TivloYou have the COSHH folder. It is in the van, or in the office, or somewhere. The data sheets are in there. Your supervisor knows where it is. That is fine, until you have a serious chemical incident on a client's site, a health and safety inspection, or a tender process that asks for evidence of your COSHH management system.
COSHH (Control of Substances Hazardous to Health) is one of the most misunderstood areas of compliance for cleaning company owners. Most businesses do the minimum. Most think the minimum is enough. It is not, and the gap between "having a COSHH folder" and "being COSHH compliant" is where claims, prosecutions, and contract losses happen.
What COSHH Actually Requires
COSHH regulations (Control of Substances Hazardous to Health Regulations 2002) apply to any business that exposes employees to hazardous substances in the course of work. For cleaning companies, that means virtually every day, at every site.
The regulations require employers to:
- •Assess the risk from hazardous substances used or encountered at work
- •Control exposure: use alternative substances if possible, use appropriate PPE, implement safe working procedures
- •Ensure controls are used: and are maintained and functioning
- •Monitor exposure where there is a risk of serious harm
- •Carry out health surveillance where required
- •Prepare plans and procedures for accidents and emergencies
- •Ensure employees are trained on the hazards and the controls
The folded sheet of chemical data sheets in a ring binder addresses about one tenth of that list.
The Records You Need to Keep
COSHH compliance is not just about having the right products or the right PPE. It is about demonstrating (with records) that you have assessed the risks, that your staff understand them, and that appropriate controls are in place.
COSHH risk assessments. For every hazardous substance used across your operations (cleaning chemicals, disinfectants, descalers, solvents) you need a documented risk assessment. This should cover what the substance is, what harm it can cause, how it is used, and what controls are in place to manage the risk. Generic assessments from a product supplier are a starting point, not a finished document. Your assessment needs to reflect how the product is actually used at your sites.
Site-specific risk assessments. A risk assessment for a multi-storey office building is not the same as one for a school, a food processing facility, or a medical centre. The ventilation, the occupancy, the sensitivity of the environment, and the specific tasks being performed all affect the risk. Site-specific assessments are not always legally mandatory for every contract, but they are expected on anything above basic commercial premises.
Training records. Every operative who uses hazardous substances must be trained on the specific risks and controls relevant to their work. That training needs to be documented: who was trained, on what, when and by whom. BICSc and COSHH-specific training from providers like the British Cleaning Council or the BICS eLearning platform are commonly used, but internal induction training is also acceptable if it is properly documented.
PPE issuance records. If your operatives use gloves, goggles, aprons, or masks, you need a record of what was issued, to whom, and when. This includes replacements. If an operative is using chemical X and their gloves split, and you have no record of PPE issuance or replacement, you are exposed.
Incident records. Any chemical incident (a spillage, a skin reaction, a splash) must be logged and investigated. What happened, who was affected, what action was taken, what changed as a result. Even near-misses should be recorded. This not only satisfies regulatory requirements, it demonstrates a functioning safety culture.
Common Failures and Why They Matter
Most enforcement action and civil claims in cleaning relate to the same failings.
Generic risk assessments that do not reflect actual practice. If your risk assessment says operatives use diluted chemical at a ratio of 1:50, and your supervisor is using it neat because it works faster, the risk assessment is fiction. In the event of an incident, that gap will be found, and it will be your liability.
Training records that cover induction but nothing else. Staff who joined three years ago may have had COSHH induction. But have they been retrained when you introduced new products? When the site requirements changed? When they moved to a new contract type? Training is not a one-time event.
No process for incidents. A member of staff gets a chemical splash on their skin, washes it off, carries on. Nothing is logged. Two weeks later they develop a skin condition. There is no record of the incident, no record of the substance, no record of the PPE that was in use. This is a completely avoidable situation that becomes very difficult to defend.
Inaccessible records. A COSHH folder in a van is not accessible to the operative working the early shift alone. Product data sheets should be available at every site where chemicals are used, and staff should know where to find them.
What Good COSHH Management Looks Like in Practice
It is not complicated. It is consistent.
Every site has a set of chemicals in use. Each one has a current risk assessment. Every operative working at that site has read and understood the assessments relevant to their work, and that is recorded. PPE is checked, issued, and replaced on a documented schedule. Any incident is logged and reviewed. Risk assessments are reviewed when products change or when site conditions change.
That is COSHH compliance. Not a folder. A system.
For most cleaning businesses, the challenge is not understanding what needs to happen: it is keeping up with the records across multiple sites and a mobile workforce. The information gets created but not stored. The training happens but is not logged. The incident is reported verbally but never written down.
Building a Compliant Foundation
COSHH compliance is not the most glamorous part of running a cleaning company. But a serious chemical incident, an HSE inspection, or a contract audit can expose everything that is missing, and at that point, "we do train our staff, we just don't write it down" is not a defence.
If you want to understand how your current health and safety processes compare to what commercial clients and regulators expect, our scorecard gives you an honest read on where the gaps are.