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Whoopsie - Made a COSHH Trainer walk out.

Posted: Mon Nov 26, 2018 6:25 pm
by stephen1974
I was about to say please tell me I have not made a fool of myself, but that ship has sailed in the way that I just handled a situation. It's possible I could even get fired over this/ So please tell me I was at least correct in what I was saying.

We just arranged for someone to comedown from a company that provides our cleaning chemicals to do COSHH Training.

The first thing I noticed was that the training material was old and had the old orange and black coshh symbols on them. its been 9 years, and whilst I have no issue with people knowing them, the new symbols should be being taught. None of the training material had any of the new sheets.

She began the training by saying it is a legal requirement to carry out COSHH training every year. (And effectively get a certificate to say they have done it) My understanding is we legally have to train people on the safe use of chemicals, review our assessments on a regular basis or in response to an incident and retrain if necessary and that we should do regular to do refreseher training, but I cant find anything that specifically says it is the law to train people on COSHH every year. It may just have been the way she worded it, but she made it sound very much like it was a specific regulation.

If anyone can point me in that direction or clear things up.

Then she asked what a COSHH sheet was and someon reponded saying its a sheet that tells you how to use the chemicals. Now, depending on how you inerpret that, yes it does, but generaly only so far as in how to handle the chemicals, not how to apply them to a task, though some people may include those instructions. She flat out said he was wrong and then proceeded to hold up a Material Safet Data Sheet and say this is your COSHH Sheet.

To me, that is wrong. Thats is a Material Data Safety Sheet and that is different to your COSHH Assessment sheet. MSDS is designed, primarily, for industrial manufacture storage and distribution of a product, and the COSHH Assessment is where you take the relevant information for your business from the MSDS. Much of the information is a straight transfer, but some is not and requires the assessor to have an understanding of how the chemical is used in your environment. Not only that, but when it comes to training staff, and MSDS has way to much information that they wont comprehend and will confuse them.

This then lead to the argument as I tried to point this out. Unfortunately her responsse was an absolutely flat no the 'COSHH SHEET' (the msds) is everything and you follow it to the letter. End of. I tried to point that things are different for dealing with a product its it neat form in vast quantities than it is for using a diluted version in a spray bottle and she went ballistic and walked out.

Now, I should have approached her afterwards or pulled her aside instead of doing this in front of the staff (though I didnt have a chance once a simple question went from simple to ballistic in no seconds flat) and the staff all believe she as the trainer is right and therefore i'm wrong. Thats my bad an I expect that.

But is this how you guys see COSHH or AM i wrong?

Re: Whoopsie - Made a COSHH Trainer walk out.

Posted: Mon Nov 26, 2018 7:46 pm
by bernicarey
Wow,. that's quite a long rant.... and wholly justified.

Ruddy incompetent trainers, out to make money and not provide a service.
We just arranged for someone to comedown from a company that provides our cleaning chemicals to do COSHH Training
Are they trainers? What do they know? Not much by the sounds of it. :evil:
The first thing I noticed was that the training material was old and had the old orange and black coshh symbols on them.
Really! :shock:
She began the training by saying it is a legal requirement to carry out COSHH training every year.
There is no legal time limit on any training requirements, other than First Aid at Work.
All others subjects have HSE recommendations etc, but training has to be appropriate to the substances and their relevant precautions.


As to the Biggie..... She's a complete and utter incompetent idiot!

One small point to clarify, there is no such thing as a 'COSHH Sheet'. There is a MSDS/SDS and there is a COSHH (risk) Assessment, but there is no COSHH Sheet.

So if she's teaching 'COSHH Sheets' that's another Black Mark against her.

The MSDS/SDS is the information about the Hazardous properties of the substance. The COSHH Assessment is how those properties affect your use of the substance.
So you are totally correct. ./thumbsup..

Good riddance to her, she's a danger to your employees and your company.

Check out http://www.hse.gov.uk/coshh/further/faq.htm

There is a Question that asks 'We have the SDS, do we still need a COSHH Assessment'.

The answer is:
YES. A good safety data sheet (SDS) does not substitute for carrying out and recording a COSHH risk assessment. Gathering SDSs is only the first stage in the assessment process. The SDS will provide information on the hazardous properties of the substances you are using, any health effects associated with its use, how likely it is to get into the air or onto the skin, and what risk reduction measures you should use to control exposure to an acceptable level. However, it will not be specific to your workplace and cannot take into account the particular environment you work in.

I get sick and tied of idiots thinking the MSDS is their COSHH Assessment. You are totally correct.

Don't pay them since they don't know what they are doing and I would be considering reporting this company to the HSE/Local Authority to have them paid a visit, purely because they could have been spreading these untruths to all their customers for years and potentially putting peoples health/lives at risk; .....but then I do have a low tolerance for incompetence in people where it matters.. ;)

Re: Whoopsie - Made a COSHH Trainer walk out.

Posted: Mon Nov 26, 2018 8:32 pm
by stephen1974
Sadly it is not good riddance to her. The Directors are getting her back in to train the staff on the agreement that I do not attend the training.
The 'Training' is provided free by the company who supply our chemicals. My initial assumption on the yearly training claim was a business tout but if the training is free its not really the case.

I'm glad i'm not wrong on this, but I feel neither the directors or the staff are going to see it in any other way than she is the official trainer, therefore she is right and I am wrong. I'm not sure I'll have a job come Wednesday as a result of this, but if I do, i'm not going to press the issue. I'll let her do her thing, give them their shiny certificate and then do my own coshh assessments and work procedures for the staff to follow.

Really? was my reaction to the training material as well. She made a comment about not writing on them as they re-use them and some are x amount of years old. (She may have said 11 years but i cant recall for certain) Always nice to know what you are being trained on is up to date. I believe the new symbols came in in 2009 and the old ones were phased out in 2015? Interestingly, I see amazon are selling a CHIP 2009 poster on their website. Again, I believe CHIP was revoked in 2015 as well and that we should be using CLP.

Re: Whoopsie - Made a COSHH Trainer walk out.

Posted: Tue Nov 27, 2018 8:40 am
by bernicarey
:twisted: :twisted:

Well I'd be reminding the Directors that they are responsible for Due Diligence in engaging with any aspect of H&S, so if they engage with a trainer who is giving incorrect training, their culpability is getting high. To do so after you have raised the matter, it's going off the top of the scale.

Remind them that the Sentencing Guidelines were changed a couple of year ago and if anyone is injured as a result of this inappropriate training, they could be facing personal Jail time....
If you haven't got a job Wednesday, then it's definitely time to call in the HSE!


http://www.hse.gov.uk/chemical-classifi ... ations.htm

http://www.hse.gov.uk/chemical-classifi ... lation.htm

Re: Whoopsie - Made a COSHH Trainer walk out.

Posted: Tue Nov 27, 2018 9:36 am
by witsd
Reminder:

Get everything in writing and BCC your personal email account in.

Re: Whoopsie - Made a COSHH Trainer walk out.

Posted: Tue Nov 27, 2018 4:37 pm
by Rowebin
You were correct on every point and have a good reason to be annoyed.

I agree with Bernicarey about the directors being responsible for doing their due diligence. At least you know you can hold the moral high ground I guess!

Re: Whoopsie - Made a COSHH Trainer walk out.

Posted: Thu Nov 29, 2018 12:30 pm
by ssmith65
This is what scares me doing the job that most of us do. I am a facilities manager and have my Nebosh cert and I believe I am able to raise issues I see in my corrent workplace and they have always been quite risk adverse so when I try and instigate new stuff or something comes to light that needs addressing they are often open to finding ways we can mitigate any risks. I would not like to be in a positon where they wouldnt follow any of my recommendations becuase in a way it questions your protessional integrity, also I wouldnt want to work for somewhere like that either, i mean I make the assumption thats why you have the job in the first place.

I would collect everything in a report to include all of the items mentioned in the replies above and present it to your bosses. The old adage that if something is free its probably rubbish definalty applies here. Let us all know how you are getting on Steve.

Re: Whoopsie - Made a COSHH Trainer walk out.

Posted: Thu Nov 29, 2018 2:23 pm
by stephen1974
The more I look in to things the more and more i'm finding out what is wrong. There is a ton of work to do here. I sure can pick em. Still, if everything was in place, life would be boring. Less stressful, but boring.

Re: Whoopsie - Made a COSHH Trainer walk out.

Posted: Thu Nov 29, 2018 3:08 pm
by witsd
I quite enjoy boring.

Or I would if I could remember what it looked like.

Re: Whoopsie - Made a COSHH Trainer walk out.

Posted: Sun Dec 02, 2018 2:52 am
by joaorosa80
I believe that I will not be saying anything new...to any of us...
But COSHH assessment, is nothing else, that the art. 7, n 3-5 of the COSHH Regulation. Simple

Re: Whoopsie - Made a COSHH Trainer walk out.

Posted: Tue Dec 04, 2018 10:02 pm
by NGC
bernicarey wrote: Mon Nov 26, 2018 7:46 pm
I get sick and tied of idiots thinking the MSDS is their COSHH Assessment. You are totally correct.
Here here. I have lost count how many times I have had that exact conversation with people... :evil:

..."but we've always done it that way" grrrr :lol:

Re: Whoopsie - Made a COSHH Trainer walk out.

Posted: Thu Dec 06, 2018 8:40 am
by PaulDonaldson
Sorry for joining this party late, I remember having a conversation with an HSE inspector who quite clearly stated that if you had the old symbols on your COSHH assessment(not the MSDS!!!) it would very likely attract an improvement notice. That being the case your trainer needs to be re-educated. You were perfectly correct in your actions.