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Water a hazardous substance! Why doesn’t it have a GHS label?

Posted by Keith Paxman - Managing Director

When we are engaged as health and safety consultants it is typical that clients will have clocked that the Control of Substances Hazardous to Health Regulations (COSHH) is an issue that needs to be managed. Generally, the evidence we find of COSHH controls is a folder with all the datasheets for the chemicals that have Global Harmonisation System (GHS) labels that are used or are present on the premises or in processes. This is where our work begins in guiding clients to consider all the other substances that might exist, or which are created as part of their processes.

Examples of the hazardous substance include:
• Fumes created as part of a burning process.
• Vapours that arise from the use of chemicals or processes
• Particles and dust created from cutting, grinding or abrading an article which in its normal state would not be a health hazard e.g. concrete, wood and metals.
• Biological agents associated with humans, animals, bacteria and viruses
• Plants and fawner that can be sensitisers

Water should not normally be hazardous to health however it can be if contaminated with bacteria which is then able to be inhaled and cause harm to the recipient.

This was first recognised when an air conditioning unit caused multiple deaths at a Legionnaires convention at a hotel in the United States. The cause of the deaths was traced back to a proliferation of a naturally occurring bacteria that is present in water. In this case, the bacteria were released into the conventions meeting rooms and lobbies environment via the Hotels air conditioning plant and system. The system was capable of creating an aerosol that suspended the bacteria in a state that allowed them to be inhaled by the delegates at the convention. The bacteria were subsequently named collectively as Legionella.

Since the discovery, there have been numerous failings, incidents and outbreaks which have been the focus of enforcement by the Health and Safety Executive (HSE). Recent cases include the security business G4S which was fined £1.8m for failing to have an adequate Legionella management system and BUPA the care home business who failed to control hot and cold water supplies and as result was fined £3m following a death at one of their care homes. The action and tragic consequences could, of course, have been prevented if the correct management controls were in place and those responsible had better understood what was needed to control water hygiene standards in workplaces, premises and facilities plant and equipment.

Water therefore not only has to be potable to meet the requirements of the Workplace (Health, Safety and Welfare) Regulations but must also form part of an employers and landlords COSHH assessments and be controlled as part of the HSE Approved Code of Practice and Guidance L8 and Guidance note HSG 274.

To help employers and duty holders better understand Legionella Praxis42 has produced a short Institution of Occupational Safety and Health (IOSH) approved awareness course which is available here

The course aims to enable duty holders and those responsible for implementing management controls to better understand the hazards, risks and compliance associated with water systems, plant and facilities. By the end of the course you will:

  • Appreciate what Legionella is and why there are potential health risks to workers and others
  • Appreciate how Legionella can affect health
  • Recognise the main ways Legionella can become airborne
  • Recognise the common control measures used to reduce the risk of Legionella including risk assessments
  • Appreciate the legal responsibilities of Dutyholders, Responsible Persons and your role in Legionella management and compliance
  • Be aware of the consequences of failing to comply with the relevant legislation and guidance

For more information on all of our Courses please take a look at our website or speak to one of our Account Managers today on 0870 446 4201


Keith Paxman - Managing Director

Keith has led Praxis42 at MD since it was formed in 2001. Prior to this Keith headed up Health and Safety, Fire and occupational Health at Cable and Wireless. Keith oversees all areas of the business as well as working with our clients to enable them to establish targets, objectives and metrics that help them meet their compliance and governance obligations.

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