COSHH: A guide for farms

Successful farming depends on the use of a wide range of hazardous substances such as herbicides, pesticides, and cleaning chemicals. Activities such as harvesting and straw chopping generate dust. Welding of farm machinery creates fumes. In short, farming relies on – and often generates – a lot of hazardous material.

To ensure an agricultural working environment is as safe as possible, farmers and farm workers must understand and adhere to the Control of Substances Hazardous to Health (COSHH) Regulations 2002. This article outlines how COSHH applies to farming, and how you can best comply.

• What does COSHH cover?
• Why is COSHH important?
• What are employer responsibilities under COSHH?
• What are employees’ responsibilities under COSHH?
• What are hazardous substances on farms?
• What control measures can you put in place?
• What is a COSHH assessment?
• FAQs

What does COSHH cover?

COSHH is a regulatory framework designed to protect workers from potential health risks caused by exposure to hazardous substances in the workplace. It involves identifying and assessing risks, implementing control measures, and providing necessary information, training, and supervision to promote a safe and healthy working environment.

Why is COSHH important?

COSHH is important for farms due to the nature of their operations, which frequently use or generate hazardous substances. Adhering to the regulations delivers significant benefits, including:

• Improved health and safety. COSHH helps farms to protect farm workers from potential health risks associated with hazardous substances. While corrosive and toxic substances grab the headlines, others can have longer-term (chronic) effects, such as mutagenic (DNA damaging), teratogenic (harmful to unborn children), carcinogenic (causing cancer), and sensitising effects, such as causing asthma and dermatitis.
• Environmental protection. COSHH requires waste from hazardous substances to be disposed of safely in a way that doesn’t put the environment at risk.
• Legal compliance. Failing to comply with COSHH regulations is dangerous, and can lead to major penalties, including unlimited fines and even imprisonment. Further, it is normally a condition of your farm insurance that you comply with applicable industry legislation.

What are employer responsibilities under COSHH?

Farm employers have a wide range of responsibilities under COSHH. The key ones are as follows:

• Identifying hazardous substances used in the workplace or generated by working activities. These can include everything from pesticides to poultry dust or veterinary medicines.
• Planning how to prevent harm to health. This is done by conducting a COSHH risk assessment (see below).
• Having control measures to prevent harm to health. These could include elimination (removing a hazard), substitution (using a safer substance), engineering controls (isolating people from the hazard), administrative controls (changing the way people work) and ensuring workers use suitable PPE.
• Making sure control measures are used. Control measures need to be adhered to during day-to-day work on the farm.
• Keeping control measures in good working order. This could include ensuring you always have adequate PPE in stock and that all new workers know safe working practices.
• Ensuring workers receive information, instruction, and training to ensure they comply with your control measures. This can be included in your health and safety training and should provide access to Safety Data Sheets (SDS) for all hazardous substances and ensure workers understand how to interpret them.
• Providing health monitoring. If there is a likelihood of exposure to certain substances that could result in health effects, farm employers may be required to provide health surveillance to monitor the health of their workers and detect any adverse effects early on.
• Emergency planning. Farms should have appropriate emergency plans to respond to accidents, spills, or incidents involving hazardous substances. This includes procedures for evacuation, first aid, decontamination, and the provision of necessary emergency equipment.

What are employees’ responsibilities under COSHH?

Farm workers also have responsibilities under COSHH to keep themselves and others safe. These include:

• Complying with control measures. Workers need to adhere to any control measures that are in place, such as procedures for handling, using, and disposing of hazardous substances.
• Using PPE. Employees should always use appropriate PPE provided by their employer. It should be worn in accordance with the manufacturer’s instructions, stored correctly and, if it could cause contamination, removed before eating, drinking, or smoking.
• Taking part in training. Workers have a responsibility to participate in training provided by their employer regarding the risks associated with hazardous substances and the proper use of control measures and PPE. This helps them understand the risks, improve their awareness, and ensure their safety and that of others.
• Reporting concerns and incidents. Employees should promptly report any concerns or incidents related to hazardous substances to their employer or supervisor. These might include accidents, spills, leaks, equipment malfunctions, or any signs of ill health that may be related to their work. They should also report any defects in PPE immediately.
• Personal hygiene. All farm workers should practise good personal hygiene, such as washing hands before eating or drinking, and follow proper decontamination procedures if they come into contact with hazardous substances.
• Health monitoring. If health surveillance is provided by the farm employer, employees should participate. This may involve regular health checks and providing relevant information about their health and exposure history. Health monitoring is particularly important for workers exposed to dust that can cause lung disease, substances such as solvents that can cause skin issues, not to mention sheep dips that contain organophosphorus (OP) compounds.

What are hazardous substances on farms?

Many hazardous substances on farms fall under the scope of COSHH. The HSE outlines the types of substances covered in all workplace settings. These include chemicals, products containing chemicals, fumes, dusts, vapours, mists, and gases.

For the purposes of farming, common hazardous substances include:

• Pesticides, herbicides, insecticides, and fungicides. Some of these chemicals can be toxic and pose risks if not handled, stored, or used correctly.
• Veterinary medicines. Livestock farms will use veterinary medicines such as antibiotics, vaccines, or parasiticides. These substances can be hazardous if mishandled or if workers are exposed to them without proper precautions.
• Fertilisers. Some fertilisers contain ammonium nitrate or other nitrogen-based compounds, which release toxic gases or cause chemical burns if not handled with care. Inhalation or contact with these substances can be harmful to health.
• Cleaning agents. Farms use cleaning agents for equipment, animal housing areas and other facilities. These agents can contain corrosive, toxic or irritant chemicals, posing risks to workers if used improperly or without adequate protection.
• Silage and animal waste. Silage and animal waste can release harmful gases that pose respiratory risks to workers if exposed to high concentrations.
• Dusts and allergens. Farms often generate dust from harvesting, feed processing, or animal bedding. Dust particles can contain allergens, pathogens, or harmful substances, causing respiratory issues or allergic reactions.

Please refer to the HSE advice sheets for more information on controlling agricultural dusts.

Hazardous substances on farms: FAQs

Is lead covered by COSHH?

No, lead is not covered by COSHH. Instead, it is subject to The Control of Lead at Work Regulations 2002. This covers the handling, processing, storage and disposal of lead, its alloys and compounds. You can download guidance on this legislation here.

Does COSHH cover asbestos?

Similarly, COSHH does not cover asbestos because it is also subject to different legislation, The Control of Asbestos Regulations 2012. Asbestos control is a complex topic, and it’s vital to comply with the law relating to this substance. You can find HSE guidance about asbestos here.

Is bleach covered by COSHH?

Yes, bleach is considered a hazardous substance under COSHH because it irritates eyes and skin and is corrosive. If you are unsure whether a chemical or cleaner is covered by COSHH, check to see whether the packaging has a hazard pictogram. If it does, it will fall under the COSHH regulations.

What control measures can you put in place?

There are three main types of control measures you can put in place to comply with COSHH and improve farm safety. These are:

• Eliminating exposure
• Controlling exposure
• Monitoring health

1.      Eliminating exposure

This is about preventing exposure to hazardous substances where possible. Ways of achieving this include using organic pest control methods rather than chemical pesticides or choosing products with lower hazard classifications, such as fertilisers and veterinary medicines with less harmful ingredients.

2.      Controlling exposure

This type of measure is about controlling workers’ exposure to hazardous substances. You could use engineering controls such as installing ventilation systems, establishing safe working practices for handling hazardous substances such as sheep dip, and supplying regular training and appropriate PPE for all relevant personnel.

3.      Monitoring health

You could implement a health monitoring programme to monitor workers’ health when working with hazardous substances. This may involve periodic medical examinations, monitoring absences from work to pick up on potential health problems, or simply keeping an eye out for workers who show any signs of dermatitis or breathing difficulties.

What is a COSHH assessment?

A COSHH assessment is a systematic process used to identify and evaluate the risks associated with hazardous substances in the workplace. It involves assessing the potential harm these substances can cause workers’ health and implementing control measures to minimise or eliminate those risks. A thorough and regularly revisited COSHH assessment is essential for farms to comply with the regulations and ensure the workplace is as safe as possible.

Typically, a COSHH assessment follows the following steps:

• Identifying the risks. You determine the substances used, produced, or present on the farm that could be hazardous to health.
• Assessing the risks: You evaluate the risks associated with each hazardous substance. This considers factors such as the nature of the substance, exposure routes (inhalation, ingestion, skin contact), quantities used or generated, frequency and duration of exposure, and potential health effects.
• Determining control measures. We’ve covered many of these, but they can include engineering controls (such as ventilation systems), administrative controls (better training), and making sure workers have appropriate PPE.
• Recording findings. This is about documenting the assessment findings, including details of the hazardous substances, associated risks, and control measures you’ve implemented.
• Reviewing and monitoring. You need to review and monitor the effectiveness of the control measures. Make regular assessments to ensure that the implemented measures adequately control the risks and take corrective actions if necessary.

FAQs

Do I need to conduct a COSHH assessment for every substance used on the farm?
Yes, a COSHH assessment should be conducted for every hazardous substance used, produced, or present on the farm to identify potential risks and implement appropriate control measures.

How often should a COSHH assessment be reviewed?
A COSHH assessment should be reviewed regularly or whenever there are changes in substances used, processes, or regulations. This ensures that your farm’s control measures remain effective and up to date.

Who should conduct the COSHH risk assessment on a farm?
A COSHH risk assessment on a farm can be conducted by the farm owner, manager, or a competent person with sufficient knowledge and understanding of the farming sector and the types of hazardous substances used or generated. Many farm owners use professional, third-party risk assessment services, such as Alan Boswell Risk Management, to ensure their COSHH assessments are as thorough as possible and to help them maintain a safe working environment.

Next steps

Complying with COSHH regulations is essential for farms and those working on them. It not only helps you avoid potentially expensive penalties, but it also helps you create a safer workplace and better protects your employees’ health. That said, undertaking COSHH assessments takes time, which can be hard to find if you’re a busy farm owner. Alan Boswell Risk Management’s industry experts regularly undertake COSHH risk assessments and can help you with any other aspect of your health and safety, including regular engineering inspections. To find out more, contact 01603 967900.