The Regulations

The Control of Substances Hazardous to Health Regulations (COSHH) introduced a legal framework for controlling people's exposure to hazardous substances arising from work activities.

The primary requirement of COSHH is for employers to make an assessment of the health risks created by work and the measures that need to be taken to protect people's health and meet the requirements of the remainder of the Regulations. Hairdressers (employers and self-employed) have duties under the Regulations towards employees and customers as appropriate.

COSHH covers virtually all substances that have the potential to cause harm to people's health. Products manufactured for use in hairdressing salons are not generally thought to be ‘hazardous to health' but a number of products because of their ingredients do come within the scope of the Regulations.

All cosmetic products, including hair preparations supplied to hairdressing salons must comply with the Cosmetic Products (Safety) Regulations, 2008. These Regulations require that cosmetic products are not liable to cause damage to human health when applied under normal conditions of use. They also lay down maximum concentrations for many substances in cosmetic products. So, provided you use substances in accordance with instructions, there should be no problems.

The Health and Safety at Work etc. Act, 1974, places a general duty upon the manufacturers/suppliers of substances to supply adequate information about any risks to health and safety from the substance and the precautions necessary to reduce the risks.

The practical effect is that you will receive information on hazards and safe methods of using preparations. If you do not have these safety data sheets, ask your supplier for them - they have a legal duty to provide them.

Assessment

Owners of hairdressing salons, in pursuing their work activity which involves the use of the above-mentioned substances, are required to carry out ‘suitable and sufficient' assessments of the risks to health to fulfil their responsibility to employees and customers.

Assessment is the cornerstone of the COSHH Regulations and its main purpose is to ensure that in the case of all work involving substances hazardous to health, a systematic approach is taken to identifying precautions which are related to the risks.

Substances may be hazardous by:
Inhalation; ingestion (either directly or from settling on food etc. or from eating food with contaminated fingers); absorption - through the skin or via the eyes (either directly or from contact with contaminated surfaces or clothing); direct contact - with the surfaces of the skin or eyes; and injection - into the body by high pressure equipment or contaminated sharp objects.

In assessing the risks the following needs to be answered:
• Do the substances used have the potential to cause harm? (You can find this out from the hazard information supplied with the product)
• If so what type of harm?
• What is the chance of exposure occurring? (For example does the way you use it lead to prolonged skin contact?)
• Who could be affected?
• Have you had any cases where staff have developed problems e.g. skin rashes?
• Can exposure be prevented?

If you are sure that the way you use products leads to no risk to health, then you simply need to write down your conclusions. However if you believe that there may be a risk, then you need to consider what you can do to prevent any harm occurring.

COSHH requires exposure to hazardous substances to be prevented or where this is not reasonably practicable to be adequately controlled.

Providing hairdressing products are used in accordance with the manufacturer's instructions, in well-ventilated salons, the task of assessment is a comparatively simple one.

Employees should be informed of the findings of assessments and any methods they need to follow to minimise risks.

Employers also have a legal duty to ensure that safe working methods are followed. A written record of the assessment should be made except in the most simple cases, where the risks and precautions necessary can be easily communicated to staff or to an inspector from the health and safely enforcing authority.

Control Measures

Wherever safer products are available they should be used. The basic rules for handling and use of hair care products should always be followed.

Where a product is a known skin irritant or staff develop contact allergy to them, sensible precautions include: using the recommended concentration; clearing up spillages immediately; resealing containers immediately after use; and providing safe storage facilities. Where there is any possibility of skin contact, gloves should be worn during mixing and pouring while face shields or goggles can help prevent splashes in the eyes.

A small scale survey of the levels of atmospheric contaminants in salons, undertaken by the Health & Safety Executive (HSE) concluded that the concentrations were below any occupational exposure limits in place at the time. Employers should, however, ensure that there is a good level of ventilation in salons and that the use of products which might become airborne, such as aerosols, is kept to a minimum.

Information and Records

The records should include:
• Hazardous ingredients of preparations with the corresponding maximum concentrations
• The method/mode by which the substance is hazardous e.g. skin contact, inhalation, etc
• Persons likely to be exposed and how
• Prevention and control measures for the activity

Health Surveillance

Where exposure to products gives rise to visible health effects such as skin rashes and dermatitis, health surveillance in the form of regular skin inspections by a responsible member of staff appointed by the employer should be carried out. This will provide information on the effectiveness of the controls in place and allow prompt remedial action to be taken in the case of any condition identified. A separate record should be kept for each employee undergoing health surveillance.

Key Action Points

Ensure that a ‘suitable and sufficient' assessment has been carried out in accordance with Regulation 6 of the COSHH Regulations and recorded. That the resulting safe systems of work have been communicated to employees as relevant and implemented.

References

Control of Substances Hazardous to Health. The Control of Substances Hazardous to Health Regulations, 2002 (as amended) Approved Code of Practice and Guidance L5 2005 HSE Books

Full information on health and safety in hairdressing can be found on www.hse.gov.uk/hairdressing/

Specific guidance on COSHH is available at www.hse.gov.uk/pubns/guidance/sr11.pdf

A guide to the Health & Safety of Hair Salon products is available from Hair product manufacturers or the Hair & Beauty Suppliers Association. www.hbsa.uk.com

Article courtesy of Aviva plc.