Table of Contents:
Walk through any production floor, and the physical hazards are usually obvious—moving machinery, forklifts, or high-voltage cabinets. But some of the most dangerous risks in your facility are the ones you can’t always see. Fumes from welding, dust from sanding, or vapours from cleaning solvents don't just cause immediate injury; they are often the silent culprits behind long-term occupational illnesses like asthma, dermatitis, and even cancer.
Managing these invisible threats isn't just about "health and safety gone mad" or ticking boxes for an auditor. It is about legal compliance and, more importantly, keeping your workforce alive and healthy.
Under the Control of Substances Hazardous to Health Regulations 2002 (COSHH), failing to adequately assess these risks is a crime punishable by unlimited fines. Yet, many maintenance teams still treat COSHH as a paperwork exercise rather than a critical operational safety protocol.
At its core, a COSHH assessment is a "suitable and sufficient" evaluation of the risks created by work involving substances that are hazardous to health.
It is the foundation of chemical safety in the workplace, serving as the bridge between a dangerous substance and a safe worker. However, there is a critical distinction that many maintenance managers miss.
It Is Not Just a Safety Data Sheet (SDS)
There is a widespread misconception in the industry that simply having a folder full of Safety Data Sheets (SDS) constitutes compliance. It does not.
You must understand the difference:
Collecting data sheets is data entry; a COSHH assessment is risk management.
Regulation 6 of the COSHH Regulations is explicit: An employer must not carry out work liable to expose employees to hazardous substances without a valid risk assessment.
This is not a suggestion—it is a prerequisite for operation. If you haven't assessed the risk, you legally cannot start the work.
A valid assessment does not just cover the moment a technician pours a chemical. It must cover the entire lifecycle of the substance within your facility:
If you only assess the "usage" phase, you are leaving your logistics and waste management teams unprotected and your operation non-compliant.
A comprehensive assessment is investigative work. You cannot simply identify the chemical; you must investigate how it interacts with your people and your environment. To ensure your assessment is "suitable and sufficient," you must evaluate these four core elements.
This is the most critical distinction in safety management. You must separate the inherent properties of the substance from the likelihood of an accident.
You must identify exactly how the hazardous substance enters the body. In maintenance operations, there are four primary routes:
The environment changes the risk profile. Using a solvent in a well-ventilated workshop is very different from using the same solvent inside a tank. You must consider:
A standard assessment assumes a healthy, adult male. You must specifically consider if the work involves:
Not every hazardous substance falls under COSHH. Knowing exactly what is covered—and what isn't—ensures your compliance strategy is efficient and legally accurate.
COSHH covers virtually any substance that can harm health when used in the workplace. This includes substances used directly in work activities (like paints, cleaning agents, and solvents), but the scope goes much deeper.
It includes substances in various forms:
Some substances are so dangerous or specific that they have their own dedicated regulations. While the principles of safety are similar, you do not assess these under COSHH:
The first step is to leave your desk and physically walk the floor to identify exactly what substances are present in your facility. You cannot rely solely on purchasing records, as this misses "stray" chemicals left in cupboards or by-products like dusts and fumes created during maintenance tasks. You must collect the Safety Data Sheets (SDS) for every identified substance and verify they are up-to-date (ideally less than 3 years old) to understand the specific hazards involved.
Once hazards are identified, you must determine who is being exposed and to what extent, paying special attention to non-routine maintenance activities. It is not enough to know a chemical is toxic; you need to know if your team is handling it for five minutes once a month or four hours every day. Remember to include everyone who might enter the area, not just the primary operator, as cleaners, contractors, and maintenance staff often face higher exposure levels during breakdowns or deep cleans.
This step involves comparing your current working conditions against legal safety standards to decide if existing precautions are adequate. You need to check if the exposure levels are kept below the Workplace Exposure Limits (WELs) published by health and safety authorities. If your current control measures—such as general ventilation or standard operating procedures—do not reliably bring exposure below these limits, the risk is unacceptable, and immediate action is required to improve safety.
When controlling risk, you must follow the "Hierarchy of Control," starting with the most effective measures and only using PPE as a last resort. Your goal is to remove the danger entirely rather than simply protecting the worker from it; for example, swapping a toxic chemical for a safe one is far better than asking a worker to wear a mask. Personal Protective Equipment (PPE) should only be relied upon after all other technical and organizational measures have been applied and residual risk remains.
Recording your assessment is not just best practice; it is a legal requirement if you employ five or more people. The record must be clear, concise, and easily accessible to all employees, serving as a live document rather than a secret file. This documentation provides proof of compliance to inspectors and serves as a vital training tool for new staff, ensuring everyone understands the risks and the mandatory precautions before starting work.
A COSHH assessment is a living document that must be revisited whenever changes occur in your operation or workforce. It is dangerous to assume that an assessment made five years ago is still valid today, as machinery ages, processes evolve, and new chemicals are introduced. You must establish a regular review schedule and immediately reassess risks if there is an incident, ensuring that your safety measures evolve alongside your business operations.
Even seasoned plant managers can fall into compliance traps. A COSHH assessment is only effective if it reflects reality. Avoiding these five common pitfalls will ensure your safety strategy actually protects your team.
This is the single most common failure in the industry. Many organizations believe that simply keeping a folder of Safety Data Sheets (SDS) constitutes a COSHH assessment.
It is easy to assess the chemicals you buy, but easy to forget the ones you create. "By-products" are hazardous substances generated during work processes that do not come in a labelled bottle.
Using a generic assessment downloaded from the internet or copying one from a different site is a dangerous shortcut.
Personal Protective Equipment (PPE) is often the first thing managers reach for, but legally and practically, it must be the last resort.
Standard assessments often focus on production operators who have a fixed routine, ignoring the people who support the operation.
COSHH is a dynamic process, not a static document. It requires a cultural shift from "compliance" to "care"—moving away from doing it because the law says so, to doing it because you want your team to retire healthy.
Modern maintenance management systems like Cryotos can bear the heavy lifting of this compliance. By integrating safety checklists, digital SDS access, and mandatory risk acknowledgments into the daily workflow, you ensure that safety isn't an afterthought—it's part of the job.
