By Jade Beharrell, Founder, Go To Learning
A COSHH assessment can be carefully prepared, filed and signed off, yet still fail to influence what happens during a busy shift. The crucial question is not simply whether a business has identified hazardous substances. It is whether the people handling them understand the risks, recognise when controls are failing and know what to do next.
The Control of Substances Hazardous to Health Regulations 2002 (as amended) require employers to assess risks, prevent or adequately control exposure, and provide suitable information, instruction and training. These are connected duties, not separate paperwork exercises. A useful assessment should inform decisions about equipment, working methods, supervision and everyday behaviour [1, 2, 9].
Hazards do not always arrive in labelled containers
It is tempting to associate COSHH with bottles carrying hazard pictograms. Yet harmful exposure can arise from the work itself: flour dust in a bakery, wood dust during sanding, welding fume, or process mist. Employees may not regard familiar materials as hazardous, particularly when effects develop gradually rather than immediately [1].
A substance’s hazard is only part of the picture. Risk depends on the task, route of exposure, duration, frequency and the controls in place. Inhaling hazardous dust and coming into skin contact with a chemical are different routes of exposure, each potentially requiring different control measures. A safety data sheet is a valuable source of information, but it is not a task-specific COSHH assessment [1, 3].
That distinction matters when work changes. A new cleaning product, a different application method, or an altered production schedule can change exposure even if a workplace’s chemical inventory looks much the same.
The gap between written controls and real work
Imagine a cleaning team with an assessment that requires correct product dilution and specified protective measures. The assessment may be sound, but what happens when a new starter has not been shown the dilution method, the dispensing equipment is unavailable, or the team is rushing to reopen an area?
These are illustrative situations, not evidence that any particular sector is routinely non-compliant. They show why managers must test whether controls are practical in the conditions employees actually face. HSE guidance emphasises that adequate control depends on equipment, safe working procedures and worker behaviour together [4].
A useful exercise is to walk through the task with the employee who performs it. Observe where substances are stored, how they are transferred, whether containers are clearly identified, and how spills or waste are managed. Ask what happens when the normal method is interrupted. This can reveal a mismatch between the assessed procedure and the routine that has developed in practice. The findings should feed back into the assessment and any corrective action, rather than remain an informal conversation.
A document cannot correct an unsafe shortcut on its own. Workers need accessible instructions, working equipment, enough time to use it, and a clear, timely route to report concerns. Supervisors also need to observe how tasks are carried out, rather than assuming that signing a training record proves understanding.
Start with prevention, not just PPE
COSHH is not primarily a rule about wearing gloves. Employers should first consider whether they can eliminate, substitute, or change a hazardous substance or process to reduce exposure. Where exposure cannot be prevented, engineering and organisational controls may be needed, including enclosure, extraction, restricted access and safe systems of work. Personal protective equipment can play an important role, but it should not automatically become the first or only answer [1, 5].
For example, controlling dust at source is generally more dependable than relying entirely on each worker to wear respiratory protection correctly. Similarly, using a safer product or a less dusty form may reduce the problem before the task begins. Decisions must reflect the particular assessment; there is no universal control measure for every substance or process.
Workers should understand not only which precautions apply, but why. When people understand the potential health consequences and the purpose of a control, they are better placed to recognise when a familiar task has become unsafe [6].
Make information usable at the point of work
Effective training goes beyond communicating information. It should equip employees to recognise hazards, understand the controls in place and make informed decisions when working conditions change. Someone handling hazardous substances should be able to answer straightforward questions: What could harm me? How could I be exposed? Which controls must I use? What signs suggest something is wrong? Who do I tell? What should I do in an emergency?
HSE states that information, instruction and training should cover relevant hazards, exposure limits, assessment findings, precautions and emergency arrangements. Workers should have access to safety data sheets, and contractors must receive relevant information about risks and controls [2].
For teams with temporary workers, shift patterns or contractors, information can be missed at handover. A short pre-task briefing can clarify which substances are in use, what has changed and which precautions apply. Where a worker is unfamiliar with a task, supervision and a practical demonstration may be especially important. Refresher instruction should respond to changes and observed needs, rather than rely on an arbitrary calendar date alone.
This does not mean handing everyone a lengthy technical document and expecting them to interpret it unaided. Short task demonstrations, clear labels, visual instructions and supervisor checks can reinforce formal learning. Training should also be understandable to the people doing the work, taking account of their roles and the exposure involved.
A practical test is to ask a worker to explain or demonstrate the safe method in their own words. If they cannot, the answer may be better instruction or a simpler process, not another signature.
Check whether the controls are still working
COSHH management needs an ongoing feedback loop. Equipment can deteriorate; processes can change; staff may rotate between tasks. Employers should review assessments and controls when changes, incidents, near misses or concerns suggest the existing arrangements may no longer be effective [1].
For some exposures, monitoring or health surveillance may be required. These are different activities: exposure monitoring assesses the extent of exposure or adequacy of controls, while health surveillance looks for early signs of work-related ill health where appropriate [7, 8]. Neither replaces the duty to prevent or adequately control exposure.
Frontline workers can provide particularly useful information. They may notice a damaged extraction hood, unexpected fumes, a product being transferred into an unsuitable container or a procedure that no longer fits the job. Encouraging early reporting turns COSHH from a periodic audit exercise into a more responsive safety system.
Five questions for managers to ask this week
- Can staff identify hazardous substances generated by the task, not just those purchased in containers?
- Can they explain the required controls and demonstrate how to use them?
- Are safer substances, methods or engineering controls available before relying on PPE?
- Have recent changes to products, people or processes triggered a review?
- Do employees know how to report failed controls, exposure concerns and emergencies?
These questions are not a substitute for a suitable and sufficient assessment. They are a quick way to see whether the assessment reaches the people it is intended to protect.
From compliance evidence to everyday protection
A well-kept COSHH assessment is important evidence of a considered approach, but its real value lies in preventing ill health. That requires more than identifying a hazard and assigning a control on paper. It requires practical controls, informed workers, effective supervision and willingness to revisit assumptions when work changes.
The most useful question for leaders may therefore be: if the person doing this task encountered a problem today, would they recognise it and know how to respond safely? If the answer is yes, and the controls are effective, COSHH becomes part of how work is done, rather than a document consulted only at review time.
About the Author: Jade Beharrell
Jade Beharrell is the founder of Go To Learning, a UK-based provider of CPD-accredited online training specialising in food safety and workplace compliance. Through Go To Learning, she helps businesses make essential training more accessible and manageable.
References
[1] HSE, How to carry out a COSHH risk assessment. https://www.hse.gov.uk/coshh/basics/assessment.htm
[2] HSE, Training for employees working with substances hazardous to health. https://www.hse.gov.uk/coshh/basics/training.htm
[3] HSE, Chemical safety data sheets. https://www.hse.gov.uk/coshh/basics/datasheets.htm
[4] HSE, Control measures to prevent or limit exposure to hazardous substances. https://www.hse.gov.uk/coshh/basics/control.htm
[5] HSE, What you need to do under COSHH. https://www.hse.gov.uk/coshh/basics/whatdo.htm
[6] HSE, Principles of good control practice. https://www.hse.gov.uk/coshh/detail/goodpractice.htm
[7] HSE, Monitoring the control of exposure to hazardous substances. https://www.hse.gov.uk/coshh/basics/monitoring.htm
[8] HSE, COSHH health surveillance. https://www.hse.gov.uk/coshh/basics/surveillance.htm
[9] HSE, Control of substances hazardous to health (COSHH): Approved Code of Practice and guidance (L5), covering the Control of Substances Hazardous to Health Regulations 2002 (as amended). https://www.hse.gov.uk/pubns/priced/l5.pdf
