Many COSHH folders are full of current safety data sheets but contain no real assessment of the work. The supplier's sheet is important evidence, yet it cannot know whether your employee sprays the product, wipes it on, heats it, uses it for ten minutes or spends a full shift beside it. It cannot see the room, the extraction, the quantity, nearby people or what happens during cleaning and maintenance. Those facts determine the exposure and the controls your business needs.
The legal duty is to assess the work, not collect paperwork
Regulation 6 of the Control of Substances Hazardous to Health Regulations 2002 requires a suitable and sufficient assessment before work liable to expose employees begins. It must identify the risk and the steps needed. Regulation 7 then requires exposure to be prevented where reasonably practicable or otherwise adequately controlled.
HSE states the distinction plainly: a safety data sheet is not a risk assessment. It supplies information about a chemical product, including hazards, handling, storage and emergency measures, which the employer uses as an input to its own assessment. Filing the sheet without applying it to the task leaves the central questions unanswered.
Start with substances created by the job as well as products bought
A product inventory is only the beginning. COSHH can cover chemicals, fumes, dusts, vapours, mists, gases and biological agents. Harmful substances may be created by the process and arrive with no supplier sheet: welding fume, wood dust from sanding, silica dust from cutting, flour dust, vehicle exhaust and mist from machining fluids are common examples.
Walk the job from delivery to disposal. Include storage, mixing, application, cleaning, maintenance, spill response and waste. Ask what happens when production is busy or equipment fails. An office list can miss the highest-exposure part of the task.
Assess exposure, not just the hazard symbol
Hazard describes the potential to cause harm. Risk depends on how exposure occurs in your workplace. Record the task, substance and form; quantity; frequency and duration; temperature or pressure; and every credible route into the body. People may inhale dust, mist, vapour, gas or fume, absorb material through the skin, swallow contamination transferred from hands or surfaces, or receive it through a puncture or injection injury.
Identify everyone who may be exposed, including cleaners, maintenance staff, contractors and people working nearby. Consider relevant respiratory or skin conditions while keeping health information confidential. Only some substances have workplace exposure limits, and a limit does not remove the duty to apply suitable control principles.
Choose controls in the right order
First ask whether the substance or process is necessary. Can the business eliminate it, buy a safer product, use a less dusty form, reduce the temperature or quantity, or change the method so less contaminant is released? If exposure cannot be prevented, consider enclosure, closed transfer, local exhaust ventilation, segregation and restricted access before relying on worker behaviour.
Procedures, supervision, training, hygiene, storage and spill arrangements support the physical controls. PPE may still be required, but it should not be the automatic first answer. Gloves must suit the substance and task. Respiratory protection must suit the contaminant and exposure; tight-fitting masks also require face-fit testing.
State exactly what is required. 'Wear gloves in accordance with the SDS' is weaker than naming the specification, change interval, removal method and action if a glove tears.
Turn product information into task-specific controls.
HR + SAFETY can observe the work, review safety data sheets and identify the practical controls, checks and instructions each task needs.
Discuss a COSHH assessment reviewDecide whether measurement or specialist advice is needed
A simple, low-risk task may be assessed using reliable supplier information and HSE COSHH Essentials. Air monitoring is relevant where measurement is needed to show compliance with a limit, demonstrate that controls work or resolve uncertainty. Screening meters do not automatically prove personal exposure is adequately controlled.
Engineering controls need examination, testing and maintenance at the required intervals. Record responsibility and retained evidence. For complex or potentially high exposure, or substances such as respiratory sensitisers, carcinogens or respirable crystalline silica, obtain competent specialist advice rather than guessing from a template.
Check whether health surveillance is required
Health surveillance is not a general wellbeing questionnaire. It is needed where an identifiable disease or effect is associated with the substance, valid detection is possible and workplace conditions make the effect reasonably likely. Examples include skin checks for dermatitis or respiratory surveillance for asthma-causing substances.
Results need competent interpretation, relevant feedback to employees and a review of controls when harm or adverse trends appear. Occupational-health input may be required, but responsibility for controlling exposure remains with the employer.
Make the assessment usable at the point of work
Employees need to understand the hazards, exposure routes, controls, checks and emergency action that apply to their task. That does not mean handing everybody a sixteen-section supplier sheet. Translate the assessment into a short operating instruction, briefing or task control that can be followed where the substance is used. Make the full assessment and current safety data sheet available for reference.
Supervisors should be able to recognise failure: damaged extraction, an empty eyewash, the wrong gloves, visible dust escaping, incompatible substances stored together or an employee improvising during a spill. Stop and review when controls are no longer effective, the substance, process, equipment or workforce changes, or an incident, near miss or health concern exposes a gap.
COSHH assessment checklist for an SME
Businesses across Teesside and the wider North East may use the same product in very different conditions: a vehicle workshop spraying cleaner, a care service handling disinfectant, a bakery weighing flour or a fabricator producing welding fume. The document must reflect the actual workplace, not the product name alone.
- List supplied products and hazardous substances generated by the work.
- Obtain and check current safety data sheets where they apply.
- Observe the real task, including cleaning, maintenance, spills and disposal.
- Record who may be exposed, by which route, how often and for how long.
- Eliminate or substitute before selecting engineering, procedural and PPE controls.
- Check storage, labelling, incompatible materials and emergency arrangements.
- Decide whether exposure monitoring, health surveillance or specialist advice is needed.
- Specify examination, testing, maintenance, training and supervision responsibilities.
- Brief workers in plain language and verify that controls work in practice.
- Review after change, control failure, an incident, a near miss or evidence of ill health.
Use the safety data sheet as evidence, then assess the real job. Identify every substance and exposure route, prevent exposure where reasonably practicable, specify workable controls and verify that those controls continue to protect people.
This guide provides general information for UK employers. It is not legal advice and should not replace advice based on the facts of a specific matter.