• measurement
• workplace

I write in response to the article by Hans Kromhout,¹ which sets out the case for exposure monitoring and proposes robust strategies for collecting data. He acknowledges that exposure monitoring may be expensive, but justifies it on the grounds that it is needed to ensure worker protection and data can be used for multiple purposes (hazard evaluation, control, and epidemiology). All this ignores the variety of competences and numbers of firms who use chemicals in the workplace.

We agree that good quality exposure data are extremely valuable for assessing the effectiveness of control measures, studies on health effects related to use of specific substances, and for long term epidemiological studies. Now that workers do not normally remain in one job all their working life and may be exposed to many chemicals in different industries, the lack of well validated exposure measurements is a concern. It will limit our ability in the future to carry out meaningful epidemiological studies.

In the UK we estimate that over 1.3 million firms are using chemicals. It is not realistic to suggest that all these firms should be carrying out the type of sampling regimes the article suggests. The costs would be astronomical and there is no capacity to collect, analyse, and interpret all the samples that would be generated. Recognising this and that small firms needed help to apply the risk assessment requirements of the Control of Substances Hazardous to Health (COSHH) Regulations, led HSE, in collaboration with industry and trade unions, to develop the COSHH Essentials.

COSHH Essentials is not intended to replace the …