Lucy - BQ Magazine EditorYou probably don’t give much thought to the spray bottle under the kitchen sink. It’s just cleaner. But in a business, the products your team uses every day can create real legal and health responsibilities, and many owners only find out about them when something goes wrong.
The good news is that the rules are manageable once you know what they are. Here’s a plain-English guide.
What COSHH actually asks of you
COSHH stands for the Control of Substances Hazardous to Health Regulations. Don’t let the name put you off. It’s the UK law that says: if a substance used at work could harm someone’s health, you have to understand the risk and control it.
“Substance” covers more than you might think. The Health and Safety Executive (HSE), the government body that oversees workplace safety in Great Britain, gives examples ranging from “paints and cleaners to flour dust”. Your cleaning products are very much included.
The law is about exposure, not the bottle itself. A product can be perfectly safe when used as intended, but still cause harm if it’s mixed too strongly, sprayed into the air as a mist or left on skin all day. So the real question isn’t just what is this product? It’s how do my people come into contact with it?
If you use a cleaning company
Many business owners assume that once a cleaning company is hired, the problem belongs to them. It doesn’t. Here’s what HSE expects:
- The cleaning company needs to know the risks in your building and how you’re controlling them.
- You need to know what they’re bringing in, and how they’ll protect your staff from it.
- Both sides’ arrangements need to fit together. Neither can simply ignore the other.
In short, you can’t hand the whole issue over and forget about it. But you also can’t ignore what’s being used in your building.
The basic steps
HSE breaks the job down into six steps:
- Find out what the health hazards are.
- Decide how to prevent harm to people.
- Put controls in place, and make sure people actually use them.
- Keep those controls working properly.
- Give people information and training.
- Plan for emergencies, such as spills.
Stop the problem at the start
Where you can, reduce the risk at source. Options include:
- Choosing a milder product
- Using water-based rather than solvent-based products
- Swapping a spray for a brush
What “safe enough” means
HSE’s standard is that the risk must be kept “as low as is reasonably practicable”. In plain terms, you take sensible, practical steps to reduce the risk. You don’t have to eliminate it completely, but you can’t skip cheap, easy measures either. Where a workplace exposure limit exists for a substance, exposure must also stay below it.
A practical checklist for business owners
Work through these in order. You don’t need to be perfect on day one, but you should be able to answer each one.
1. Make an inventory
List every cleaning product used on your premises, including anything brought in by contractors. Note where each one is kept and who uses it.
2. Collect the safety data sheets
Suppliers of dangerous products must provide an up-to-date safety data sheet (SDS). It sets out the hazards, handling, storage and emergency measures. Keep them somewhere staff can reach. An SDS isn’t a risk assessment in itself. It’s the information you use to make one.
3. Write a risk assessment
For each product, think about who could be harmed and how (breathing it in, skin or eye contact, swallowing it), how often and for how long people are exposed, what you already do to control it, and what else needs doing, by whom and by when. If you have five or more employees, you must record the assessment. Even with fewer, it’s sensible to write down what you’ve done.
4. Plan storage
Keep products in clearly labelled containers, store them securely and separate incompatible products. HSE’s example is keeping acids and caustics apart.
5. Control dilution and dosing
Use proper dosing equipment rather than guessing measures. Over-strong solutions are a common source of skin and eye problems. This is practical good sense rather than a specific legal rule, but it’s a quick win.
6. Set up clean-up and spill procedures
Have the right equipment to clear up spillages quickly and safely. For dust, HSE recommends a dust-free method: vacuum rather than sweep.
7. Treat PPE as the last line, not the first
HSE says not to reach automatically for personal protective equipment, as it’s less reliable than other controls. Where your assessment shows it’s needed, provide the right kit and make sure people wear it correctly.
8. Train your people
Anyone working with these products, including cleaning and maintenance staff, should understand the risks and the controls, know what to do after a spillage or accident, and know where to find the safety data sheets. Keep basic training records.
9. Review regularly
Check that your controls still work, and update your assessment when you change staff, products, equipment or processes, or after an accident or near miss.
Questions to ask your cleaning provider
If you’re thinking about handing chemical-heavy work to a contractor, such as office, school or factory cleaning, or a builders’ clean, the questions below are a good test. A provider who answers them clearly is usually one who takes the job seriously.
- Which products will you bring on site, and can you send the safety data sheets in advance?
- How have you assessed the risks for our premises, and can we see your written risk assessment and method statement?
- How do you dilute and dose products, and do you use fixed equipment?
- Where will products be stored on our site, and how are they kept separate and labelled?
- What PPE do your staff use, and how are they trained to use it?
- What’s your procedure if there’s a spillage or someone is exposed?
- What insurance do you hold, and at what level of employers’ and public liability cover?
- Are you accredited under any recognised scheme, and can you show evidence?
If you’re looking at local providers, Gloucester Cleaning Solutions is one example of a company you could put these questions to. Their website says every client receives a Risk Assessment and Method Statement, that they hold £10m employers’ and public liability cover, and that they’re SAFE contractor accredited.
Frequently asked questions
Every business is different, so here are a few general answers first, followed by notes for common niches. Jump to the one that fits you.
Do I need a COSHH risk assessment if I only use supermarket cleaning products?
It depends on the product, not on where it came from. COSHH applies to any substance that’s hazardous to health when used at work, and many everyday cleaners carry hazard warnings on the label. Products used as directed, in small amounts and infrequently, often present a low risk, but you still need to check the label and think through how your people use them.
Do I need to write it down?
If you have five or more employees, yes: the risk assessment must be recorded. Even with fewer, writing it down is good practice, because it shows what you looked at and gives you something to review later. A short, clear document is usually enough for a small business.
Is bleach a COSHH issue?
It can be. Bleach (sodium hypochlorite) can irritate or damage skin and eyes at strong concentrations, and it must never be mixed with acid-based or ammonia-based products, as this releases harmful gases. Check the safety data sheet for your specific product and use proper dosing equipment rather than guessing.
For small offices and hybrid teams: Do I still need to think about cleaning products if most of my team works from home?
For small offices and hybrid teams: The products in your kitchen, toilets and store cupboard are still your responsibility whenever people are working on site. Keep the list short: one inventory, a folder of safety data sheets and a simple assessment is good practice. Compare your list with what your cleaner brings on site, so nothing slips through.
For schools and nurseries: Who sets the rules for cleaning products around children?
For schools and nurseries: Staff are covered by COSHH in the same way as any workplace, and products should be stored locked and well out of children’s reach. Child-care settings also have their own registration and safety requirements, which come from your nation’s regulator (Ofsted in England is one example). Ask any cleaning contractor for their risk assessment before they start work.
For factories and workshops: How should I handle stronger cleaners and degreasers?
For factories and workshops: Degreasers, solvents and industrial cleaners are where COSHH matters most, so the full checklist above applies. Focus on controlling exposure at source, such as closed systems, proper dosing equipment and ventilation, before relying on gloves or masks. Check the HSE guidance for your sector to see whether health surveillance is needed for any product.
For landlords and property managers: Should I check the products used in a builders’ clean or handover clean?
For landlords and property managers: If you hire someone for a builders’ clean or a handover clean, ask them for their risk assessment and safety data sheets before they start, just as you would with any contractor. Post-building work often involves dust and harsher products, so it’s worth checking the HSE guidance on construction work as well. The questions in the list above are a good starting point for any handover clean.
For shops and cafés: Does COSHH cover the cleaners my staff use behind the counter?
For shops and cafés: Yes, COSHH applies to the cleaning chemicals your staff handle, so the same inventory, safety data sheet and training steps apply. Food hygiene is a separate regime, though, and rules for surfaces that touch food are set by the Food Standards Agency (or Food Standards Scotland in Scotland). Check their guidance on which products are suitable for food-contact surfaces.
For holiday lets and Airbnb hosts: Do I need a COSHH assessment for my cleaning products?
For holiday lets and Airbnb hosts: Whether COSHH formally applies depends on whether you’re running the let as a business or employing someone to clean, so check the HSE guidance for your situation. Even if it doesn’t formally apply, the same habits are good practice: label products clearly, store them out of guests’ reach and use them at the right strength. If you hire a cleaner, ask them for their product list and assessment.
Keeping it proportionate
COSHH isn’t about being wary of cleaners. As HSE puts it, many substances can harm health but, used properly, they almost never do. The aim is to know what your people are working with and to control it sensibly. A clear inventory, a proportionate risk assessment and an open conversation with your cleaning provider will cover most of what matters, and they give you a proper record if a question ever comes up.
This is general information to help you get started, not legal advice. For your specific situation, check the HSE’s COSHH guidance or speak to a health and safety adviser.