measures should be only administered on the basis that they will control or prevent a more severe and significant risk. All employers should ensure the reasonable maximum protection of all employees from hazardous substances within the job environment.
All hazardous substances need to be adequately controlled at a reasonably practicable level. For employers to comply with their duty of prevention from hazardous substances, substitution should be preferred in the case where the employers avoid as long as it is reasonably practicable. Using of hazardous health substances in the workplace should be reduced by substituting or replacing it with another substance or a process that will reduce or eliminate the health risks to employees, under the manner of its use (Palmer & Freegard, 2006). In cases whereby it is not reasonably practicable to prevent the exposure to hazardous substances, employers may apply the appropriate protection measures about the respective risks identified.
These include measures that will regulate employees’ behavior such as eating habits and movements, or other factors within the work environment such as storage, ventilation or production procedures that are linked to hazardous substances thus increasing health risks.
Recommendations
Based on this case study, the first recommendation would be on more COSHH requirements for biological agents, mutagens, and carcinogens regarding prevention from exposure. These hazardous substances and risks lack early warning signs and may, therefore, take long before their health effects can be felt. It is, therefore, recommendable to conduct a risk assessment to determine whether mutagens and carcinogens are present and if they are; their nature and levels of risk (Simpson & Simpson, 1991). This ensures that precautions and control measures are adequately undertaken. If possible, a safer alternative within the work process should be identified to eliminate or reduce the use or production of mutagens and carcinogens. COSHH applies to mutagens and carcinogens as it is the case for other harmful substances, apart from the situation where it is not possible to prevent exposure on the reasonably practicable basis. In the case whereby employers have to apply the control measures in a priority and best practices order, they should also incorporate other practices to supplement prevention from exposure. These include total enclosure of the procedure and handling of systems, prohibition of eating, drinking or smoking, regular cleaning, designation of areas that may be contaminated, and use of warning signs to signal employees, as well as proper storage, handling and disposal of hazardous substances (Woodward & Atkinson, 1992).
The second recommendation is to ensure minimum exposure limits in the workplace and control exposure through inhalation. The incidence in this case study involves exposure through
inhalation whereby the office cleaner detergent irritated employees. The exposure by breathing hazardous substances in the workplace has to, therefore, be below a certain limit. The employee, in this case, needs to reduce exposure even further to reduce further attacks emanating from the irritation. Employers should ensure that they use substances that have WEL (Work Exposure Limit), which gives further safety guidelines on the handling and use of these substances. For substances that contain a WEL, employees need to be trained on how to incorporate principles of best practice to manage exposure to a specific level whereby almost all employees will be exposed on a regular basis with zero or minimize risks. Employers should, therefore, prioritize on using substances that have a WEL because it becomes easier to control exposure when using them (Hill, 1992).
The third recommendation is on PPE (Personal Protective Equipment) which is an alternative for achieving adequate control where it is not possible to achieve it using appropriate production, operational measures and best practices only. Personal protective equipment should be provided at zero cost to workers and should be used alongside the other control measures. The employer in this case study needs to ensure that all employees have the appropriate PPE which is stored, maintained and checked at regular intervals and repaired when in poor condition. The workers should put on protective clothing and have the right working equipment that ensures minimum exposure and maximum protection from the hazardous office cleaner. The workers need to be properly trained and supervised and consulted during the selection of PPE to ensure that the best is selected.
The fourth recommendation involves changing the process through which the hazardous substance is used (Woodward & Atkinson, 1992). This, however, depends on the identified risks and their potential effects on people. Substances whose effects occur via inhalation should not be
in their gaseous form which increases their hazardous ability. Instead, other forms of using the substance should be considered, such as usage in its liquid form. In this case study, it is recommended for the hazardous detergent to be used in a more friendly less hazardous form. In a similar situation whereby the highest risk occurs through ingestion, protective personal equipment and clothing should be used in designated places specific for this task only (Simpson & Simpson, 1991).
The fifth recommendation entails monitoring and evaluating the control measures. The management and safety department should ensure that the measures of control are installed and working effectively. Apart from monitoring the progress of the exposure reduction measures, the management should also ensure that the physical controls such as protective equipment are in good condition. Other control measures such as work systems, supervisions and procedures should be reviewed and monitored frequently to ensure that they are working.
Conclusion
COSHH generally requires all employees to conduct an adequate risk assessment and ensure that the work environment is comfortable and safe for all employees. Employers can achieve this through a series of activities including identification of the hazards, determining the risk level of each hazard, identifying the workers at higher risks level and the most vulnerable workgroups. They should also identify the appropriate preventive and control measures for the identified risks. Employers should conduct a risk assessment by real-life situations. However, due to a lot of dynamism in the job environment, the process of risk assessment should be done regularly, depending on the hazard and the possibility of causing harm to an employee.
Employers can as well conform to the COSHH requirements through effective planning for incidents, accidents, and emergencies that may occur in the workplace.
References
Cooke, R. A., Gavaghan, S., Hodgson, E. B., & Moore, S. (2011). General practitioners’ awareness of COSHH regulations. BMJ: British Medical Journal, 303(6810), 1132.
Garrod, A. N. I., Evans, P. G., & Davy, C. W. (2007). Risk management measures for chemicals: the “COSHH essentials” approach. Journal of Exposure Science and Environmental Epidemiology, 17(S1), S48.
Hill, E. C. (1992). COSHH regulations and microbial hazards associated with metal-working fluids. Tribology international, 25(2), 141-143.
Hyatt, N. (2003). Guidelines for process hazards analysis (PHA, HAZOP), hazards identification, and risk analysis. CRC press.
Palmer, K. T., & Freegard, J. (2006). Compliance with the Control of Substances Hazardous to Health Regulations (COSHH) 2008 and health and safety awareness in hairdressing establishments. Occupational medicine, 46(1), 49-52.
Simpson, D., & Simpson, W. G. (Eds.). (1991). The COSHH Regulations: a practical guide.
Royal Society of Chemistry.
Woodward, K. N., & Atkinson, K. (1992). The Control of Substances Hazardous to Health (COSHH) Regulations and their application to veterinary medicines. British Institute of Regulatory Affairs Journal, 10, 22-24.
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