Biological Monitoring & COSHH
Biological Monitoring · Biological Monitoring overview
The Control of Substances Hazardous to Health Regulations 2002 (COSHH) do not name 'biological monitoring' as a separate regulation, but regulations 7, 10 and 11 collectively make it the default verification method for substances with skin notation, low WELs or established HSE BMGVs.
Regulation 7 — preventing or controlling exposure
Regulation 7 requires exposure to be prevented or, where not reasonably practicable, adequately controlled. Adequacy must be demonstrable — biological monitoring is the strongest available demonstration for substances that absorb through skin or where airborne exposure measurement alone is inconclusive.
Regulation 10 — monitoring exposure at the workplace
Regulation 10 mandates exposure monitoring where it is needed to ensure the maintenance of adequate control or where it is specified in Schedule 5. Biological monitoring is one form of exposure monitoring and is the appropriate choice when uptake routes other than inhalation are material.
Regulation 11 — health surveillance
Regulation 11 health surveillance is distinct from biological monitoring but the two are commonly run together. Biological monitoring of urinary lead, for example, is statutory under CLAW alongside biological-effect monitoring (zinc protoporphyrin) and clinical surveillance.
HSE BMGVs
HSE has published BMGVs for substances including 4,4'-MDA (for MDI/MDA), TDA (for TDI), urinary chromium, urinary cobalt, butan-2-one, cyclohexanone, mercury, n-hexane and others. BMGVs are advisory but treated by enforcement as the benchmark against which control adequacy is judged.
Frequently asked questions
Is COSHH biological monitoring mandatory?
COSHH does not explicitly name it as mandatory, but for substances with skin notation, low WELs or HSE BMGVs it is the recognised method of demonstrating adequate control under regulation 7.
What is the difference between a WEL and a BMGV?
A WEL is a limit on airborne concentration; a BMGV is a guidance value for the substance or metabolite measured inside the worker. WELs control source emission; BMGVs evidence absorbed dose.
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