The Employers’ Guide to COSHH: Awareness, Tools & Compliance

Adrian A.
Jan 3, 2023

The Control of Substances Hazardous to Health Regulations (COSHH) is a set of regulations that employers are required to comply with in the United Kingdom. 

In this article, we’ll go over the main objectives of COSHH and the specific steps UK employers must take to keep their employees safe from hazardous substances.

We’ll also cover the tools managers or supervisors can use to simplify the process of staying compliant with COSHH, so employees can remain productive without compromising their safety.

COSHH: An overview

The purpose of COSHH is to prevent or reduce employees’ harmful exposure to hazardous substances in the workplace. COSHH regulations require employers to conduct risk assessments that:

  1. Identify all hazardous substances in the workplace
  2. Evaluate the risks of these substances to health
  3. Select measures to prevent or control exposure to the identified substances
complete guide to coshh

COSHH regulations also require employers to:

  1. Keep records of all COSHH risk assessments
  2. Regularly review COSHH risk assessments

COSHH: Important terms and prerequisites

Before we dive into more details of each step, let’s first cover the definitions of the most important terms employers need to know under COSHH:

Biological agentA micro-organism, cell culture, or human endoparasite which may cause infection, allergy, toxicity, or otherwise create a hazard to human health.
CarcinogenA substance or preparation that:Falls under carcinogenic (category 1) or carcinogenic (category 2); Is listed in Schedule 1 or arises from a process specified in Schedule 1
Control measureA measure taken to reduce exposure to a substance hazardous to health.
Hazard/hazardous substanceA substance with an intrinsic property or potential to harm a person’s health.
Inhalable dustAirborne material capable of entering the nose or mouth during breathing.
Micro-organismA microbiological entity that can replicate or transfer genetic material.
MutagenA substance or preparation categorised under mutagenic (category 1) or mutagenic (category 2).
PreparationA mixture or solution of two or more substances.
Respirable dustAirborne material that can penetrate the gas exchange region of the lung.
RiskThe likelihood that exposure to a substance hazardous to health will cause harm to an employee.
Workplace exposure limitsThe exposure limit approved by the HSE according to their guideline, EH40 Workplace Exposure Limits 2005

As a prerequisite, employers must make sure that managers or supervisors in charge of COSHH compliance are trained to:

a. Understand the most important terms under COSHH
b. Identify substances categorised under carcinogenic, mutagenic, or hazardous;
c. Know how employees will work with the hazardous substances;
d. Take relevant control measures approved by the HSE to prevent employees from exposure where possible to; and
e. In cases where prevention isn’t possible, design safety protocols to comply with HSE’s workplace exposure limits of hazardous substances.

Once these prerequisites are met, companies will be ready to conduct a COSHH risk assessment according to the steps outlined below.

Step 1: Identifying hazardous substances

The person conducting the risk assessment for hazardous substances needs to:

  1. Compile a detailed list of:

    1. Hazardous substances present in the workplace (for example, biological agents that employees have to handle)
    2. Hazards arising as a by-product or result of a particular work activity (for example, inhalable dust at a construction site)
    3. Hazards arising from work done by sub-contractors, which employees may be exposed to (for example, routine fumigation for pest or mould control)

  2. For each hazard identified, list out:

    1. The type of exposure that could happen (for example, inhalation, skin contact, etc.)
    2. The people, or group of people, that could be exposed to the hazard (for example, night cleaners, warehouse staff, lab workers, etc.)
    3. An estimated extent of exposure (for example, exposure to disinfectants more than five times a week)

Step 2: Evaluate health risks

After identifying the hazards and the people they could affect, the risk assessment needs to include an evaluation of the risks each hazard could have on the health of an employee.

These steps include:

  1. Grading the likelihood of a foreseeable risk of ill health as either:
    1. Probable
    2. Possible
    3. Remote
    4. Nil/Negligible

  2. Grading the severity of ill health, if it occurs, as either:
    1. Serious health effects
      Anything permanent, progressive, or irreversible (such as cancer or lifelong disability) is considered a serious health effect.
    2. Significant health effects
      If an effect is serious but considered temporary or non-progressive with treatment (such as salmonella infection or chemical burns), it is considered a significant health effect
    3. Minor health effects
      If an effect doesn’t require serious medical intervention or hospitalisation (such as mild skin irritation), it is considered a minor health effect.

Step 3: Prevent or control exposure

Once the health risks have been evaluated, the person conducting the risk assessment needs to choose the appropriate prevention or control measures by answering the following questions:

  1. Is there a reasonably practical way to prevent exposure by substituting hazardous substances?

  2. If not, can employers control the exposure by using a less hazardous substance or a less hazardous form of the substance?

  3. If not, choose one or more control measures to limit hazardous exposure, such as:
    1. Imposing a safe working distance
    2. Limiting the time exposed through worker rotation
    3. Administrative controls such as supervision or training
    4. Worker-specific controls such as personal protective equipment

Step 4: Record the assessment

According to the HSE, employers must keep records of all COSHH risk assessments. The key points that need to be recorded are:

  1. The hazards identified
  2. The identified people at risk
  3. The control measures identified and implemented
  4. The effectiveness of these control measures (described in the next step, “Review the assessment)

HSE has provided the following list of key hazards that should be investigated and recorded in risk assessments according to specific industries:

AgricultureDust, chemicals, diseases, toxic gasses.
BakingDust, enzymes, flavour concentrates, cleaning products.
BeautyAcrylic fumes, Ingredients that can cause skin irritation, allergies, or asthma
CateringFumes, ingredients that can cause dermatitis or skin allergies
CleaningCorrosive products, products that can cause dermatitis, allergies, or asthma
EngineeringDusts, fumes, chemicals, germs in fluids
HairdressingProducts that can cause dermatitis, allergies, or asthma
Offshore oil & gasDust, chemicals, gasses, radiation
PrintingSolvent vapours, products or ingredients that can dermatitis, allergies, asthma, or damage to internal organs over a long time.
Motor vehicle repairPaints, fuels, fluids, lubricants, products, fumes, dust, battery acid
WeldingFumes, dust, chemicals, inert gasses
WoodworkingDust, adhesives, paints, fluids, lubricants, disinfectants

Step 5: Review the risk assessment

COSHH risk assessments should be reviewed regularly for any possible changes. 

The COSHH law does not specify how often a review should be done, so it is up to the employer or health and safety officer to decide on a reasonable and practical review period. 

Other than regular reviews, COSHH reviews should be conducted immediately if:

  • There is any reason to believe the original assessment is inaccurate, such as a health-related incident or machinery defects detected from an inspection.
  • Any changes to work procedures that can affect an employee’s exposure to a hazardous substance.

COSHH risk assessment reviews should also revise any control measures that are not as effective as they should be.

Tools & Templates

Conducting COSHH risk assessments as accurately as possible is essential to maintain high workplace safety standards.

This is where having the right tools and templates can help health & safety managers or supervisors conduct risk assessments to keep their employees safe from hazardous substances and stay compliant with COSHH.

The two most invaluable tools to help managers in charge of COSHH assessment and reviews are:

1. Mobile inspections and task management software

Software like Workflows makes it easy to conduct inspections without the hassle of managing paperwork. With Workflows, health & safety managers or supervisors can:

  1. Create COSHH risk assessment templates for each workspace or department.
  2. Customise the questions and fields on the template to fit their industry and specific business processes.
  3. Assign risk assessments to their staff, so they can complete them from a mobile device.
  4. Automatically keep records of all risk assessments conducted without wasting time filing paperwork.
  5. Easily access past assessments for COSHH risk assessment reviews.

Since Workflows allow one to assign tasks and discuss issues within an assessment, health & safety managers or supervisors can also easily keep track of:

2. Mobile hazard and incident reporting:

Although reporting hazards and incidents is not part of the COSHH risk assessment process, it is crucial to alert managers or supervisors of any immediate dangers that may require a COSSH risk assessment review.

By using a mobile app to report hazards and incidents:

  1. Staff can easily report any hazards or incidents they see from their mobile devices.
  2. Managers or supervisors can see the hazards or incidents reported in real-time to take quick action, from assigning corrective actions to reporting to the HSE.
  3. Managers or supervisors can use the automated reporting system to identify trends or insights which can guide their COSHH risk assessments and reviews.

Stay compliant with COSHH the easy way

HSE managers and supervisors have a lot to handle when it comes to completing and reviewing COSHH risk assessments to keep employees safe from hazardous substances.

Having the right tools and templates at their fingertips can make it much easier to meet COSSH compliance without spending much time on manual paperwork and follow-ups.

To learn more about how our inspection and task management software, Workflows, and hazard and incident reporting tool can help your organisation complete high-quality COSHH risk assessments, contact us here to speak to our sales.

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