COSHH Regulations: A Practical Guide for Employers

Every year, thousands of UK workers develop serious health conditions — from dermatitis and asthma to cancer — as a result of exposure to hazardous substances at work. The Control of Substances Hazardous to Health Regulations 2002 (COSHH) exist to prevent this harm, and compliance is a legal obligation for virtually every employer in the country.

Whether you run a restaurant with industrial cleaning chemicals, a construction site with cement dust, or a hair salon with colouring products, COSHH almost certainly applies to your business. This guide provides a practical, step-by-step approach to getting it right.

What Is COSHH?

COSHH is the law that requires employers to control substances hazardous to health. It applies to a wide range of substances including:

• Chemicals — cleaning products, solvents, paints, adhesives, pesticides
• Fumes — welding fume, exhaust fume, soldering fume
• Dusts — wood dust, flour dust, silica dust, cement dust
• Biological agents — bacteria, viruses, fungi (including legionella)
• Nanotechnology — engineered nanoparticles
• Any substance with a Workplace Exposure Limit (WEL)

COSHH does not cover lead (which has its own regulations), asbestos (also separate regulations) or radioactive substances.

Who Must Comply?

If you are an employer and your workers could be exposed to hazardous substances during their work, you must comply with COSHH. This includes:

• Direct employees
• Temporary and agency workers
• Contractors working on your premises
• Anyone else who might be affected by the work (visitors, members of the public)

Self-employed people must also protect themselves and others from hazardous substances.

The 8-Step COSHH Assessment Process

The HSE recommends a systematic 8-step approach to COSHH assessment. Here is how to apply each step in practice.

Step 1: Identify the Hazardous Substances

Start by creating a comprehensive inventory of every hazardous substance used, stored or generated in your workplace. This includes:

• Products you buy (check labels for hazard symbols)
• Substances created by your processes (dust, fumes, vapours)
• Biological agents (mould, bacteria in cooling systems)
• Substances brought in by contractors

Practical tip: Walk through every area of your workplace, every process, every storage area. Check under sinks, in cleaning cupboards, in maintenance stores. Many businesses are surprised by how many hazardous substances they have.

Step 2: Obtain Safety Data Sheets (SDS)

For every chemical product you use, you should have a Safety Data Sheet (formerly MSDS). Suppliers are legally required to provide these. An SDS contains 16 sections of critical information including:

• Section 2: Hazards identification — the GHS classification and hazard statements
• Section 7: Handling and storage — how to use and store the product safely
• Section 8: Exposure controls and PPE — what protection is needed
• Section 11: Toxicological information — health effects of exposure

If you do not have an SDS for a product, request one from the supplier immediately.

Step 3: Assess the Risks

For each hazardous substance, assess:

• Who is exposed and how (inhalation, skin contact, ingestion, eye contact)
• How much exposure occurs (concentration, duration, frequency)
• What controls are already in place
• What the health effects could be (acute and chronic)

Consider routine use, maintenance activities, cleaning and foreseeable emergencies (spills, leaks).

Step 4: Decide on Control Measures

COSHH requires you to follow a hierarchy of control:

1. Eliminate — Can you remove the hazardous substance entirely? Can you use a non-hazardous alternative?
2. Substitute — Can you use a less hazardous substance? (e.g., water-based paint instead of solvent-based)
3. Enclose — Can you enclose the process so exposure cannot occur?
4. Local exhaust ventilation (LEV) — Can you extract fumes, dust or vapour at source?
5. General ventilation — Can improved ventilation reduce exposure levels?
6. Safe systems of work — Can procedures reduce the duration or frequency of exposure?
7. PPE — Personal protective equipment is the last resort, not the first

Important: PPE should only be relied upon when all higher-level controls have been considered and found insufficient. PPE fails if it is not worn, does not fit properly, or is not maintained.

Step 5: Implement the Controls

Put your control measures into practice. This includes:

• Purchasing and installing engineering controls
• Writing safe working procedures
• Procuring appropriate PPE (correctly sized and specified)
• Updating storage arrangements
• Installing safety signage

Step 6: Train and Inform Workers

Every worker who could be exposed to hazardous substances must receive:

• Information about the substances they work with and the risks
• Training on control measures, safe working procedures and PPE use
• Instruction on emergency procedures (spills, first aid, fire)

Training must be refreshed regularly and whenever substances or processes change.

Step 7: Monitor and Review

COSHH assessments are not one-off documents — they must be reviewed regularly and updated when:

• New substances are introduced
• Processes change
• An incident or near-miss occurs
• Health surveillance identifies a problem
• New information about a substance becomes available

As a minimum, review all COSHH assessments annually.

Step 8: Health Surveillance

For certain substances and exposures, health surveillance is a legal requirement. This might include:

• Skin checks for workers exposed to dermatitis-causing substances
• Lung function tests for workers exposed to respiratory sensitisers
• Blood or urine monitoring for certain chemical exposures

Health surveillance must be carried out by a qualified person and records must be kept for at least 40 years.

Understanding GHS Classification

The Globally Harmonised System (GHS) of classification and labelling of chemicals uses standardised hazard symbols (pictograms) that you will see on product labels and SDS. The key pictograms are:

• Skull and crossbones — Acutely toxic substances
• Flame — Flammable substances
• Exclamation mark — Irritants, sensitisers, acute toxicity (lower categories)
• Health hazard — Serious long-term health effects (carcinogens, mutagens, respiratory sensitisers)
• Corrosion — Corrosive to skin, eyes or metals
• Environment — Hazardous to the aquatic environment
• Flame over circle — Oxidising substances
• Gas cylinder — Gases under pressure
• Exploding bomb — Explosive substances

Every hazardous product label must also include hazard statements (H-statements) describing the nature of the hazard and precautionary statements (P-statements) advising on safe handling.

PPE Requirements Under COSHH

When PPE is required, it must be:

• Suitable for the specific hazard — the SDS will specify the type of glove material, respirator filter, or eye protection needed
• CE-marked and conform to the relevant standard
• Correctly sized for each individual worker
• Maintained in good condition and replaced when damaged or expired
• Stored properly when not in use

Common PPE for chemical hazards includes:

• Chemical-resistant gloves (nitrile, neoprene, PVC — the correct type depends on the substance)
• Safety goggles or face shields for splash risks
• Respiratory protection (disposable masks, half-face or full-face respirators with appropriate filters)
• Chemical-resistant aprons or coveralls for body protection

Storage Requirements

Correct storage of hazardous substances is a critical part of COSHH compliance:

• Segregate incompatible substances — acids away from alkalis, oxidisers away from flammables
• Use appropriate containers — original containers or approved chemical storage containers
• Label everything — never transfer chemicals to unlabelled containers
• Secure storage — prevent unauthorised access
• Ventilation — ensure storage areas are adequately ventilated
• Spill containment — use bunded storage for liquids
• Quantity limits — store only what you need for current use

Common COSHH Mistakes

Assuming COSHH only applies to “chemical” businesses — Even offices have cleaning products. Restaurants use industrial degreasers. Schools have science lab chemicals. COSHH applies far more broadly than many employers realise.

Relying solely on PPE — PPE is the last line of defence. If your entire COSHH strategy is “give them gloves,” you are almost certainly not compliant.

Generic assessments — Downloading a template COSHH assessment from the internet and filing it away does not meet your legal obligations. Assessments must be specific to your substances, your processes and your workers.

Outdated assessments — COSHH assessments gathering dust in a filing cabinet are of no value. They must be living documents that are regularly reviewed and updated.

Missing SDS — You cannot assess the risk of a substance if you do not know what is in it. Ensure you have current SDS for every chemical product on your premises.

Not recording the assessment — If you employ 5 or more people, you must record your COSHH assessments in writing (or digitally). For a broader look at risk assessment requirements, see our guide on how to write a risk assessment.

Penalties for COSHH Non-Compliance

COSHH is enforced by the HSE and local authorities. Penalties for non-compliance include:

• Improvement notices — requiring you to take specific actions within a set timeframe
• Prohibition notices — stopping an activity immediately until it is made safe
• Prosecution — with unlimited fines and potential imprisonment for serious breaches
• Civil claims — employees who develop health conditions due to inadequate COSHH controls may bring personal injury claims

Digitise Your COSHH Compliance

Managing COSHH assessments, SDS libraries, training records, review schedules and PPE inventories on paper quickly becomes unmanageable — especially as your business grows or your workforce changes. Digital COSHH management systems can store all your assessments in one place, alert you when reviews are due, track training completion, and provide instant access to SDS from any device.

Learn more about how Assistant Manager can simplify your chemical safety management with our COSHH Assessments feature. For related compliance needs, explore our Risk Assessments and Training & LMS features.