COSHH isn’t a vague aspiration to “be safe around chemicals.” It’s a structured legal duty with eight distinct requirements under the COSHH Regulations 2002. Get any one of them wrong, and you’re exposed — legally and financially.
Step 1: Assess the Health Risks Before any work involving hazardous substances begins, you must conduct a COSHH assessment. This means identifying what substances are present, who could be harmed and how, what Workplace Exposure Limits (WELs) apply, and whether current controls are adequate. If you employ five or more people, this assessment must be documented. (Yes, even the cleaning products in your office kitchen.)
Step 2: Decide What Precautions Are Needed Use the hierarchy of control: elimination first, substitution second, engineering controls third, administrative measures fourth, and personal protective equipment (PPE) as the last resort — never the first. Most small businesses jump straight to PPE. That’s backwards, and the HSE knows it.
Step 3: Prevent or Control Exposure Where prevention isn’t reasonably practicable, you must control exposure so that it stays below the relevant WEL. The HSE publishes WELs in EH40, its workplace exposure limits document — updated regularly and worth bookmarking.
Step 4: Ensure Control Measures Are Used and Maintained Local exhaust ventilation (LEV) systems must be examined and tested at least every 14 months. Records must be kept for at least 5 years. This is one of the most frequently failed areas during HSE inspections — equipment that exists but nobody maintains.
Step 5: Monitor Exposure For certain substances, you need regular air or biological monitoring. Records of carcinogen monitoring must be kept for 40 years — not 5. That’s not a misprint. The health effects from carcinogen exposure can take decades to appear, and those records protect both workers and employers.
Step 6: Carry Out Health Surveillance Where there’s a reasonable likelihood of disease developing from a substance — occupational asthma from isocyanates, for example — health surveillance is legally required. Not optional. Not “nice to have.”
Step 7: Prepare Plans for Accidents, Incidents, and Emergencies Eye wash stations, chemical showers, spill kits, trained first responders. If you’re working with substances that could cause serious acute harm, your emergency response plan needs to be detailed, practised, and genuinely accessible — not laminated on a wall nobody reads.
Step 8: Inform, Train, and Supervise Employees COSHH training must happen before an employee starts working with hazardous substances — not during their first week when they’ve already started. It must be refreshed whenever substances or processes change. And it must be genuinely understood, not just ticked off a form.
Final Thoughts
COSHH compliance isn’t about ticking boxes — it’s about building a system that actively prevents harm. The regulations are deliberately structured so that each step reinforces the next: you can’t control what you haven’t assessed, you can’t protect people if your controls aren’t maintained, and training means nothing if it isn’t understood or applied.
What trips most organizations up isn’t complexity — it’s complacency. Skipping documentation, over-relying on PPE, neglecting maintenance, or treating training as a formality are exactly the kinds of gaps regulators look for. And when they find them, the consequences aren’t just fines — they’re reputational damage, operational disruption, and, in the worst cases, long-term harm to people.
If you take one thing away, let it be this: COSHH is a continuous process, not a one-time task. Substances change, processes evolve, and risks shift over time. Your controls, monitoring, and training need to evolve with them.
Do it properly, and COSHH becomes more than compliance — it becomes a safeguard for your people, your business, and your future.
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