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February 5, 2014

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Five common CoSHH mistakes


Phil Chambers BSc CMIOSH, Strategic Safety Systems Ltd

Over the years, I have seen a range of assessments of substances hazardous to health. Some pose problems, so here are five common mistakes and what you need to do to avoid them.

Mistake 1 — A collection of datasheets

I sometimes go into companies and the management says: “Here’s our CoSHH file.” You look at it and find that it is just a collection of (often incomplete) datasheets.

What you are required to do is assess the risks from each substance depending upon how you use it in your workplace, then put appropriate measures in place to control the risk. Finally, you have to verify that those control measures work.  And don’t just go by what you’ve bought recently; open up cupboards and see what might be lurking.

Mistake 2 — A perfect set of CoSHH assessments sitting on the shelf

The next mistake is to have a perfect set of CoSHH assessments in a pristine folder, while people on the shop floor don’t know anything about them.

A thick manual full of assessments and datasheets on the shop floor is not a workable solution, so I promote the practice of having summaries at the point of use. These state how the substances are to be used and the emergency measures to take in the event of an incident. You also have to talk to people about these instructions. It is best practice to involve them when coming up with the control measures in the first place — that way they are more likely to buy into them.

Mistake 3 — Getting distracted by trivia

I have seen control measures for a carcinogen lost in a collection that included Mr Sheen (with separate assessments for Original and Pot Pourri). If you assess every substance on your site, then apart from the effort involved, you will end up with an unworkable system where the critical substances are masked by the trivial ones.

It is critical that people using substances believe that following the control measures is a necessity. If they are asked to follow measures that they regard as silly, it can devalue the whole approach. By all means cover yourself by listing substances that are low risk, but don’t clog up the main system.

Another way of making it controllable is to group substances together. For example, printing inks for a particular type of printing process are generally the same, irrespective of their colour. So just have one assessment for conventional litho inks, another for digital inks. Don’t have one for magenta, one for cyan, etc.

Mistake 4 — Failure to follow the hierarchy of control measures

There is a hierarchy of control measures you need to follow, with elimination/substitution at the top of the list and PPE at the bottom. Often, people put effort into the middle and lower order control measures and never consider substitution. Where a substance is an inherent part of your process, substitution may be unrealistic. But there are plenty of solvents and cleaning substances in use where less hazardous alternatives are available.

To aid management commitment, I use a colour coding system of:

  • green — no effect;
  • amber — short-term effect, such as solvents which cause light-headedness on inhalation over-exposure;
  • red — medium/long term effect such as corrosive substances which burn the skin or cause permanent eye damage; and
  • purple — long term effects such as carcinogens.Once you have a colour code, agree a policy of working towards the green end of the colour coding, starting by attempting to remove purple substances, with KPIs of how many of each colour have been removed.

Mistake 5 — unrealistic use of personal protective equipment (PPE)

People on the shop floor need to “buy into” the practices around hazardous substances. One good way of defeating this is to require staff to wear PPE for everything.  A substance may irritate to the eyes, but so is soap, and you don’t wear goggles when you wash your face. You want to make sure that people wear eye protection when handling a substance that has a serious risk of eye damage.

Datasheets tend to recommend PPE, even when there is no effect.  What the supplier has to address in his datasheet is all possible uses of the substance. What you have to do is to assess the outcome based on what you do and take appropriate steps. The two may not be the same and your PPE requirements need to suit the latter.

With all risk control measures, the emphasis should be on effectiveness and implementation.  If you avoid the above pitfalls, you can be well on the road to achieving good control of substances hazardous to health in your workplace.

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stephen whyles

very informative, and common sense approach.

scott Maitland
It is good advice when you are in control of your own processes, people and environment. Many of us though are constrained by the requirements of a client when on their site. They often have a ‘no common sense’ approach and therefore expect us to have one! PPE for everything, substituting over the top controls for short term work ,(I have been told to use fixed scaffold for a 10 minute job..honest!, the reason being, “if it can be done, it should be done.”) I have had to produce CoSHH assessments for oxygen..! (Seriously..) Those of us with more enlightened… Read more »
Roland Neal CMIOSH

An excellent passage. All too often I have experienced the same problem from employers / clients where they think that COSHH assessments are the data sheets. To anyone with limited knowledge of COSHH this is an educational piece of information. It is amazing that here we are in 2014 and the original legislation came into force in 1988 with many still not sure what COSHH is about.

Paul Cookson

Very useful information with a sensible usable approach.


Please don’t dismiss Oxygen. (after all you’d consider oxidising agents?) The old trick of welders (oxy-acetylene) working in enclosed areas, sweetwening the air by venting oxygen can be disasterous. Consider every substance and ask – can it cause significant hazard, – is that hazard likely to occur – only if yes to both then document and mitigate.

Paul Forsythe

Excellent summary. I particularly like the colour-coding idea. The variable quality of SDS, confusion with COSHH and who they are written for was discussed at a meeting I attended yesterday

Michael Ellerby

Pertinent points made in the article – nicely done.

People do seem to make heavy weather of COSHH, with a fear of “Chemicals” rather that a consideration of hazards and controls. Too often the assessment is little more than an antiquated collection of SDSs. I prefer a (where appropriate) a process or operational approach rather than a substance by substance battle against the odds.

Chris G

And don’t forget chemicals react and you may not have an off the shelf SDS for the reaction product which could propose different hazards to the original materials. (Example: silica solid + hydrofluoric acid aqueous soln gives off Silicon trtraflouride. Toxic gas)

Phil Chambers

Thanks for the comments, guys. Very much appreciated. Like the comment on reaction products. Hydrofluoric acid itself is one of the worst substances with which I have had to work. See for the fatality in Western Australia; poor sod took 15 days to die. (I was working with HF in Melbourne at the time.)

Jan Moore

A great article Phil. Colour coding is an excellent idea.

I agree entirely with the focus on medium to high risks but still pull my hair out at the idea of writing pages of information (that no-one will bother to read) about such things as Fairy Liquid!

Clive Booth

I completely agree. I have seem much of the same. Refreshing to see it written down

Ernie Taylor CMIOSH

A really good piece Phil, written plainly and succinctly and useful to Line Managers and Supervisors.

Bob Kennedy
When with the HSE I called upon a Demo job with a Major Stake Holder. (Drug Manufacturer) Nosing about, I came accross brown jars with yellow Skull & Crossbone warning markers on them, about 20, 5 litre containers. They were neatly placed within a room due to be demolished. Adjacent walls were alreading knocked down on the concrete floor, along with huge steel doors. (An indication perhaps of the severe nature of chemiclals housed within?) When I enquired why they were still present, I was informed by the Site Agent and Foreman that they were empty? And when I asked… Read more »
Paul Preston

Good aticle, sensible and practicle. I also like the colour coding idea, visual aids usually help.

john H

Whilst it is clear that there ius still (after all these years) confusion surrounding COSHH, just how much will there be when REACH asks everyone to dublicate (in spades), what we have already done since 1988, thanks to Bureaucratic EU Overkill??

In the words of the fa,ous American: “You ain`t seen nothin` yet!”

Still, crats, wherever they are employed never learn “Easy or Uncomplicated”!

Excellent article. I’m working towards all of the best pracise in this piece, and particulary like the colour coding but I’ve been asked by my HSE Director to make sure all SDS’s we are holding are no older than 3 years. This is difficult as checking suppliers websites, their SDSs can be 5 years old or older. We hold mineral oils whcih are not re-ordered often so the correesponding SDS is the same age as the substance. I think this is right – it mateches what we have. Later versions of SDSs for the product may not reflect excatly what… Read more »
Lynda Gornall
Sue from Looe – The company I work for also require MSDS’s to be no more than three years old. I worked at a new site that we took over where a large number of the MSDS’s were dated in the 1990’s. In a lot of these data sheets there was one common factor being that the first aid instructions said to induce vomiting if swallowed, whereas now this is recognised as being very dangerous as the substance can do just as much damage on the way back up as it did on the way down. If you notice now,… Read more »
Dave Ripley

The summary at point of use is a good idea. Also the points on PPE over use are well made.