COSHH Assessment: Start by Walking the Store Cupboard

A COSHH assessment is the employer's assessment, under the Control of Substances Hazardous to Health Regulations 2002, of the risk from a hazardous substance at work — who could be harmed, how, and whether the controls are enough. Most guidance starts with the form. In practice the hardest part comes before it: knowing what you've actually got.

An assessment can only cover a substance someone has noticed. So start with a walk.

Walk the site, not the purchase ledger

The purchase ledger tells you what was bought. It doesn't tell you what's in the back of the van, what the cleaning contractor brought in, or what the process makes. Walk every area and look for three kinds of substance.

1. The ones in containers

• Store cupboards and chemical stores: solvents, adhesives, paints, degreasers, acids
• Cleaning stores: bleach, descalers, oven cleaners, floor strippers — often the most forgotten
• Workshops: oils, coolants, brake cleaners, fuels
• Vehicles and site boxes: what technicians carry with them
• Kitchens, labs, maintenance cupboards, the boiler room

For each, note the product name, where it's kept, roughly how much, and whether there's a safety data sheet for it.

2. The ones your work makes

These are the substances most often missed, because nobody bought them.

• Dust: wood dust from sawing and sanding, silica dust from cutting stone, concrete or brick, flour dust in bakeries
• Fume: welding and soldering fume, fumes from hot processes
• Mist and vapour: from spraying, metalworking fluids, solvents evaporating from open containers
• Gases produced by a process

3. The biological ones

• Bacteria and viruses in healthcare, laboratories and some waste work
• Legionella in water systems (it has its own risk assessment, but it's still a hazardous substance)
• Animal and bird droppings, mould, sewage

What to check at each one, on the walk

You're not assessing yet; you're collecting what the assessment will need.

• The label and pictograms: what the hazard is
• The safety data sheet: present, current, and actually read by someone
• How it's used: decanted, sprayed, heated, mixed, used by hand. The task changes the risk more than the tin does.
• Who uses it, and how often
• The controls in place right now: extraction working, lids on, ventilation, gloves of the right type available, eye protection
• Storage: sealed containers, incompatible substances kept apart, nothing in unlabelled bottles
• A photo: of the label, the storage and the place it's used

From list to assessments

Once the list exists, group it:

• Low-risk products used as directed (washing-up liquid, normal office supplies) often need little more than confirming they're used as the label says.
• Similar substances used in the same way can often share one assessment: for example, several solvent-based paints sprayed in the same booth.
• Anything that's sprayed, heated, generates dust or fume, or carries a serious hazard warning usually needs its own assessment of the task.

Then each assessment works through who's exposed, how (breathing, skin, swallowing), for how long, the controls in order of preference, and whether further action is needed.

What a walk usually turns up

The unlabelled bottle. Something decanted into a drinks bottle or spray bottle with no label. Nobody's sure what it is.

The out-of-date data sheet, or none at all, for a product that's been on the shelf for years.

The dust nobody assessed. A workshop that assessed every tin but never the wood or silica dust it makes all day.

Extraction that's switched on but not working. Local exhaust ventilation needs a thorough examination and test at least every 14 months under COSHH for most systems, and a quick check that air is actually moving before each use.

Gloves that don't protect. The right glove depends on the chemical; the data sheet says which.

Doing it on the walk

Walking a site with a clipboard, copying label after label, is slow enough that it gets left half-done. Photos help; speaking helps more.

Speak while you walk, and the document writes itself. Say what you find on each shelf — "Workshop store, top shelf. Brake cleaner aerosol, about twelve cans, data sheet in the folder, used by hand on the bench. Two-part epoxy, no data sheet, photo of the label. Unlabelled spray bottle, blue liquid — removed." — and the inventory is written and photographed by the end of the walk.

Related

• Chemical exposure assessment (COSHH): the free template
• Hazardous material handling inspection: the store walk
• Dust risk assessment: silica, wood and other dusts
• Spill kit inspection checklist: ready for when a container leaks

Frequently asked questions

What is a COSHH assessment? An assessment, required by the Control of Substances Hazardous to Health Regulations 2002 in Great Britain, of the risks to health from hazardous substances at work, and of whether the controls in place are adequate.

What substances does COSHH cover? Chemicals and products with hazard warnings, dusts, fumes, mists, vapours and gases, and biological agents. Lead, asbestos and radioactive substances are covered by their own regulations instead.

Do I need a COSHH assessment for every product? Not necessarily a separate one. Low-risk products used as the label directs may need little more than confirmation of that. Similar substances used in the same way can often share an assessment. Higher-risk substances and tasks usually need their own.

Is a safety data sheet the same as a COSHH assessment? No. The safety data sheet describes the substance's hazards and how to handle it in general. The COSHH assessment looks at how it's used in your workplace, who's exposed, and whether your controls are enough.

How often should COSHH assessments be reviewed? Whenever something changes — a new substance, process, or piece of equipment, or evidence that controls aren't working — and regularly anyway. Many employers review at least every year.

Do COSHH assessments have to be written down? In Great Britain, employers with five or more employees must record the significant findings of their risk assessments. Writing them down is good practice for any size of business.