The print shop before the inspector calls
You work in a small digital print shop with seven staff, including a 17-year-old apprentice who started last month. During a walk-round you note four things. The guillotine guard works, but the key has been left in the switch, so anyone can start the blade. Cleaning solvent is decanted into an unlabelled squash bottle and kept under the sink next to the staff mugs. A four-way extension lead trails across the walkway between the laminator and the paper store. The only risk assessment on file is dated five years ago, when the shop had three machines instead of six. The manager says the solvent "has always been fine" and that the apprentice is "careful anyway". The local authority environmental health officer is due in six weeks and has asked to see your risk assessments and COSHH paperwork.
1. Using the solvent and the guillotine, explain the difference between a hazard and a risk, and why the apprentice's risk may not be the same as yours.
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A hazard is the thing with the potential to cause harm: the solvent (harmful by inhalation and skin contact) and the guillotine blade (harm to hands, fingers, eyes).
Risk is the chance, high or low, that someone will be harmed, combined with how serious the harm would be. The same two hazards carry different risk for different people because risk depends on exposure and competence:
- The solvent in a drinks bottle is a far higher risk than solvent in a labelled, lidded container, because the mistake people actually make - swallowing it - becomes possible.
- The apprentice is new, has less experience of reading a situation, may not challenge an instruction, and is likely to be given the repetitive cutting work, so exposure is higher.
Conclusion: you cannot rank hazards without asking who is exposed, how often and how badly they could be hurt. That is exactly what the risk assessment must record.
2. Rank the four findings by risk and set out which control you would put in first, explaining your choice in terms of the hierarchy of control.
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A defensible ranking, with reasoning:
- Solvent in an unlabelled drinks bottle - highest, because the harm (poisoning) is severe and the container invites the exact mistake that causes it. Control: eliminate the need to decant where possible (buy ready-to-use, trigger-spray containers), or substitute a less hazardous product. If decanting is unavoidable, use dedicated labelled containers with hazard symbols and store them away from food and drink, plus COSHH assessment and information for staff.
- Key left in the guillotine - very high severity, and the interlock is defeated at a stroke. Control: engineering/administrative - key held by an authorised, trained operator only, guard interlock tested and recorded.
- Extension lead across the walkway - moderate; trip and electrical risk. Control: relocate socket outlets or use cable routing, not a mat over the cable if people still step on it.
- Out-of-date risk assessment - not itself a hazard, but it invalidates the control of everything above. Fix it as part of the same action plan.
The hierarchy puts elimination and substitution first because they remove the hazard from the person rather than relying on behaviour. PPE and "be careful" come last, which is exactly why the manager's reassurance is not a control.
3. The manager proposes to deal with the paperwork by copying the old assessment, changing the date, and adding a line telling staff to wear gloves. Explain what is wrong with this and what a suitable and sufficient assessment would contain.
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Copying and re-dating produces a document, not a control. The shop now runs six machines, so the hazards have changed (more dust, more noise, different electrical loads, more movement around the floor). Telling staff to wear gloves after the fact inverts the hierarchy: gloves do not stop solvent vapour being breathed in, do not stop a blade, and do not stop a person drinking from the wrong bottle.
A suitable and sufficient assessment would: identify the hazards machine by machine and chemical by chemical; identify who might be harmed and how, naming the apprentice and any pregnant or vulnerable staff; evaluate the risks and set out the precautions in hierarchy order; be recorded and brought to the attention of the people doing the work; and carry a review date and named owner. It should be reviewed whenever the process, equipment, substances or people change - and reviewed after any incident. The COSHH part needs safety data sheets, exposure routes and any health surveillance or exposure monitoring required. The inspector will look for evidence that staff know the controls, not just that a folder exists.