Examples from COSHH investigations

• Cleaning products were being used without a specific COSHH assessment. The business had Safety Data Sheets available, but there was no documented assessment of how the products were actually being used or the exposure involved.

• Employees were decanting chemicals into unlabelled containers. This created uncertainty about what the containers contained and increased the risk of incorrect use or exposure.

• Personal protective equipment was identified in the COSHH assessment but wasn't being used consistently. The investigation found a difference between the documented control measures and what happened in practice.

• A chemical was being used in a poorly ventilated area. Although the product was routinely used, consideration had not been given to whether the ventilation arrangements were adequate for the way it was being used.

• Employees had not been given sufficient information about the products they were using. The substances were familiar to employees, but they were not necessarily aware of the associated health risks or the precautions required.

• A COSHH assessment had been completed for one product, but the business had subsequently changed to another product. The assessment had not been reviewed to reflect the change.

The COSHH assessments existed — but the employee wasn't given the information

• We investigated a claim involving a cleaner who developed an allergy following exposure to cleaning products used during her work.

• The employer had a substantial number of COSHH assessments covering the cleaning products being used. However, the investigation found that the relevant information had not been properly passed on to the employee, and appropriate gloves had not been provided for the work she was undertaking.

• Despite having the required documentation in place, the employer was ultimately found liable because the information and control measures had not been effectively communicated and implemented.

• The lesson: COSHH compliance isn't simply about having assessments on file. Employees need to be given appropriate information and instruction about the substances they use, and the control measures identified in the assessment need to be provided and implemented.

• The Safety Data Sheet isn't the COSHH assessment.

• We have encountered situations where a business has produced a Safety Data Sheet and considered that this dealt with its COSHH obligations. The Safety Data Sheet provides important information about the substance, but the business still needs to consider how the substance is actually used in its workplace and what controls are required.