COSHH Assessment: Control of Substances Hazardous to Health Guide

Quick Answer: What Is COSHH?

COSHH stands for the Control of Substances Hazardous to Health Regulations 2002. These regulations require UK employers to assess, control, and monitor exposure to hazardous substances in the workplace. A COSHH assessment is a specific type of risk assessment focused on substances that can harm health.

COSHH applies to a wide range of substances found in virtually every workplace -- not just factories and laboratories. Cleaning products, paints, adhesives, dust, fumes, and even biological agents like bacteria all fall under COSHH.

---

What Substances Does COSHH Cover?

What COSHH Does NOT Cover

COSHH does not apply to:

• Lead (covered by the Control of Lead at Work Regulations 2002)
• Asbestos (covered by the Control of Asbestos Regulations 2012)
• Radioactive substances (covered by the Ionising Radiations Regulations 2017)
• Simple asphyxiants in some circumstances
• Below-ground work in mines (separate regulations apply)

---

The 8 Steps of COSHH Assessment

The HSE sets out 8 principles of good practice for controlling exposure to hazardous substances:

Step 1: Identify Hazardous Substances

Create an inventory of all substances used, produced, or generated in your workplace:

• Check product labels for hazard symbols and signal words (Danger, Warning)
• Read Safety Data Sheets (SDS) -- suppliers must provide these for all hazardous products
• Consider substances generated by work processes -- wood dust from cutting, welding fumes, flour dust from baking
• Include biological agents -- legionella in water systems, blood-borne viruses in healthcare

GHS hazard symbols to look for:

Step 2: Assess the Risks

For each substance, consider:

• Who could be exposed? (employees, contractors, visitors, members of the public)
• How could they be exposed? (inhalation, skin contact, ingestion, injection)
• How much and how often are they exposed?
• What is the effect? (acute poisoning, chronic disease, sensitisation, cancer)

Use the Safety Data Sheet sections on toxicological information and exposure controls to understand the risks.

Step 3: Determine the Control Measures

Apply the hierarchy of controls (most effective first):

1. Eliminate the substance -- can you remove it from the process entirely?
2. Substitute with a less hazardous alternative -- water-based paint instead of solvent-based, for example
3. Enclose the process -- use closed systems, glove boxes, or sealed containers
4. Local exhaust ventilation (LEV) -- extract fumes, dust, or vapours at source
5. General ventilation -- dilute airborne contaminants with fresh air
6. Reduce exposure -- limit the number of people exposed and the duration of exposure
7. PPE -- respirators, gloves, goggles, overalls (last resort)

Step 4: Implement the Controls

Put your chosen controls in place. This may involve:

• Purchasing new equipment (LEV systems, enclosed mixing vessels)
• Changing work procedures (different application methods, batch sizes)
• Providing PPE and ensuring it fits correctly
• Installing warning signs and COSHH information points
• Restricting access to areas where hazardous substances are used

Step 5: Monitor Exposure

Where there are Workplace Exposure Limits (WELs) listed in HSE publication EH40, you may need to carry out exposure monitoring:

• Personal exposure monitoring using sampling pumps worn by workers
• Static (area) monitoring to check general air quality
• Results must be kept for at least 5 years (or 40 years for substances that cause cancer, asthma, or other chronic diseases)

Step 6: Health Surveillance

Health surveillance is required when:

• Employees are exposed to substances known to cause specific diseases (e.g. isocyanates causing asthma)
• There is a valid technique to detect early signs of disease
• There is a reasonable likelihood of disease occurring under normal working conditions

Examples include:

• Lung function testing for workers exposed to respiratory sensitisers
• Skin checks for workers exposed to dermatitis-causing substances
• Biological monitoring (blood or urine tests) for workers exposed to lead, mercury, or other specific substances

Health surveillance records must be kept for at least 40 years.

Step 7: Prepare for Emergencies

Plan for accidental releases, spills, or exposure incidents:

• Spill kits appropriate to the substances used
• Emergency procedures including evacuation routes and assembly points
• First aid measures specific to the substances (detailed in SDS Section 4)
• Emergency contacts including the National Poisons Information Service (NPIS) where relevant

Step 8: Train and Inform Employees

All employees who work with or near hazardous substances must receive:

• Information about the substances they may be exposed to and the risks they present
• Training on the controls in place and how to use them correctly
• Instructions on what to do in an emergency
• Access to Safety Data Sheets for all substances they use

Training must be provided before first exposure and refreshed regularly.

---

COSHH Assessment Record Template

---

Industry-Specific COSHH Considerations

Cleaning and Facilities Management

Cleaning products, disinfectants, and bleach are common COSHH substances. Mixing products (e.g. bleach and ammonia-based cleaners) can produce toxic gases. Ensure cleaners understand SDS sheets and never mix chemicals.

Construction

Cement, silica dust, solvents, paints, and adhesives. Silicosis from respirable crystalline silica (RCS) is a major concern. Dust suppression and RPE are critical controls.

Manufacturing

Wide range of substances depending on processes. LEV systems, enclosed processes, and health surveillance programmes are common control measures.

Healthcare and Social Care

Blood-borne viruses, cleaning chemicals, pharmaceutical agents, and anaesthetic gases. Sharps injuries and needlestick procedures are specific concerns.

Hairdressing and Beauty

Hair dyes, bleaching products, acrylics, and cleaning agents. Dermatitis and occupational asthma are significant risks. Gloves, ventilation, and skin care programmes are essential.

---

Penalties for COSHH Non-Compliance

Failure to comply with COSHH can result in:

• Improvement notices requiring action within a specified period
• Prohibition notices stopping work immediately
• Prosecution with unlimited fines and up to 2 years' imprisonment
• Civil claims from employees who develop occupational diseases due to exposure

---

How Grove HR Supports COSHH Compliance

• Training records -- track COSHH training for all employees who handle hazardous substances
• Document management -- store COSHH assessments, SDS sheets, and monitoring records
• Onboarding checklists -- include COSHH awareness training as a mandatory step
• Health surveillance tracking -- log surveillance appointments and results
• Absence monitoring -- identify patterns of occupational illness