If your team handles cleaning products, chemicals, dust or fumes, COSHH isn’t optional. It’s a legal duty – and one that’s easy to get wrong if it’s treated as a box-ticking exercise.

Let’s take a look at who COSHH applies to, what a proper assessment includes, and the practical steps you can take to reduce exposure.

Who COSHH actually applies to

The Control of Substances Hazardous to Health (COSHH) Regulations 2002 apply to any workplace where employees face exposure to substances that could harm their health. That’s a wider list than most managers expect.

It covers obvious cases like cleaning chemicals, solvents and lab reagents. But it also covers:

• Dust and fumes. Including wood dust, flour dust and welding fumes.
• Biological agents. Bacteria and mould encountered in care settings or waste handling.
• Substances produced by a work process. Fumes from soldering or exhaust from vehicles maintained indoors.

If your business operates in care, cleaning, maintenance, manufacturing or a lab environment, you almost certainly have COSHH duties. The regulations require employers to protect employees who may be exposed to substances hazardous to health through their work, not just those handling substances directly.

What a COSHH risk assessment should cover

A proper COSHH assessment goes further than reading a safety data sheet. To meet your legal duty, it needs to cover:

• What the substance is and how it’s used. Include its hazardous properties, the form it takes (such as liquid, dust or vapour), the amount involved and relevant information from the supplier, including the safety data sheet.
• Who’s exposed and how. Think about the level, type and duration of exposure, including routes such as inhalation, skin contact and accidental ingestion. Consider everyone who could be affected, as well as higher-risk activities such as maintenance.
• The level of risk. Weigh up the hazards against actual exposure, taking account of any relevant workplace exposure limits and the combined effects of substances where necessary.
• The control measures in place. Ventilation, personal protective equipment (PPE), safe storage and handling procedures should all be recorded, along with how they’re checked and maintained.
• Emergency procedures. Spillage response, first aid steps and disposal methods need to be clear and accessible to anyone who might need them.

Occupational lung disease reminds us why this matters. The Health and Safety Executive (HSE) estimates that around 11,000 lung disease deaths each year are linked to past exposure at work. Many health effects caused by hazardous substances develop gradually rather than following a single incident, so assessments need to consider long-term as well as immediate risks.

Assessments must be reviewed regularly, and straight away if there’s reason to think they’re no longer valid, there’s been a significant change in the work or exposure-monitoring results show that a review is needed.

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The practical steps that reduce exposure

Assessments only work if they change what happens on the ground. These are the steps that make the biggest difference day to day:

• Prevent exposure where you can. Start by asking whether you can avoid using the hazardous substance or process altogether. If not, consider whether a safer substance or process could do the same job before relying on measures such as ventilation or PPE.
• Control dust, fumes and vapours at source. Where appropriate, local exhaust ventilation (LEV) can capture contaminants before workers breathe them in. The right control will depend on the substance, process and level of exposure.
• Get PPE right. Use the correct glove material and, where respiratory protective equipment (RPE) is required, the right type and filter. Staff also need to know how to use it correctly, including carrying out fit checks where appropriate. The wrong equipment can create a false sense of protection.
• Store substances properly. Keep hazardous substances in suitable, clearly labelled containers, following the manufacturer’s instructions and your COSHH assessment. Store incompatible substances safely and restrict access where necessary.
• Monitor exposure and health where required. Depending on the substance and circumstances, exposure monitoring or health surveillance may be legally required. These measures help employers check whether controls are working and identify potential harm early.

Training frontline staff, not just supervisors

COSHH compliance often gets treated as a management responsibility, with training aimed at supervisors and health and safety leads. But that leaves a real gap. Frontline staff may be among those most exposed to hazardous substances, and they need to understand the risks and the control measures they’re expected to follow.

Effective COSHH training for employees should cover:

• Recognising hazards. Staff should understand relevant hazard labels and symbols, the risks associated with the substances they work with and the precautions identified in your COSHH assessment.
• Correct use of control measures. Not just wearing PPE, but understanding why it matters and what happens if it’s ignored.
• What to do if something goes wrong. Spillages, accidental exposure and near misses should all have a clear, known response.
• Reporting concerns. Staff need to feel confident flagging a substance, process or symptom that doesn’t seem right, and know it’ll be taken seriously.

Training shouldn’t be treated as a one-off. Products and processes change, and new starters need the same grounding as everyone else. Review and update information, instruction and training when changes affect the risks or precautions staff need to understand.

Keeping compliance audit-ready

Compliance isn’t just about doing the right thing – it’s about being able to show you’ve done it. If HSE inspects your workplace, or an incident triggers a review, you’ll need to demonstrate that assessments, training and controls are current and consistently applied.

That means:

• Dated, accessible records. Assessments and training completions should be easy to locate.
• Clear ownership. Someone should be responsible for keeping COSHH assessments current and making sure they’re reviewed regularly and when circumstances change.
• Evidence of training, not just intention. Keep records showing who has received relevant COSHH information, instruction and training, and when. Online course certificates can form part of that evidence alongside workplace-specific training and instruction.

If you’re managing training across a growing team, spreadsheets can quickly become difficult to keep on top of. An easy-to-use LMS can flag renewals automatically and give you training records in a couple of clicks, making it much easier to see who’s completed their training and where the gaps are.

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Please note: This article provides general information about COSHH compliance and isn’t intended as legal advice. Organisations should seek appropriate advice about how the requirements apply to their individual circumstances.

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