A bottle of cleaning fluid comes with a label. Dust created by cutting stone does not.
Both can create risks that employers need to manage under the Control of Substances Hazardous to Health Regulations 2002, usually shortened to COSHH.
For employers, the practical challenge is turning those requirements into everyday protection: understanding where exposure happens, choosing effective controls and checking that they continue to work.
Here is what that means for your workplace.
COSHH requires employers to prevent exposure to substances hazardous to health or, where prevention is not reasonably practicable, adequately control it.
The 2002 Regulations, as amended, provide the framework for Great Britain. Northern Ireland has separate COSHH Regulations dating from 2003.
The starting question is straightforward: could a substance used or produced at work harm someone’s health?
That makes COSHH relevant well beyond laboratories and chemical manufacturing. A workshop, construction site, cleaning operation or food production facility can all involve hazardous substances.
COSHH covers a broad range of health hazards, including harmful dusts, fumes, vapours, gases, mists, chemicals and biological agents.
Exposure can happen through breathing a substance in, swallowing it, skin contact or penetration of the skin. An assessment focused only on airborne exposure can therefore miss other important risks.
Examples of substances generated by work include:
These hazards need attention even when the original material does not arrive in a container carrying a warning label. Lead and asbestos are covered by separate regulations.
Collecting safety data sheets is useful, but it does not complete a COSHH assessment.
A safety data sheet describes a product’s hazards and provides handling and safety information. Your assessment must consider what happens when that product is used in your workplace. HSE explicitly states that a safety data sheet is not a risk assessment.
Consider a cleaning product used in two different ways. One worker applies a small amount to a cloth. Another sprays it repeatedly inside a confined work area.
The product may be identical, but the potential exposure is different. Your controls need to reflect the task.
Start with the work people actually do.
Identify the substances involved, who could be exposed, how exposure occurs and how often it happens. Include cleaning, maintenance and nearby workers, rather than looking only at the main operator.
Then establish what controls are already in place, what needs improving, who will take action and when.
Businesses with five or more employees must record their assessment. Smaller businesses still need to assess and control the risks, and a written record is useful.
Review assessments regularly and when changes or concerns suggest they may no longer be valid.
A practical way to test your assessment is to walk through the task with the people doing it. Ask where the written procedure differs from reality and what makes the controls difficult to use.
The first priority is to prevent exposure. Substitution should be considered: could a different substance or process eliminate or reduce the risk?
Where exposure remains, controls may include enclosed processes, extraction, safer working procedures and suitable protective equipment.
Local exhaust ventilation, or LEV, captures airborne contaminants close to their source. Working arrangements also matter, including access restrictions, cleaning procedures, supervision and the way equipment is used.
Controls need checking in practice. An extraction system can only help when it is operating effectively and used correctly. Employees should understand the controls and report problems promptly.
PPE can be part of the solution, but it should not automatically become the first or only response. HSE advises using other effective controls wherever possible.
Workplace exposure limits, or WELs, are limits for concentrations of certain hazardous substances in workplace air, averaged over a specified period. Current Great Britain limits are published in HSE’s EH40 guidance.
A substance without a WEL can still be hazardous and require control.
For carcinogens, mutagens and asthmagens, exposure must be reduced as low as reasonably practicable. Treating a limit as a target misses the purpose of exposure prevention.
For managers, the useful question is: what evidence shows that the controls are keeping exposure adequately controlled during the work being carried out?
Exposure monitoring helps establish whether control is adequate. It can be appropriate when you need to demonstrate compliance with a WEL or check whether control equipment is protecting workers sufficiently.
Personal air monitoring assesses exposure in the air a worker breathes. Screening instruments can provide useful indicators, but their readings should be interpreted according to what the instrument and method actually measure.
Before commissioning monitoring, define the question you need answered. For example:
Agree the measurement approach and interpretation with a competent specialist.
Exposure monitoring examines exposure. Health surveillance looks for work-related effects on workers’ health.
Under COSHH, health surveillance is needed in relevant circumstances where a substance is associated with an identifiable health effect, there is a reasonable likelihood of that effect occurring under the working conditions, and suitable detection methods are available.
It might involve checks relating to skin condition or respiratory health, depending on the risk.
The results must lead to action where needed. Completing checks without responding to findings leaves the underlying exposure problem unresolved.
Installing equipment is the beginning of its working life.
LEV needs commissioning, appropriate information and training, and periodic examination and testing. HSE specifies testing at least every 14 months; the requirements for the particular process and system must also be checked.
Regular checks should identify problems before the next scheduled examination. Workers need a clear route for reporting damaged equipment or controls that appear ineffective.
Keep records of control-equipment examinations, tests and repairs for at least five years. These can help reveal recurring faults and deterioration.
A recurring fault deserves a recurring question: why does this keep happening, and what needs to change?
A useful COSHH programme connects the assessment to the task, the task to its controls, and the controls to evidence that they work.
For your next workplace review, take one activity and follow it from preparation through to cleaning up. Can the supervisor explain the risks? Can workers demonstrate the controls? Is there a clear response when something goes wrong?
Those conversations help turn a document into a working system.
COSHH stands for Control of Substances Hazardous to Health. It concerns preventing or adequately controlling workplace exposure to substances that could harm health.
No. A safety data sheet provides information about a substance or product. A COSHH assessment uses that information alongside the actual conditions of work to assess exposure and determine suitable controls.
Yes. Hazardous substances generated during work, including dust from sanding or cutting and fumes from welding, need to be considered. COSHH is not limited to purchased chemicals.
No. Only some substances have WELs. The absence of a published limit does not remove the need to assess the risk and control exposure.
No. They serve different purposes. Exposure monitoring helps assess exposure and control effectiveness, while health surveillance checks for relevant effects on workers’ health. Depending on the risks, both may be required.
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