In Brief

The Control of Substances Hazardous to Health Regulations 2002 require employers to provide suitable information, instruction and training about hazardous substances and controls.
A safety data sheet describes supplied-product hazards; it is not the employer’s COSHH assessment or a complete work instruction.
Communication must cover substances generated by work, such as dust and fume, even when no supplier label exists.
Workers need to understand exposure routes, control checks, foreseeable failures and emergency action—not memorise pictograms alone.
Monitoring, health surveillance and worker feedback should be used to test whether the communication system is effective.

Information Is Not the Same as Understanding

Many workplaces can produce a folder of safety data sheets within minutes. Fewer can show that workers understand which substances they encounter, how exposure occurs and what to do when a control fails. A document archive may satisfy a purchasing process while having little effect at the workbench.

Chemical communication succeeds when information changes decisions. A mixer closes a lid before starting. A welder positions extraction correctly. A cleaner refuses an unlabelled bottle. A maintenance worker checks whether residues and reaction products are present before opening equipment.

The American source article framed this subject through OSHA’s Hazard Communication Standard. Great Britain uses a different legal structure. Supply-chain classification and labelling operate through GB CLP and UK REACH, while workplace risk assessment and control are governed principally by COSHH and related regulations.

Establish the UK Framework

The Control of Substances Hazardous to Health Regulations 2002 (COSHH) require employers to assess risks, prevent exposure where reasonably practicable and otherwise control it adequately. Regulation 12 requires suitable and sufficient information, instruction and training for employees who may be exposed.

Information should cover the names of substances, risks to health, relevant workplace exposure limits, significant findings of the assessment, precautions, control use, monitoring and health-surveillance results where appropriate, and emergency procedures. It must be updated to reflect significant changes and adapted to take account of new or changed circumstances.

Suppliers have duties under UK REACH and the Great Britain Classification, Labelling and Packaging regime to provide labels and safety data sheets in applicable circumstances. Northern Ireland follows distinct arrangements for chemical supply, so businesses operating across UK markets should verify territorial requirements.

Lead, asbestos and radioactive substances have specific regimes. Dangerous Substances and Explosive Atmospheres Regulations 2002 may apply to fire and explosion properties. A workplace communication programme should bring applicable duties together rather than imply that COSHH covers every chemical risk.

Build a Reliable Chemical Inventory

The first step is to know what enters, exists within and leaves the workplace. Link each purchased product to its current safety data sheet, supplier, formulation, storage location, typical quantity, use and COSHH assessment. Include maintenance, cleaning, laboratory and contractor products—not only production materials.

An inventory must also identify substances generated by work. Welding fume, hardwood dust, respirable crystalline silica, diesel-engine exhaust, fermentation gases and decomposition products may not arrive in labelled containers. Process knowledge and task observation are essential.

Remove obsolete duplicates and investigate unknown containers. Quarantine products with missing or inconsistent information rather than guessing. Control sample cupboards, trial materials and products brought by contractors through the same approval process.

Assign ownership for additions and changes. Purchasing controls should prevent an unassessed substitution entering use because a usual product is unavailable. Review the inventory against stores and work areas, not solely against accounting data.

Read the Safety Data Sheet Critically

A safety data sheet (SDS) contains 16 structured sections covering identification, hazards, composition, first aid, firefighting, accidental release, handling, exposure controls and other information. It helps employers assess risk, but HSE states explicitly that an SDS is not a risk assessment.

Check that the product identifier and supplier match the container. Confirm the revision date and whether the formulation or classification has changed. Sections on hazard identification and composition help identify concerns, while exposure-control information may support control selection. Emergency sections inform—but do not automatically define—site response.

Supplier recommendations are necessarily general. A glove material listed without thickness, contact type or breakthrough time may not answer the task. “Use adequate ventilation” does not prove that a room fan controls a concentrated release. Seek clarification from the supplier and competent advice where information is incomplete.

Workplace exposure limits in EH40 apply to specified airborne substances in Great Britain. They are not safe-versus-dangerous boundaries, and many substances have no limit. Carcinogens, mutagens and asthmagens require exposure reduced as low as reasonably practicable in addition to relevant adequate-control requirements.

Convert Hazard Information Into a COSHH Assessment

Hazard is the potential to cause harm; risk depends on how exposure occurs. Assess the task, quantity, concentration, physical form, temperature, pressure, frequency, duration, routes and people affected. Consider inhalation, skin and eye contact, ingestion and accidental injection.

Observe routine and non-routine work. Charging, pouring and spraying may differ from cleaning, filter changes, sampling, spill response and maintenance. Reactions can consume the original substance but generate something more hazardous. Assess storage, handling and disposal as well as use.

Identify workers requiring particular consideration, including young workers, pregnant workers and people with relevant health conditions, through appropriate confidential processes. Contractors, visitors and cleaners may encounter hazards without belonging to the production team.

Record the controls, how they work, checks, foreseeable failures and emergency action. A generic assessment copied across products cannot be suitable where volatility, dustiness, corrosivity or control methods differ materially.

Communicate the Hierarchy of Control

Training should explain why elimination or substitution comes first. Removing an unnecessary chemical or selecting a less hazardous form can eliminate reliance on behaviour. Workers should know how to report a possible substitute and why unauthorised substitution is unsafe.

Engineering controls include enclosure, closed transfer, automation, isolation and local exhaust ventilation. Explain the capture principle and visible or instrumented checks. A worker who understands why a hood must remain close to a source is more likely to position it correctly and report weak airflow.

Administrative controls cover access, quantities, sequencing, permits, hygiene and cleaning. They should support engineering measures rather than compensate indefinitely for poor design. Personal protective equipment and respiratory protective equipment manage residual risk and require selection, fit, compatibility, maintenance and training.

Communication should state control limitations. Gloves may protect against splash but not prolonged immersion. A particulate filter does not protect against vapour. A fume cupboard sash position matters. Clear limitations allow workers to recognise when the safe system no longer applies.

Make Labels Useful at the Point of Work

GB CLP labels can include a product identifier, supplier information, pictograms, signal word, hazard statements and precautionary statements. Teach workers to read these elements together. A pictogram alone does not describe severity, exposure or the complete precaution.

Workplace containers and decanted products need clear identification appropriate to the system and risk. Do not use food or drink containers. Standardise labels, avoid unexplained abbreviations and replace damaged information. Fixed pipework and process vessels may use other identification arrangements, which workers and emergency teams must understand.

Labels provide immediate warning, not a safe method. Site instructions should connect the labelled product to the task assessment, required controls and emergency response. Place concise information where workers need it while retaining access to the relevant SDS.

Design Training for Real Decisions

Start with the tasks workers perform. Use the actual containers, controls and equipment. Ask people to identify the release point, demonstrate a pre-use check, select the relevant procedure and explain what they would do after an alarm or spill.

Adapt communication for language, literacy, disability and working environment. Translation may help, but technical accuracy must be checked. Photographs and diagrams can support understanding where they accurately represent the process. Essential information should not exist only in a digital system unavailable during a power or network failure.

Initial training should occur before exposure, with refreshers after significant change and at intervals justified by risk. A repeated annual presentation does not correct a misunderstood control. Supervisors need enough knowledge and authority to observe work and intervene.

Contractors require site-specific information, and host employers need information about contractor substances and processes. Agree responsibilities for assessment, storage, labelling, spills and waste before work begins. Shift handovers should communicate temporary changes and control defects.

Prepare for Accidents and Emergencies

COSHH requires arrangements for foreseeable accidents, incidents and emergencies in applicable circumstances. Plans should identify alarms, isolation, evacuation, spill control, decontamination, first aid, emergency-service information and safe re-entry.

Do not train every worker to tackle every spill. Define limits for local response and when to withdraw. Spill kits, RPE and chemical protective clothing require correct selection and competence. Unknown or escalating releases may require specialist assistance.

Exercise scenarios involving an unlabelled container, failed extraction, splash or incompatible mixture. Verify that workers can locate current information and that eyewash, showers and communications remain available.

Verify Understanding and Control

Attendance records show who was present, not what they understood. Use practical demonstration, questions, observation and worker consultation. Investigate recurring errors as possible weaknesses in design, information or supervision rather than automatically blaming individuals.

Exposure monitoring can test defined uncertainties and confirm whether controls perform under representative work. Health surveillance may be required where COSHH criteria are met. Explain relevant results to workers and use them to review the assessment.

Audit inventory accuracy, SDS currency, workplace labels, training coverage, control checks and corrective actions. Review after new substances, changed formulations, process modifications, incidents, symptoms or evidence that instructions are not being followed.

Sysco Environmental can support COSHH assessment and workplace exposure monitoring where chemical information must be converted into defensible control decisions. Monitoring should answer a defined question, not substitute for understanding the process.

Workers have been properly informed when they can recognise the hazard, use and check the controls, explain limitations and act safely when conditions change. The objective is not a complete folder. It is reliable understanding at the point of exposure.

Do Your Workers Understand the Chemicals They Use?