Plastics Manufacturing COSHH Checklist: Air Monitoring and Fume Control

COSHH compliance in plastics manufacturing is an ongoing cycle of assessment, control, monitoring, and review. This checklist is designed for facilities managers and H&S leads to use as a quick reference: bookmark it, come back to it, and use it to spot anything that's slipped.

See our other pages for more information:

• Workplace Exposure Limit (EH40 WELs) Testing
• Indoor Air Quality Monitoring Service
• Industrial Sector Page
• Or get in touch for specific enquiries about LEV testing, advice, etc.

The Legislation You Need to Know

Three documents define what HSE expects from plastics manufacturers on air quality:

• COSHH Regulations 2002 — the primary legal framework for controlling hazardous airborne substances
• EH40/2005 Workplace Exposure Limits — the legally binding list of maximum airborne concentrations for specific substances
• PPIS13: Controlling fume during plastics processing — HSE's sector-specific fume control guidance for moulding, extrusion and similar processes

Your Responsibilities as a Plastics Manufacturer

Under COSHH, legal responsibility sits with you as the employer. You can appoint competent people to help, but you cannot delegate the liability. In brief:

• Prevent exposure first. Eliminate hazardous fumes at source where reasonably practicable — through material substitution, enclosed processes, or process redesign — before relying on controls.

• Control to below WELs. Where fumes can't be eliminated, keep exposure below the relevant Workplace Exposure Limit. For carcinogens, mutagens and respiratory sensitisers such as formaldehyde, exposure should be reduced as low as reasonably practicable.

Maintain your controls and prove they work. Extraction that is switched on but underperforming is not adequate control. Regular testing, monitoring, and documentation are all part of the legal obligation.

Mandatory Tasks Checklist

Legal requirements under COSHH. Non-compliance can result in enforcement notices, prohibition, or prosecution.

COSHH Assessment (Reg. 6)

Risk assessment completed for every substance used or produced, covering fumes from each polymer and additive combination — not just the base resin

Current safety data sheets (SDS) obtained from suppliers for every formulation

All potentially exposed workers identified, including those in adjacent areas

Findings recorded in writing (required for five or more employees)

Assessment reviewed after any material / process change, or incident (recommended at least annually regardless of any changes or incidents)

 

Purging, cleaning, and maintenance activities separately assessed under COSHH

Prevention and Control (Reg. 7)

LEV installed wherever required to achieve adequate control as identified by the COSHH assessment

 

Temperature controls and alarms on all processing equipment verified as functional — overheating is the primary cause of unexpected fume events

For carcinogens and sensitisers, documented evidence that exposure is being driven to ALARP

LEV Maintenance and Testing (Reg. 9)

All LEV systems thoroughly examined and tested at least every 14 months by a competent LEV examiner (may hold BOHS P601 or equivalent certification)

LEV test records retained for a minimum of five years

Defects identified during testing actioned and documented

Daily and monthly LEV checks carried out and recorded per PPIS13

Exposure Monitoring (Reg. 10)

Air monitoring undertaken where necessary to demonstrate adequate control or verify compliance with applicable WELs

Results compared against current EH40 WELs and retained for inspection

Re-monitoring scheduled following any significant change to materials, processes, or controls

Health Surveillance (Reg. 11)

Workers exposed to sensitisers (e.g., formaldehyde) enrolled in a health surveillance programme

Health surveillance records retained for a minimum of 40 years

Training (Reg. 12)

All exposed workers trained on health hazards, controls, and correct procedures for purging and handling alarm conditions

Training records maintained and refreshed when substances or processes change

Recommended Tasks Checklist

Beyond the legal minimum, these are the measures that keep you ahead of problems rather than reacting to them.

Real-time air quality monitoring in place on the production floor, with alerts configured to flag readings approaching WEL thresholds

Filter condition tracked against actual system performance via Smart Filtration Management, rather than fixed calendar intervals

COSHH assessment reviewed by an independent occupational hygienist, with quantified exposure data from WEL testing incorporated

Ventilation validation carried out post-installation and after any significant changes to the facility or production layout

Compliance register maintained with forward-looking due dates for all assessment, monitoring, LEV test, and training renewals

What Does a Plastics Fumes Inspection Achieve?

A periodic independent inspection by a qualified occupational hygienist does things internal checks cannot. It produces quantified air sampling data — the only way to know whether styrene is at 40 ppm or 140 ppm. It catches hazards introduced by new grades, additives, or regrind material that may not be reflected in your current COSHH assessment. And it creates a dated, independent compliance record that carries real weight with HSE and, if needed, in legal proceedings.

Find out more about our WEL exposure testing.

Think Your Air Quality Monitoring Programme Has Gaps?

ARM Environments provides WELs testing, indoor air quality testing, and ongoing monitoring for manufacturing facilities across the UK — with results benchmarked directly against EH40.

Talk to our team to arrange an assessment.