Ready for inspection

The Health and Safety Executive (HSE) has announced its updated business plan for 2025/26, with 14,000 inspections planned for across the UK. HSE’s priorities for 2025/26 include:

• Hazardous substances and agents: Risks associated with asbestos, noise, hazardous dust, and exposures to radiation, lead, and chromium VI.
• Musculoskeletal disorders (MSDs).
• Work-Related stress and aggression.
• Health surveillance and support services.
• Legionella prevention.

This article focuses on hazardous dust and the Control of Substances Hazardous to Health (COSHH) 2002 Regulations.

It is worth noting that the plan specifically mentions respirable crystalline silica (RCS), isocyanates, and dusty ingredients, so any business using these substances will likely receive an inspection.

The HSE’s overarching objective is to protect people by reducing risks to health and safety at work. The latest edition to its 10-year plan prioritises the prevention of occupational lung disease.

With 1.7 million people suffering work-related illness and 12,000 estimated deaths a year linked to past workplace exposure, the HSE’s proactive approach aims to enforce, assure and evaluate control measures in target sectors where evidence, research and insight demonstrate high levels of incidence and risk.

To help FMs navigate the HSE’s updated priorities, the following guidance provides a solid foundational overview of how to prepare. Synergy advises talking with an occupational hygiene expert for assistance.

RISK ASSESSMENT

A typical COSHH risk assessment involves five steps:

• Identify hazardous substances: Review all substances used or generated in the workplace.
• Assess the risks: Who might be exposed, how, and for how long?
• Decide on control measures: Determine how to prevent or control exposure through ventilation, process changes, PPE, or training.
• Record the findings: Keep clear documentation of the risks and actions taken, essential for compliance and audits.
• Review and update regularly: Update risk assessments when work processes change, new substances are introduced, or after incidents.

WORKPLACE EXPOSURE LIMITS

EH40/2005 is an HSE document that contains a list of workplace exposure limits (WELs) for use with the COSHH regulations.

WELs are concentrations of hazardous substances. They are averaged over a specified period, which is referred to as the time-weighted average.

WELs are the legal limit, and results that fall below them do not guarantee the safety of employees. Synergy recommends that companies aim to achieve <10 per cent of the WEL in line with the recommendations of BS EN 689:2018.

MONITORING & CONTROLLING EXPOSURE

Exposure monitoring plays a fundamental part in assessing risks. We recommend two air monitoring methods:

• Personal sampling: Workers wear personal air samplers that measure hazard concentration in the breathing zone.
• Area sampling: Stationary air samplers are placed in work areas to gauge general air quality and hot spots.

Air monitoring is appropriate when there is a need to show compliance with a WEL and that control measures are working. For businesses using chemicals, biological monitoring may be appropriate. It measures substances that have entered the body and can be conducted by blood, urine and hair sampling.

MONITORING CHALLENGES

• Exposure variability: Levels of airborne hazards vary greatly by job and individual working practice.
• Sampling duration: It this is too short it may miss fluctuations and too long can be impractical.
• Detection limits: Difficulty detecting low levels of hazards, especially with other dust sources present.
• Instrument calibration: Poorly calibrated instruments can overestimate or underestimate exposure levels, leading to incorrect conclusions and potentially inadequate protective measures.
• Data interpretation: Interpreting collected data requires a high level of skill.

Control: It is good COSHH practice to adopt the ALARP principle, As Low As Reasonably Practicable. The Hierarchy of Control is a tool to help achieve this principle and prioritises control methods from most effective to least:

• Elimination: Remove the hazardous substance entirely from the workplace.
• Substitution: Replace the substance with a safer alternative.
• Engineering Controls: Implement physical controls like Local Exhaust Ventilation (LEV) to reduce exposure at the source.
• Administrative Controls: Introduce procedural methods such as safe work practices, job rotation, or restricted access to limit exposure.
• Personal Protective Equipment (PPE): As a last resort, provide PPE, such as respirators, to protect individual workers.

HEALTH SURVEILLANCE

Health surveillance is necessary when:

• Exposure at work can be directly connected to a specific disease or health condition.
• It is possible to detect illnesses early and reduce potential harm.
• Conditions in the workplace are likely to cause illness.

Health surveillance includes spirometry, skin surveillance and biological sampling.

READY FOR INSPECTORS

Having a thorough risk assessment does not guarantee a smooth inspection. An inspector will use their expertise and judgment to assess workplace safety. Dusty floors or workers not following safety procedures are surefire ways of receiving enforcement notices.

Workplace safety is a team effort. Staff training and implementing best practices every working day will help to ensure worker safety and regulatory compliance.