Health & Safety Update (August 2010)

Interaction of REACH and COSHH

Registration, Evaluation, Authorisation and Restriction of Chemical substances (REACH) and Control of Substances Hazardous to Health (COSHH) both impose requirements on the use of hazardous chemicals in the workplace. Although REACH and COSHH should ultimately complement one another, their requirements overlap to some extent and this has the potential to give rise to inconsistencies in their application. While REACH and COSHH share the same philosophy, better protection of human health, there are a number of differences in how they set about achieving those ends.

• REACH is a very broad ranging Regulation, and its requirements encompass occupational health and safety, environmental protection and consumer protection. COSHH is focussed solely on the first of these.
• COSHH requires all employers to assess the risks to employees' health created by work with hazardous substances, and identify the necessary controls. REACH places the onus of risk assessment and the identification of the necessary controls much higher up the supply chain (on the manufacturer or importer). Because of this, COSHH risk assessments are more likely to be site-specific, while the risk management measures identified by REACH are likely to be more broad-based.
• COSHH covers all work activities involving hazardous substances and includes process derived substances- fumes, dusts etc. REACH will not address process-derived substances, but instead addresses the manufacture of a substance and all its identified uses across the EU, provided the substance is manufactured or imported by the registrant at 10 tonnes per year or more.
• REACH is substance-driven, and the risk assessments will relate to the use of that substance throughout the supply chain. It is unlikely to take into account the other substances in use on any one particular site or the interactions of different substances in certain processes. COSHH is process driven- the employer looks at the process being carried out, including existing controls, and then at all the substances used in the process.
• REACH exempts a number of substances from REACH entirely, for example, waste, or substances covered by legislation on the carriage of dangerous substances or mixtures. Other substances have partial exemptions from REACH, for example, a substance used in medicinal products. 

We at Mentor can help you with all aspects of your duties under REACH and COSHH. Call your dedicated consultant or the Mentor Telephone Advice Service for more details.