Welding Fumes and the COSHH Regulations

The principal regulations governing exposure to welding fumes are the Control of Substances Hazardous to Health Regulations 2002, commonly known as COSHH.

Under COSHH, employers must prevent exposure to hazardous substances where reasonably practicable. Where prevention is not reasonably practicable, exposure must be adequately controlled.

These requirements apply to specialist welders and employees who only weld occasionally. Suitable controls are required regardless of how short the welding task may be.

Completing a COSHH Risk Assessment for Welding

Before welding work begins, the employer must complete a suitable and sufficient COSHH risk assessment. This should identify:

• The welding processes being used
• The metals, coatings and consumables involved
• The fumes, gases and other hazardous substances that may be produced
• Who may be exposed, including people working nearby
• The frequency and duration of the work
• Whether the welding will take place indoors, outdoors or in a confined space
• The control measures required to prevent or adequately control exposure

The assessment must consider employees and other people who could be affected by the work, including contractors, visitors and members of the public.

All Welding Fumes Must Be Controlled

The Health and Safety Executive states that all welding fumes can cause lung cancer. This includes fumes produced when welding mild steel.

Employers must ensure that suitable controls are provided for every welding activity. The need for controls applies regardless of:

• The welding process used
• The type of metal being welded
• Whether the welding takes place indoors or outdoors
• How frequently welding is undertaken
• How long the task takes

No welding activity should proceed without suitable exposure controls.

Employers’ Legal Duties for Welding-Fume Control

Employers must select effective control measures based on the findings of the risk assessment. Their duties may include the following.

Preventing or Reducing Fume Production

Where reasonably practicable, employers should consider using an alternative joining technique or a welding process that produces less fume.

Providing Local Exhaust Ventilation

For indoor welding, suitable engineering controls will normally include local exhaust ventilation (LEV). LEV should capture fumes close to the point at which they are produced and prevent them from entering workers’ breathing zones.

Providing Suitable Respiratory Protection

Where LEV does not adequately control exposure, or where its use is not reasonably practicable, the employer must provide suitable respiratory protective equipment (RPE).

RPE must be adequate for the hazard, suitable for the wearer and compatible with other personal protective equipment. Tight-fitting masks must be face-fit tested, and workers must be clean-shaven wherever the mask seals against the face.

Providing Adequate General Ventilation

Employers must maintain adequate general ventilation to help prevent fumes from accumulating. However, general ventilation alone is not normally sufficient to control indoor welding fumes.

Protecting People Working Nearby

Control measures must protect the welder and anyone else who may be exposed. Employers may need to restrict access, separate the welding area or introduce other controls to prevent fumes from spreading.

Maintaining and Testing Welding-Fume Controls

Employers must keep exposure-control equipment in efficient working order, good repair and a clean condition. This includes:

• Checking extraction equipment before use
• Inspecting hoods, hoses, ducts and filters
• Repairing defects promptly
• Cleaning or replacing filters when required
• Inspecting RPE before use
• Maintaining reusable RPE in accordance with the manufacturer’s instructions

Thorough Examination and Testing of LEV

LEV systems used to control welding fumes must be thoroughly examined and tested by a competent person at least once every 14 months. More frequent examinations may be required where the system could deteriorate more quickly.

Records of LEV thorough examinations and tests must normally be retained for at least five years. Any critical defect should be addressed immediately.

Information, Instruction and Training

Employers must provide workers who may be exposed to welding fumes with suitable information, instruction and training. This should cover:

• The health risks associated with welding fumes
• The findings of the COSHH risk assessment
• The control measures that must be used
• Correct positioning and use of LEV
• Correct selection, fitting and use of RPE
• Pre-use checks and defect-reporting procedures
• Relevant symptoms and how to report them
• Emergency arrangements and safe systems of work

Employers must also provide appropriate supervision to ensure the controls are used correctly.

Monitoring Exposure and Reviewing Controls

Workplace exposure monitoring may be required where the risk assessment shows that it is necessary to demonstrate adequate control or protect workers’ health.

Employers should regularly review the effectiveness of the controls. The COSHH assessment must be reviewed if there is reason to believe that it is no longer valid or if there has been a significant change to the work.

A review may be necessary following:

• A change in the welding process or materials
• The introduction of new equipment
• A failure or defect in an exposure-control system
• Exposure-monitoring results indicating inadequate control
• A worker reporting relevant symptoms
• New information about the health risks

Employees’ Legal Responsibilities

Employees must take reasonable care of their own health and safety and that of other people who may be affected by their actions. They must also co-operate with their employer’s health and safety arrangements.

Workers must:

• Follow the employer’s safe systems of work
• Use LEV and other control equipment correctly
• Position extraction equipment close enough to capture the fumes
• Wear RPE and other PPE when required
• Complete the necessary checks before using the equipment
• Report damaged, defective or ineffective control equipment
• Attend required training and health-surveillance appointments
• Report relevant symptoms or unsafe working conditions promptly

Employees must not intentionally misuse or interfere with equipment provided for health and safety purposes.

Health Surveillance for Welders

Health surveillance is a system of ongoing health checks used to detect early signs of work-related ill health and assess whether exposure controls are effective.

Health surveillance is required where the COSHH risk assessment identifies that:

• A disease or adverse health effect is associated with the exposure
• It is possible to detect the condition or an early change
• There is a reasonable likelihood that the condition could develop under the particular working conditions

Respiratory Health Surveillance

Respiratory health surveillance should normally be provided when stainless steel is welded and the fumes contain a known cause of occupational asthma, such as chromium, unless the risk assessment shows that asthma is not reasonably likely to develop.

An asthma health-surveillance programme may include:

• A baseline respiratory questionnaire
• Baseline spirometry or lung-function testing
• Further questionnaires during the worker’s early period of exposure
• Annual respiratory questionnaires and spirometry
• Referral to a competent occupational-health professional where necessary

Health surveillance does not replace effective exposure controls. Employers must interpret the results and take action where signs of work-related ill health or inadequate control are identified.

Reporting Occupational Disease

Some diagnosed occupational diseases may be reportable under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR).

Where an employer receives a written diagnosis from a doctor confirming a reportable disease linked to workplace exposure, the employer should determine whether a RIDDOR report is required.

Key Legal Requirements for Welding Fumes

• Complete a suitable and sufficient COSHH risk assessment.
• Prevent exposure where reasonably practicable.
• Where prevention is not practicable, adequately control exposure.
• Provide effective engineering controls, normally LEV, for indoor welding.
• Provide suitable RPE where engineering controls are insufficient or impracticable.
• Protect welders and everyone else who may be exposed.
• Maintain, examine and test exposure-control equipment.
• Thoroughly examine and test LEV at least every 14 months.
• Provide suitable information, instruction, training and supervision.
• Provide risk-based health surveillance where appropriate.
• Review the assessment and controls whenever circumstances change.