Phoenix Journal · LEV & Air Quality
A small engineering firm can carry the same chemical risks as a large one, minus the safety department. Welding fume, coolant mist, solvents and grinding dust all sit on the shop floor, and the law does not scale its expectations to the size of the payroll. The good news is that managing them well is mostly method, not money.
The Control of Substances Hazardous to Health Regulations apply to every employer that uses, makes or releases substances that can harm health, regardless of size. In a small engineering firm that means a surprisingly long list hiding in plain sight: welding fume from the bench, oil mist thrown off by machining coolant, solvents and degreasers in the wash tank, two-pack paints carrying isocyanates, and the fine dust from grinding, cutting and linishing. Each is a substance hazardous to health, and each needs to be assessed and controlled.
Where a small firm often goes wrong is treating a folder of safety data sheets as if it were the assessment. It is not. Data sheets are raw material; the COSHH assessment is the step where you work out who is exposed to what, by which route, at what level, and what controls are actually needed. If you employ five or more people that assessment must be written down, and even below that the HSE strongly advises keeping a record, because an assessment you cannot show is an assessment an inspector will treat as absent.
The sector even has its own HSE guidance, HSG129 on health and safety in engineering workshops, which is a useful map of where the risks cluster. And the enforcement is real: engineering firms have been fined six-figure sums over uncontrolled isocyanate and dust exposure, the kind of case that usually starts with an assessment that was never truly done.
Control in order
The controls have an order, and it is not the order most workshops reach for. First ask whether the substance can be eliminated or substituted for something safer, a water-based degreaser instead of a solvent, a less hazardous consumable. Next comes enclosure and, most importantly for engineering, local exhaust ventilation to capture fume, mist and dust at source before it reaches anyone's breathing zone. Safe systems of work come next, and only then, as the last line, respiratory protective equipment. Starting at PPE and working backwards is the classic small-firm error, and it leaves everyone relying on a mask instead of clean air.
Where LEV is the control, the law attaches duties to it. It must be maintained in effective working order and given a thorough examination and test at least every fourteen months, with the records kept for five years. An extraction system that exists but has never been tested is one of the easiest findings an inspector can make, and it is common precisely in smaller firms where nobody owns the job.
A live substance register helps hold it all together: a simple inventory of every hazardous substance on site, linked to its data sheet and assessment, updated before anything new is brought in. It turns COSHH from an annual panic into a running record that is always ready to show.
Do the assessment properly
Everything downstream depends on the assessment being real rather than a form filled in to have one. It has to look at the actual tasks, the way people really work, and the routes by which a substance gets into the body, since a respirator that guards the lungs does nothing about a solvent absorbed through the skin. Getting this right is a discipline in itself, and it is worth following how COSHH assessments should actually be done rather than copying a generic template that never touches your real processes. A good assessment names the control for each task and sets the review date; a poor one just lists chemicals and reassures nobody who matters.
The signature hazard
Of everything on an engineering floor, welding fume is the exposure most likely to be underestimated, because it is routine, it is quick, and much of it is invisible. Yet it is now treated as capable of causing cancer whatever the metal, so it must be controlled with extraction wherever welding happens, indoors or out. Learning to manage welding fume beyond just buying extraction is central to a small firm's COSHH duties: buying a fume arm is only the start, and it protects nobody if it is badly positioned, switched off or never tested. Wrap the fume, mist, solvent and dust controls into training, health surveillance where it is needed, and honest records, and a small firm meets the same standard as a large one without a large one's budget.
Questions
Yes. COSHH applies to every employer using or producing hazardous substances, whatever the size. The duties to assess and control exposure are the same for a two-person workshop as for a factory. Firms with five or more employees must also record the assessment in writing, and the HSE recommends smaller firms keep a record too.
Commonly welding fume, oil or coolant mist from machining, solvents and degreasers, two-pack paints containing isocyanates, and dust from grinding, cutting and linishing, which can include respirable crystalline silica. Each needs assessing and controlling, usually with local exhaust ventilation as the main engineering control.
No. Safety data sheets are useful information, but collecting them does not meet the duty to assess. A COSHH assessment uses that information to work out who is exposed, by what route, at what level, and what controls are needed for the actual tasks, then records the controls and a review date.
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