COSHH requires employers to control risks from substances that can harm health. For senior managers, the duty is not simply to hold safety data sheets or file COSHH assessments, but to make sure hazardous substances are identified, exposure is controlled, workers are informed, and controls are reviewed in practice.
What does this means for managers?
COSHH applies where work uses, creates or exposes people to substances hazardous to health. This includes chemicals, biological agents, dusts, fumes, vapours, mists and gases, as well as harmful substances created by work processes.
The management task is to understand where exposure can happen and whether controls are strong enough. That includes substances brought onto site, substances produced by work activities, and exposures affecting employees, contractors, maintenance workers, visitors or others.
A good COSHH system should answer four questions: what substances are hazardous, who may be exposed, how exposure is prevented or reduced, and how the organisation checks that controls continue to work.
Main duties and Requirements
HSE guidance explains that COSHH requires employers to plan, manage and monitor the use of chemicals, micro-organisms and other substances hazardous to health.
Employers must assess the risks from hazardous substances and decide what measures are needed to control exposure. The assessment should consider how people may be exposed, including breathing substances in, skin contact, swallowing, and the frequency and duration of exposure.
Control should start with preventing exposure where possible. This may mean eliminating a substance, using a safer alternative, or changing the process so the substance is no longer used or created. Where exposure cannot be prevented, employers must use adequate control measures to reduce the risk.
If an employer has five or more employees, the COSHH assessment must be recorded. HSE guidance also states that controls must be reviewed to make sure they are working and that the assessment should be kept up to date.
What does this mean in practice?
COSHH should be linked to how work is actually carried out. Managers should not rely only on product labels or safety data sheets. HSE makes clear that some harmful substances are generated by the work itself, such as dust from cutting or sanding, or fumes from welding.
The assessment should look at the substance, the task, the people exposed, the route of exposure, the control measures already in place, and any further action required. It should also identify who is responsible for action and when it must be completed.
Control measures may include changing the substance or process, containment, closed handling systems, local exhaust ventilation, restricted access, safe storage, suitable labelling, planned cleaning, safe waste disposal, and emergency arrangements for spillages. PPE may still be needed, but HSE guidance warns against automatically choosing PPE as the main control because it is less reliable than other measures.
Common Compliance Gaps
A common weakness is treating safety data sheets as the COSHH assessment. SDS information is useful, but it does not assess the task, the workplace, the way the substance is used, or the actual exposure conditions.
Other gaps include failing to consider substances generated by processes, overlooking skin exposure, not involving contractors, poor storage arrangements, weak labelling, and no clear process for reviewing controls.
Local exhaust ventilation is another area where assurance matters. HSE guidance says ventilation equipment must be examined and tested every 14 months by a competent person. Senior managers should make sure this is tracked, evidenced and followed up.
Training can also be too general. Workers need to understand the hazards, risks, control measures, workplace exposure limits where relevant, monitoring results where applicable, and what to do in an emergency.
Manager Checklist
Use this checklist to test whether COSHH arrangements are working:
- Are all hazardous substances identified, including those created by work processes?
- Are COSHH assessments task-specific rather than just based on SDS files?
- Are exposure routes considered, including inhalation, skin contact and swallowing?
- Have contractors, maintenance workers and visitors been considered where relevant?
- Are controls based on prevention and reduction of exposure, not automatic reliance on PPE?
- Is LEV, where used, examined and tested by a competent person at the required interval?
- Are workers trained on the risks, controls, PPE and emergency arrangements?
- Are assessments reviewed when substances, processes, equipment, staff or working methods change?
Training and Competence Considerations
The person carrying out a COSHH assessment does not need a specific qualification, but must be competent. HSE describes competence in this context as having the knowledge, skills and experience to understand hazard and risk, know how exposure can occur, collect the necessary information, and make decisions about controlling exposure.
Workers also need clear information, instruction and training. They should know what substances they are working with, how exposure can harm health, which controls they must use, and what to do if there is an accident or spillage.
Frequently Asked Questions
- Is a safety data sheet enough for COSHH compliance?
No. HSE states that a safety data sheet does not replace a COSHH risk assessment. The assessment must consider the specific workplace, task, exposure routes and controls.
- Do COSHH assessments need to be recorded?
If the employer has five or more employees, the COSHH assessment must be recorded. The record should show the risks identified and the actions taken to control risks to workers’ health.
- Does COSHH only apply to labelled chemicals?
No. COSHH can also apply to substances generated by work processes, including dusts, fumes, vapours, mists and gases.
- Is PPE enough to control COSHH risks?
Not usually on its own. HSE guidance says employers should not automatically choose PPE as the control measure because it is less reliable than other controls. PPE may be needed alongside other measures.
When should a COSHH assessment be reviewed?
It should be reviewed regularly and when there are changes to staff, processes, substances or equipment. It should also be reviewed if workers report problems, or after accidents or near misses.