Q.01

How does COSHH Essentials choose the right chemical exposure controls?

COSHH Essentials picks a control approach by combining two inputs: a hazard group taken from the product's CLP H-statements, and an exposure potential band built from dustiness or volatility plus the amount used. It then picks the least stringent approach that is expected to keep airborne exposure within the concentration range HSE treats as "adequate control" for that hazard group. The method is set out in HSE's technical basis document, COSHH essentials: Controlling exposure to chemicals – a simple control banding approach (01/17). It covers liquids and solids only, not gases or liquids used above their boiling point.

Approach: I read the HSE ACOP and guidance L5 entries on COSHH Essentials and the INSST authorised Spanish translations of the control guidance sheets. I then read the HSE technical basis document in full.

The four steps

Step 1: Hazard group (A to E, plus S). HSE sorts the toxicological H-statements into five groups. Each of groups A to D has a target airborne range that counts as adequate control:

GroupExample H-statementsDust (mg/m³)Vapour (ppm)
AH304, H315, H319, H336, EUH066>1 to 10>50 to 500
BH302, H312, H332, H371>0.1 to 1>5 to 50
CH301, H311, H314, H317, H318, H331, H335, H370, H373, EUH071>0.01 to 0.1>0.5 to 5
DH300, H310, H330, H351, H360, H361, H362, H372<0.01<0.5
EH334, H340, H341, H350, EUH070none setnone set
  • Group E covers genetic damage, cancer and respiratory sensitisation. For these, HSE says no safe exposure level can be identified with confidence, so specialist advice "should be sought" case by case.
  • Group S is separate and stacks on top of the others. It flags substances that harm by direct skin or eye contact or are absorbed through the skin. These get the extra skin and eye measures in sheets S100 to S102 and S200.

Step 2: Exposure predictor (EP) band, 1 to 4.

  • For solids, dustiness is rated low, medium or high.
  • For liquids, volatility at the process temperature is rated low, medium or high. At room temperature (25 °C): low means a boiling point above 150 °C, medium 50 to 150 °C, and high at or below 50 °C. For heated or cooled processes there are formulas based on process temperature.
  • Amount is small, medium or large: grams, kilograms or tonnes for solids, and millilitres, litres or cubic metres for liquids.
  • The two are combined into EP1 to EP4. For example, grams of a low or medium dustiness solid is EP1, and tonnes of a medium dustiness solid is EP4.

Step 3: What each control approach (CA) is expected to achieve:

CATypeExpected reduction vs general ventilation
1General ventilation1 (baseline)
2Engineering control (LEV)10-fold
3Containment100-fold
4SpecialNone given; expert advice needed

Step 4: Choosing the approach. For the EP band, HSE checks CA1, then CA2, then CA3. The first one whose predicted exposure falls within or below the hazard group's target range is the one chosen. If none of them gets low enough, CA4 (specialist advice) is recommended. HSE's worked example for a group B solid (target 0.1 to 1 mg/m³):

  • Grams: CA1 is enough.
  • Kilograms of medium dustiness material: CA2.
  • Tonnes: CA3.

Resulting matrix (HSE Table 6)

Hazard groupEP1EP2EP3EP4
A solid / liquidCA1 / CA1CA1 / CA1CA1 / CA1*CA2 / CA2
B solid / liquidCA1 / CA1CA1 / CA1CA2 / CA2CA3 / CA2
C solid / liquidCA1 / CA1CA2 / CA2CA3 / CA3CA4 / CA3
D solid / liquidCA2 / CA2CA3 / CA3CA4 / CA4CA4 / CA4
ECA4CA4CA4CA4

*Later validation found that a medium amount of a high-volatility group A liquid needs CA2.

The matrix HSE actually publishes is more cautious in two more places:

  • A large amount of a high-volatility group B liquid takes CA3.
  • A large amount of a medium-volatility group C liquid takes CA4.

Adjustments in the e-tool

  • Under 15 minutes a day: the approach drops one level, from CA3 to CA2 or from CA2 to CA1.
  • Mixtures made by the user:
    • Any group S or group E component makes the whole mixture S or E.
    • A group D or C component at ≥0.05% makes it D or C.
    • A group B component at ≥10% makes it B.
    • Otherwise the mixture is group A.
    • An H334 component at 0.1% to <0.5% follows its own lookup table.
  • Aerosols: the amount is taken as the total amount in use. HSE advises a stricter approach than the matrix gives, unless a sheet specific to that task exists. For hand-held aerosol sprays, ignore the propellant and use the lowest boiling point among the ingredients.
  • Volatile solids (e.g. naphthalene): assess both as a dust and as a vapour, and apply the stricter result.
  • Respiratory protective equipment (control approach R): sheets R1 to R6 cover RPE with assigned protection factors from 4 to 2000, set from the hazard group, amount and dustiness or volatility. HSE describes RPE as "the last line of defence".

Each CA links to its own control guidance sheets: the 100 series for CA1, 200 for CA2, 300 for CA3 and 400 for CA4. The INSST Spanish versions repeat the same wording, for example sheet 210 is for cases where the control banding tool recommends control approach 2 [1]. The skin sheet S101 asks for the same inputs: dustiness, boiling point, process temperature and task duration [2].

Legal standing under COSHH (L5)

  • Use is optional. L5 guidance says employers "may use" COSHH Essentials to identify control measures. It also says "it remains the responsibility of employers to ensure that they" are, among other things, controlling exposure adequately under regulation 7(7) [3][4].
  • Assessment records. The output "may" be used as part of the significant findings recorded under regulation 6(4) [5].
  • When it gives no answer. ACOP text says that if no suitable controls can be identified this way and no WEL exists, an in-house exposure standard "may" be possible and useful [6].
  • Complex tasks. For more complex processes, employers may need competent specialist help [7].

Sources:

Q.02

How do the Spanish INSST control sheets compare?

The INSST Fichas de Control de Agentes Químicos (FCAQ) are authorised Spanish translations of HSE's COSHH Essentials sheets, so the control advice and the control strategy 1 to 4 numbering are the same. Three things differ:

  • Scope: INSST translated only part of HSE's set.
  • Legal references: the sheets cite Spanish law and Spanish exposure limits instead of the UK COSHH framework.
  • No selection step: the Spanish set contains no hazard-group or exposure-band method of its own. It sends users back to HSE's "control banding" tool to find out which strategy applies.

Approach: I read the INSST FCAQ collection in full (107 sheets) and compared it with HSE's published COSHH Essentials sheet indexes. I did not compare the Spanish wording line by line against each English original.

What is the same

  • Same origin and stated purpose. Each sheet says it is an authorised translation of HSE's "Control guidance sheet" or "Direct advice sheets" from COSHH essentials: easy steps to control chemicals [8][9].
  • Same trigger. Sheet 100 is to be used where "la herramienta 'control banding' recomienda una estrategia de control 1" (the control banding tool recommends control strategy 1) [10].
  • Same technical content. Sheet 100, for example, recommends 5 to 15 air changes per hour and keeping records of checks, for example for the last five years [10][8].
  • Same group S logic.
    • Skin and eye measures are additional to the 100, 200 and 300 series.
    • Substitution comes first.
    • PPE "únicamente debe considerarse" (should only be considered) when other controls are not feasible [11][12].
    • Sheet S101 keeps HSE's inputs: dustiness (high, medium or low), boiling point and process temperature [2].

What differs

1. No selection method in Spanish. I found no Spanish sheet that sets out hazard groups A to E, the H-statement mapping, volatility bands or the 15-minute adjustment. "Grupo de peligro" appears only in S100, and only for group S. The Spanish sheets are the output end of HSE's method, not a replacement for it.

2. Spanish legal references replace UK ones. The "Más información" (further information) boxes cite:

  • RD 374/2001 (chemical agents at work)
  • RD 486/1997 (workplaces)
  • RD 665/1997 (carcinogens)
  • the INSST technical guides
  • Límites de exposición profesional para agentes químicos en España (Spain's occupational exposure limits list)

These references appear in sheet 100, CR1 and G409 [8][13][14]. Every sheet in the 100 to 300, CR, QY, BK, MN, ST and FD series cites RD 374/2001. The four S sheets do not.

3. Spanish limit values in the silica sheets.

  • QY0 gives respirable crystalline silica a Spanish VLA-ED® of 0.05 mg/m³ [15].
  • CR1 says proper controls generally keep exposure below the established limit (0.05 mg/m³) [16].
  • G409 says engineering controls may be sufficient where results are below one third of the occupational exposure limit [17].

4. RPE given as protection factors.

  • CR1, where no measurement data are available, gives RPE with a protection factor of at least 20 as an example [18].
  • The foundry sheets ask for a nominal protection factor of 48 or more, noting that some countries use an assigned protection factor, which "debería ser de 20 o más" (should be 20 or more) [19].
  • Strategy R appears only as the header of sector sheets BK5, CR1 and MN1 to MN4. I found no Spanish equivalents of HSE's general RPE sheets R1 to R6.

5. Same voluntary status. G409 and CR1 say they contain good-practice guidance "que no son obligatorias" (that is not mandatory) [14]. QY0 says alternative measures may be adopted [20]. This matches L5's "may use".

Coverage: Spanish set vs HSE

SeriesINSST sheetsCompared with HSE
Strategy 1 (100)100 to 103 (4)Core set
Strategy 2 (200)200 to 231 (32)Core set
Strategy 3G300 to G322 (23)Core set
Strategy 4G406, G409 only (2)HSE also lists G401 to G404 (health monitoring and surveillance) and G408 (isocyanate urine sampling) (HSE CA4 index). FD5 still points to G402 [21]
Skin and eye (S)S100, S101, S102, S200 (4)Core set
Silica sectorsCR0 to CR5 (6), QY0 to QY8 (9), BK0 to BK7 (8), MN0 to MN4 (5), ST0 to ST7 (8), FD0 and FD2 to FD6 (6)Ceramics, quarries, brick and tile, manufacturing, stone and foundry are covered. HSE's construction silica series has no Spanish series
Other HSE sector seriesnone foundHSE also publishes agriculture, flour, metalworking fluids, microelectronics, motor vehicle repair, offshore, printing, rubber, service and retail, welding, woodworking and dichloromethane (HSE direct advice)

Editions

The sheets were published in batches with different NIPO numbers:

  • Sheets 100 to 208 carry FCAQ.1.1.16.
  • Sheets 209 to 231 and the S sheets carry FCAQ.2.1.17.
  • The G300 series carries FCAQ.3.1.18.
  • The sector series carry their own numbers: QY, G406 and G409 share 871-19-022-X; FD has 118-25-028-4.

The earlier sheets credit the translation to the "Instituto Nacional de Seguridad e Higiene en el Trabajo (INSHT)" and cite the HSE original as October 2003 [8]. The later ones credit INSST [9].

Sources:

Q.03