The short answers to the COSHH questions people actually ask. No, you do not need a separate assessment for every product. No, the supplier’s safety data sheet is not a COSHH assessment. Yes, an office with cleaning products is in scope. And no, there is no legal expiry date on a COSHH assessment.
Everything below is the practical layer — the questions that come up once you already know what COSHH is. For the fundamentals, start with what is COSHH.
Assessments
Do I need a separate COSHH assessment for every single product?
No — and doing so is the most common way businesses end up with an unusable folder of 200 assessments nobody reads.
COSHH assesses tasks, not bottles. If ten cleaning products are used in the same way, in the same place, with the same controls and the same exposure, they can sit within one assessment. Conversely, a single product used two very different ways — sprayed in a confined space versus wiped on a cloth — needs both scenarios assessed, because the exposure is not the same.
Can I just use the supplier’s safety data sheet?
No. An SDS describes the substance in general. A COSHH assessment describes your use of it: how much, how often, by what method, in what space, with what ventilation, and who is nearby.
The SDS is an input to the assessment — sections 2, 8 and 11 especially. It is not the assessment. Filing SDSs and calling it COSHH compliance is one of the most frequent findings inspectors make.
Do I have to write it down?
If you employ five or more people, the significant findings must be recorded. Below that, recording is not compulsory — but you must still be able to show a suitable and sufficient assessment was made, which in practice means writing it down anyway.
How often must assessments be reviewed?
COSHH sets no fixed interval. It requires review regularly, and immediately if there is reason to suspect it is no longer valid or if the work has changed significantly.
Annual review is the common convention. Always review after a new substance, a process change, an incident, a monitoring result, or a change in who does the work.
Who is allowed to write a COSHH assessment?
Anyone competent — which means having the knowledge, skills and experience for the substances and processes involved, not a specific qualification. For straightforward cleaning chemicals, a trained supervisor is usually fine. For complex processes, fume, or carcinogens, you may need occupational hygiene support. Awareness-level training alone does not make someone competent to write assessments.
Scope — what’s in and what’s out
We’re an office. Does COSHH apply to us?
Yes. Cleaning products, toner, correction fluid and washroom chemicals are all substances hazardous to health. The assessment will be short and simple, but “we’re only an office” is not an exemption.
Does COSHH apply to hand sanitiser and cleaning wipes?
If the product is classified as hazardous — most alcohol gels are classified as flammable, and many disinfectants are irritant — then yes, it is in scope. In most workplaces the risk is low and the assessment is brief. Note that flammability itself falls under DSEAR rather than COSHH; COSHH covers the health effects.
Is asbestos covered by COSHH?
No. Asbestos has its own regime under the Control of Asbestos Regulations 2012. Lead and radioactive substances are likewise excluded from COSHH and covered by their own regulations.
What about dust with no hazard label?
Still COSHH. Regulation 2 catches dust of any kind at 10 mg/m³ inhalable or 4 mg/m³ respirable as an 8-hour average — no label required. See COSHH and dust.
Does COSHH cover fire and explosion risk?
No — that is DSEAR. A solvent that is both toxic and flammable is subject to both sets of regulations, and one assessment does not discharge the other.
Controls and PPE
Can we just issue gloves and masks?
Not as the primary control. Regulation 7 requires exposure to be prevented where reasonably practicable, then controlled by elimination, substitution, engineering controls and safe systems of work. PPE is the last resort. Reaching for it first is the single most common COSHH failing.
Are any gloves fine?
No. Glove material must match the substance — nitrile, latex, neoprene and butyl all resist different chemicals, and breakthrough time matters. The SDS usually specifies a material and thickness. The wrong glove can be worse than none, because it holds the chemical against the skin.
Does a beard stop a mask working?
For tight-fitting RPE, yes. A seal cannot be achieved through stubble or a beard — that is physics, not policy. Options are being clean-shaven where the seal contacts the face, or using loose-fitting powered respiratory protection. Tight-fitting RPE also requires face-fit testing for each individual wearer.
How often must extraction be tested?
Local exhaust ventilation must be thoroughly examined and tested at least every 14 months, more often for certain processes. Records kept five years. See employer duties.
What if an employee refuses to use the controls?
Employees have a legal duty under Regulation 8 to use control measures and report defects. But before treating it as a discipline matter, check the obvious: is the PPE uncomfortable, the wrong size, or does it make the job impossible? Refusal is frequently a design problem wearing a behaviour costume.
Monitoring, health and records
Do we have to do air monitoring?
Only where the risk assessment shows it is needed, where you cannot otherwise show controls are adequate, or for substances and processes listed in Schedule 5. Most low-risk workplaces never need it.
How long must records be kept?
- Health surveillance records — 40 years from the last entry
- Personal exposure monitoring relating to identifiable people — 40 years
- Other monitoring records — 5 years
- LEV examination reports — 5 years
Is health surveillance the same as a medical?
No. Health surveillance looks for specific effects of specific exposures — skin checks for dermatitis, lung function for respiratory sensitisers. It is not a general health check, and its purpose is catching harm early enough to act.
Training and enforcement
Does COSHH training expire?
Not in law. Three years is the common convention. Refresh whenever substances, processes, controls or people change. See COSHH training: what’s legally expected.
What happens if we get it wrong?
Enforcement by the HSE or local authority: improvement notices, prohibition notices stopping the work, and prosecution under the Health and Safety at Work etc. Act 1974 with unlimited fines. Individual managers can be liable as well as the business. Civil claims for occupational asthma, dermatitis or silicosis can follow decades later.
What do inspectors look at first?
The assessments, and whether they match what is actually happening on the floor. Then the LEV test report, training records, and whether PPE is doing work that engineering controls should be doing.
Further reading
COSHH training
Our COSHH Awareness course covers substances hazardous to health, exposure routes, hazard pictograms, the hierarchy of control and what an assessment involves.
Related reading: What is COSHH? · How to do a COSHH risk assessment · COSHH symbols explained · COSHH and dust
£9 per course. CPD accredited, 100 % online, verifiable e-certificate on completion. Pay for 2, get 3 — any 3 courses for £18.
Please note: this is a CPD-accredited awareness course and general information, not legal advice. It is not an Ofqual-regulated qualification. Awareness training does not make someone competent to write COSHH assessments for complex processes — take competent advice where needed, and always check your employer’s and scheme’s specific requirements.