COSHH Compliance Checklist: What UK Employers Need in Place

COSHH compliance isn't one task with a single sign-off. It's eight separate duties, set out in Regulations 6 to 13 of the COSHH Regulations 2002, and each one has its own requirements. This checklist walks through each duty so you can check what's in place and what's missing.

For an introduction, see our guide to what COSHH is and who it applies to.

1. Assess the risk to health (Regulation 6)

Before any work that could expose employees to a hazardous substance begins, the employer must make a "suitable and sufficient" assessment. This has to consider the substance's hazardous properties, the level, type and duration of exposure, information from the supplier including anything in the Safety Data Sheet, and the effect of any control measures already in place.

Under Regulation 6(3), the assessment must also be reviewed regularly, and immediately if there's reason to think it's no longer valid, if the work changes significantly, or if a monitoring result shows it's needed. For a full walkthrough of how to carry one out, see our step-by-step COSHH risk assessment guide.

2. Prevent or control exposure (Regulation 7)

Where reasonably practicable, exposure should be prevented altogether, for example by not using the substance at all or substituting it for something less hazardous. Where prevention isn't reasonably practicable, exposure must be adequately controlled instead, and Regulation 7 sets out a hierarchy for doing so: eliminate or substitute first, then apply engineering controls such as local exhaust ventilation, and treat personal protective equipment as a last resort rather than the first line of defence.

3. Make sure control measures are actually used (Regulation 8)

Having the right controls in place isn't the same as using them. Regulation 8 requires employers to take reasonable steps to ensure control measures are properly used, and it's one of the few COSHH duties that falls on employees too: anyone provided with a control measure must use it, and must report any defect they notice as soon as they become aware of it.

4. Maintain, examine and test control measures (Regulation 9)

Engineering controls need upkeep to keep working. Regulation 9 requires all control measures, including PPE, to be maintained in an efficient state, kept in good repair, and examined and tested at suitable intervals, with records kept.

For local exhaust ventilation, HSE guidance specifies a thorough examination and test at least once every 14 months, and more frequently for some processes or contaminants. A competent person must carry out the examination and test.

5. Monitor exposure where required (Regulation 10)

Monitoring isn't automatic for every substance. Regulation 10 requires it where it's needed to make sure a Workplace Exposure Limit isn't being exceeded, or otherwise necessary to check that controls are working and protect health. Where monitoring is carried out on an employee who is also under health surveillance, an individual record must be kept for that person, and some personal exposure records must be retained for at least 40 years.

Silica dust exposure on stone-cutting sites is a common example of work that triggers this duty. See our guide to what COSHH requires when cutting stone for how that plays out in practice.

6. Carry out health surveillance where appropriate (Regulation 11)

Health surveillance also depends on the work rather than applying across the board. Regulation 11 treats it as appropriate either where the substance and process appear together in Schedule 6 of the Regulations, or where there's a reasonable likelihood that an identifiable disease could result from the exposure and there's a practical way of detecting it.

Where surveillance flags a problem, the employer must ensure a suitably qualified person tells the affected employee and reviews the control measures being used.

7. Provide information, instruction and training (Regulation 12)

Every employer whose work could expose an employee to a hazardous substance must give that employee suitable and sufficient information, instruction and training. Regulation 12 sets out what this has to cover: the names of the substances involved and the risk they present, any relevant exposure limit, and access to the relevant Safety Data Sheet. The duty also extends beyond direct employees, to anyone carrying out work connected with the employer's COSHH duties, including contractors.

8. Prepare for accidents, incidents and emergencies (Regulation 13)

Employers must have arrangements ready before something goes wrong, not put together afterwards. Regulation 13 requires appropriate facilities such as first aid, procedures that have been practised rather than just written down, and a way to raise the alarm and communicate quickly if an incident happens.

Who is actually responsible for working through this checklist?

The legal duty for all eight regulations sits with the employer, not with whoever is asked to carry out the day-to-day work. An employer can appoint a competent person, an occupational health adviser, a health and safety manager or an external consultant to complete the risk assessment, run monitoring, or deliver training, but appointing someone doesn't transfer the underlying legal responsibility. If that work is done badly or not at all, it's the employer who is answerable to HSE or a local authority inspector, not the person they delegated it to.

This matters most in workplaces with more than one employer on site, such as a construction project with several contractors, or a shared building with different tenant businesses. Each employer retains their own COSHH duties for their own employees and the substances their own work involves; one employer's risk assessment doesn't automatically discharge another's.

Reviewing the checklist, not just completing it once

Reviewing the risk assessment should prompt a check of the arrangements that support it. Update controls, training and emergency arrangements where the review shows changes are needed, rather than only revising the assessment paperwork.