COSHH Regulations: The Complete UK Guide for Construction and Security Professionals

Every year, thousands of UK workers develop serious health conditions from exposure to hazardous substances at work. From silica dust on construction sites to cleaning chemicals in commercial buildings, the risks are real and the legal obligations are clear. The Control of Substances Hazardous to Health Regulations 2002 (COSHH) exist to prevent these outcomes, and if you employ people or manage sites in the UK, compliance is not optional.

This guide breaks down exactly what COSHH regulations require, who they apply to, how to carry out a proper COSHH assessment, and what happens when organisations get it wrong.

Key Takeaways

• COSHH stands for the Control of Substances Hazardous to Health Regulations 2002, the primary UK legislation governing workplace exposure to hazardous substances.
• All UK employers must assess and control risks from hazardous substances. This includes construction firms, security companies, facilities managers, and the self-employed.
• There are 8 key steps to achieving COSHH compliance, from risk assessment through to training and review.
• Penalties are severe: unlimited fines, criminal prosecution, and even imprisonment for serious breaches.
• COSHH assessments are distinct from general risk assessments but should be integrated into your RAMS (Risk Assessment Method Statements) documentation.
• Construction sites are high-risk environments for hazardous substance exposure, with silica dust, cement, solvents, and asbestos among the most common dangers.
• Documentation and record-keeping are legal requirements, not just best practice. Records must be kept for at least 5 years (40 years for personal health surveillance records).

What Are COSHH Regulations?

COSHH stands for the Control of Substances Hazardous to Health Regulations 2002. Introduced under the Health and Safety at Work etc. Act 1974, COSHH is the primary piece of UK legislation that requires employers to control substances that are hazardous to health.

The regulations are enforced by the Health and Safety Executive (HSE) and apply across all industries in England, Scotland, and Wales. They have been amended several times since 2002, with updates in 2004 reinforcing workplace exposure limits (WELs).

In practical terms, COSHH requires employers to:

• Identify all hazardous substances used or produced in the workplace
• Assess the risks those substances pose to workers and others
• Prevent or control exposure using a hierarchy of control measures
• Monitor workplace exposure levels where necessary
• Provide health surveillance for employees exposed to certain substances
• Train and inform all employees about the risks and the controls in place

COSHH does not cover lead (governed by the Control of Lead at Work Regulations 2002), asbestos (governed by the Control of Asbestos Regulations 2012), or radioactive substances. These have their own dedicated regulations, though the principles of risk assessment and control remain similar.

What Substances Does COSHH Cover?

COSHH applies to a broad range of substances that can cause harm to health. These include:

• Chemicals used at work, such as adhesives, paints, solvents, and cleaning products
• Substances generated by work processes, including dust, fumes, and vapours (for example, welding fumes or wood dust)
• Naturally occurring substances, such as grain dust or silica
• Biological agents, including bacteria and other micro-organisms

A substance is considered hazardous to health if it is listed as dangerous for supply under the Classification, Labelling and Packaging (CLP) Regulation, has a workplace exposure limit (WEL) listed in the HSE's EH40 publication, is a biological agent, or is any kind of dust at concentrations exceeding permitted levels.

Currently, WELs are assigned to around 500 hazardous substances in the UK, published in HSE document EH40/2005 (Workplace Exposure Limits).

Hazardous Substances Commonly Found on Construction Sites

Construction is one of the highest-risk sectors for COSHH-related health problems. Common hazardous substances include:

Substance: Silica dust — Source: Cutting, drilling, or grinding concrete, stone, and brick — Health Risk: Silicosis, lung cancer, COPD

Substance: Cement — Source: Wet cement and cement dust — Health Risk: Dermatitis, burns, respiratory irritation

Substance: Wood dust — Source: Sawing, sanding, and machining timber — Health Risk: Asthma, nasal cancer

Substance: Welding fumes — Source: Arc welding, gas cutting — Health Risk: Lung disease, metal fume fever

Substance: Solvents and adhesives — Source: Paints, thinners, glues, resins — Health Risk: Liver and kidney damage, dermatitis, neurological effects

Substance: Asbestos fibres — Source: Demolition and refurbishment of older buildings — Health Risk: Mesothelioma, asbestosis, lung cancer

Substance: Isocyanates — Source: Spray paints, foam insulation — Health Risk: Occupational asthma

Substance: Lead — Source: Old paintwork, lead-based materials — Health Risk: Organ damage, neurological effects

The HSE estimates that occupational lung disease kills approximately 12,000 people per year in the UK, many of them in construction. Silica dust alone contributes to hundreds of new silicosis cases annually.

Hazardous Substances in the Security and Facilities Management Sector

While security and facilities management may seem lower risk than construction, COSHH still applies. Common exposures include:

• Cleaning chemicals: Bleach, ammonia, descalers, and industrial degreasers used during cleaning operations
• Disinfectants and sanitisers: Particularly prevalent since COVID-19 increased sanitisation requirements
• Biological agents: Security and FM staff may encounter needle-stick injuries, bodily fluids, or contaminated waste
• Fumes and vapours: Staff working in car parks, loading docks, or near plant rooms may be exposed to diesel exhaust or chemical fumes

Even if your organisation does not manufacture or directly use these substances, you are still responsible for assessing and controlling your employees' exposure to them.

Who Needs to Comply with COSHH?

COSHH applies to virtually every employer in the UK. Specifically:

• All employers who use or produce substances hazardous to health in their work activities
• Self-employed individuals who use hazardous substances
• Anyone who controls a workplace where hazardous substances may be present (including principal contractors on construction sites under CDM 2015)

Under Regulation 3 of COSHH, the duties apply to any substance that is hazardous to the health of any person, not just employees. This means you must also consider the exposure of contractors, visitors, members of the public, and anyone else who may be affected by your work.

In construction, this is especially relevant. Principal contractors have a duty under both COSHH and the Construction (Design and Management) Regulations 2015 to ensure that all work on site is properly planned, managed, and monitored, including work involving hazardous substances.

The 8 Steps of COSHH Compliance

The HSE outlines a clear framework for achieving COSHH compliance. These 8 steps form the backbone of any effective COSHH management system.

Step 1: Assess the Risks

Regulation 6 of COSHH requires a suitable and sufficient assessment of the risks to health from hazardous substances before any work begins.

Your assessment must:

• Identify all hazardous substances present or likely to be produced
• Determine who might be exposed and how (inhalation, skin contact, ingestion)
• Evaluate the level, type, and duration of exposure
• Consider the effects of combined exposure to multiple substances
• Review Safety Data Sheets (SDS) provided by manufacturers and suppliers

If you employ five or more people, you must record the significant findings of your assessment in writing. Even if you employ fewer, documenting your assessment is strongly recommended as evidence of compliance.

Practical tip: On a construction site, walk the site and list every substance used or likely to be encountered, from ready-mix concrete additives to the degreaser in the site compound. Check Safety Data Sheets for each product, which suppliers are legally required to provide.

Step 2: Decide What Precautions Are Needed

Based on your assessment, determine what control measures are necessary to prevent or adequately control exposure. The precautions you select must follow the hierarchy of control:

1. Eliminate the hazardous substance entirely
2. Substitute with a less hazardous alternative
3. Enclose the process to prevent release
4. Use engineering controls such as local exhaust ventilation (LEV)
5. Implement administrative controls (safe systems of work, reduced exposure times)
6. Provide PPE as a last resort

PPE should never be your first or only line of defence. COSHH specifically requires that you prevent exposure where reasonably practicable, and only resort to controlling exposure when prevention is not possible.

Step 3: Prevent or Adequately Control Exposure

Regulation 7 is the core obligation: you must either prevent your employees from being exposed to hazardous substances, or, where prevention is not reasonably practicable, adequately control their exposure.

Exposure is considered adequately controlled only if:

• Any relevant Workplace Exposure Limit (WEL) is not exceeded
• For carcinogens, mutagens, and asthmagens, exposure is reduced to as low as reasonably practicable (ALARP), regardless of whether a WEL exists

WELs are expressed as time-weighted averages (TWA):

• Long-term exposure limit (LTEL): maximum average concentration over 8 hours
• Short-term exposure limit (STEL): maximum average concentration over 15 minutes

Step 4: Ensure Control Measures Are Used and Maintained

Under Regulations 8 and 9, employers must:

• Ensure all control measures are properly used by employees
• Maintain all control equipment in efficient working order and good repair
• Carry out thorough examination and testing of engineering controls (such as LEV systems) at specified intervals, typically every 14 months
• Keep records of examinations and tests for at least 5 years

Employees also have a duty to use control measures correctly, report defects, and return equipment after use.

Step 5: Monitor Exposure

Regulation 10 requires exposure monitoring where:

• The risk assessment identifies it as necessary
• There is a risk that WELs may be exceeded
• It is needed to verify that control measures are working

Monitoring might involve atmospheric sampling, personal exposure monitoring, or biological monitoring. Records of monitoring results must be kept for at least 5 years (or 40 years if they relate to identifiable individuals).

Step 6: Carry Out Health Surveillance

Regulation 11 requires health surveillance where employees are exposed to substances linked to specific diseases or adverse health effects. This includes:

• Workers exposed to silica dust (lung function tests)
• Workers exposed to isocyanates (respiratory questionnaires)
• Workers handling cement regularly (skin checks for dermatitis)
• Workers exposed to known carcinogens

Health surveillance records must be kept for 40 years from the date of the last entry. Employees have the right to access their own health records.

Step 7: Prepare Plans and Procedures for Accidents, Incidents, and Emergencies

You must have procedures in place to deal with:

• Accidental spills or releases of hazardous substances
• Failure of control measures
• Emergency situations where exposure levels could spike

This is especially critical on construction sites where multiple trades work simultaneously, and a spill or dust event in one area can affect workers across the site.

Step 8: Ensure Employees Are Properly Informed, Trained, and Supervised

Regulation 12 requires that anyone who may be exposed to hazardous substances receives adequate information, instruction, and training. This should cover:

• The nature of the hazardous substances they may encounter
• The risks to their health and how these are assessed
• The control measures in place and how to use them
• The results of any exposure monitoring (in a non-identifiable form)
• What to do in an emergency
• The purpose and importance of health surveillance

Training must be reviewed and updated whenever there is a significant change in the work, the substances used, or the control measures in place. On construction sites, this often means providing site-specific COSHH briefings during induction and whenever new substances are introduced.

COSHH Assessment vs General Risk Assessment: What Is the Difference?

A common source of confusion is the relationship between COSHH assessments and general risk assessments. While they share some similarities, they serve different purposes:

General Risk Assessment: Focus — COSHH Assessment: All workplace hazards (slips, trips, falls, manual handling, etc.) — Specifically hazardous substances

General Risk Assessment: Legal basis — COSHH Assessment: Management of Health and Safety at Work Regulations 1999 — COSHH Regulations 2002

General Risk Assessment: Scope — COSHH Assessment: Broad task-based assessment — Substance-specific assessment

General Risk Assessment: Documentation — COSHH Assessment: Risk rating matrices, control measures — Safety Data Sheets, WELs, health surveillance needs

General Risk Assessment: Review triggers — COSHH Assessment: Changes to work activity — New substance introduced, monitoring results, health surveillance findings

A COSHH assessment is not a substitute for a general risk assessment, and vice versa. Both are required where hazardous substances are present. In practice, your COSHH assessments should feed into your wider RAMS documentation to ensure a comprehensive approach to workplace safety.

How COSHH Relates to RAMS Documents

If you work in construction or security, you will be familiar with RAMS (Risk Assessment Method Statements). RAMS are the standard documents used to plan safe systems of work, and they are routinely required by principal contractors before anyone sets foot on site.

COSHH assessments should be integrated into or referenced by your RAMS. Here is how they fit together:

• Your risk assessment (the "RA" in RAMS) should identify hazardous substance exposure as a hazard for any task that involves them
• Your method statement (the "MS" in RAMS) should detail the step-by-step controls, including the COSHH hierarchy of control measures
• A separate, detailed COSHH assessment should be produced for each hazardous substance or group of substances, and cross-referenced in the RAMS
• Safety Data Sheets for all substances should be available on site and referenced in the documentation

For example, if your RAMS covers "concrete cutting", the risk assessment section should identify silica dust as a hazard. The method statement should specify wet cutting methods, LEV requirements, RPE specifications, and dust suppression measures. A supporting COSHH assessment should detail the silica WEL, exposure monitoring requirements, and health surveillance obligations.

This integrated approach ensures that COSHH compliance is embedded in your day-to-day operations rather than treated as a separate paperwork exercise.

Producing thorough, regulation-compliant RAMS that properly address COSHH requirements is one of the most time-consuming tasks in construction health and safety management. AI-powered RAMS tools can significantly reduce this burden while ensuring nothing is missed.

COSHH Documentation and Record-Keeping Requirements

COSHH compliance is not just about doing the right thing on site. You also need to prove it through proper documentation. The regulations require:

What You Must Record

• COSHH risk assessments (mandatory if you employ 5+ people, strongly recommended for all)
• Details of control measures implemented and their rationale
• Exposure monitoring results (kept for at least 5 years; 40 years for individual records)
• Health surveillance records (kept for 40 years)
• Maintenance and testing records for engineering controls like LEV systems (kept for 5 years)
• Training records showing who was trained, when, and on what

What to Include in a COSHH Assessment Record

A well-documented COSHH assessment should contain:

1. The substance name and its hazard classification
2. How it is used in your workplace (including quantities and frequency)
3. Who is potentially exposed and how (route of exposure)
4. The Workplace Exposure Limit (if applicable)
5. Information from the Safety Data Sheet
6. Control measures in place (following the hierarchy)
7. Monitoring and health surveillance arrangements
8. Emergency procedures for spills or overexposure
9. Review date and reviewer details

Safety Data Sheets

Manufacturers and suppliers must provide a Safety Data Sheet (SDS) for any hazardous product. The SDS contains 16 sections covering everything from hazard identification to disposal considerations. However, an SDS is not a COSHH assessment. It provides the raw information you need to carry out your own workplace-specific assessment.

You should keep current SDS documents for every hazardous substance on your site, readily accessible to all workers who may be exposed.

Penalties for Non-Compliance with COSHH Regulations

Breach of COSHH regulations is a criminal offence in the UK. The consequences are serious and can affect both the organisation and individual managers or directors.

Fines

Since the introduction of the Sentencing Council's Health and Safety Offences guidelines in 2016, fines have been calculated based on the seriousness of the offence and the turnover of the organisation. There is no upper limit on fines for health and safety offences:

• Minor breaches can result in fines of tens of thousands of pounds
• Serious breaches regularly attract fines of hundreds of thousands to millions of pounds
• The largest HSE fine in 2025 was £6 million
• Large corporations can face fines proportional to their annual turnover

Criminal Prosecution and Imprisonment

For the most serious breaches, particularly where negligence leads to death or serious injury:

• Company directors and managers can be personally prosecuted under Section 37 of the Health and Safety at Work etc. Act 1974
• Individuals found guilty of gross negligence can face imprisonment
• Corporate manslaughter charges may apply in the most extreme cases

Other Consequences

Beyond fines and prosecution, non-compliance can lead to:

• HSE Improvement Notices: requiring you to take specific action within a set timeframe
• HSE Prohibition Notices: immediately stopping work until the issue is resolved (this can halt an entire construction project)
• Civil claims: employees who develop health conditions due to COSHH failures can bring personal injury claims, often resulting in significant compensation payouts
• Reputational damage: prosecution details are published on the HSE's public register and frequently reported in trade press
• Loss of contracts: many principal contractors and clients now require evidence of COSHH compliance as part of their prequalification processes (such as CHAS, SafeContractor, and Constructionline)

The message is clear: the cost of compliance is always less than the cost of getting it wrong.

Practical Steps for Improving COSHH Compliance

Whether you are starting from scratch or strengthening an existing system, here are practical steps to improve your COSHH compliance:

1. Carry Out a Substance Inventory

Walk your site or workplace and create a comprehensive list of every hazardous substance used, stored, or produced. Include products used by subcontractors. Collect Safety Data Sheets for each.

2. Prioritise Your Assessments

Start with the highest-risk substances: those used most frequently, in the largest quantities, or with the most severe health effects. Carcinogens, asthmagens, and substances with WELs should be assessed first.

3. Use the Hierarchy of Control

For each substance, work through the hierarchy systematically. Can you eliminate it? Substitute it? Enclose the process? Only when you have exhausted higher-level controls should you rely on PPE.

4. Integrate COSHH into Your RAMS Process

Do not treat COSHH as a separate system. Ensure every RAMS document that involves hazardous substances references the relevant COSHH assessment and specifies the controls.

5. Train Your Team

COSHH training is not a one-off event. Deliver training during induction, when new substances are introduced, and at regular refresher intervals. Make sure workers understand not just the rules, but the reasons behind them.

6. Monitor and Review

Set clear review dates for every COSHH assessment. Review immediately if there is a change in the work process, a new substance, an incident, or health surveillance findings. COSHH compliance is an ongoing process, not a one-time exercise.

Frequently Asked Questions About COSHH Regulations

How often should COSHH assessments be reviewed?

There is no fixed legal frequency, but the HSE recommends reviewing COSHH assessments whenever there is a significant change in the work, the substances used, or the control measures. In practice, most organisations review annually at a minimum, or whenever a new substance is introduced to the workplace.

Do I need a COSHH assessment for every product I use?

You need a COSHH assessment for every hazardous substance, but you can group similar substances or activities together in a single assessment where the risks and controls are the same. For example, you might have one assessment covering "solvent-based paints" used in a specific process.

Is COSHH training a legal requirement?

Yes. Regulation 12 of COSHH explicitly requires employers to provide adequate information, instruction, and training to anyone who may be exposed to hazardous substances. This includes temporary workers and contractors.

What is the difference between a WEL and an OEL?

WEL (Workplace Exposure Limit) is the UK-specific term used in the COSHH Regulations. OEL (Occupational Exposure Limit) is the broader term used across the EU. Since Brexit, the UK uses WELs as published in HSE document EH40.

Can I be prosecuted as an individual, not just as a company?

Yes. Under Section 37 of the Health and Safety at Work etc. Act 1974, if a health and safety offence is committed with the consent or connivance of a director, manager, or similar officer, that individual can be prosecuted personally.

How swiftRMS Helps with COSHH Compliance

Managing COSHH obligations alongside CDM 2015, HASAWA, Work at Height Regulations, and all the other legislation that applies to your work is a significant administrative burden, especially when you are producing RAMS documents for every task on site.

swiftRMS uses AI to generate comprehensive, regulation-compliant RAMS documents in minutes rather than hours. Every RAMS produced by swiftRMS automatically considers relevant legislation, including COSHH 2002, and identifies hazardous substance risks specific to the task being assessed.

Here is how swiftRMS supports your COSHH compliance:

• Automatic hazardous substance identification: The AI identifies COSHH-relevant hazards based on the task description, flagging substances like silica dust, solvents, and welding fumes that need specific controls
• Built-in hierarchy of control: Every RAMS follows the correct hierarchy, from elimination through to PPE, ensuring your documentation reflects best practice
• Legislation references: COSHH regulation numbers and requirements are embedded directly into the output, so your RAMS documents demonstrate regulatory awareness
• Consistency across teams: Whether it is your most experienced H&S officer or a site supervisor producing the RAMS, the quality and compliance level remains the same
• Time savings: Teams using swiftRMS report cutting RAMS production time by up to 80%, freeing up time for the on-site supervision and monitoring that COSHH actually requires

COSHH compliance is ultimately about protecting people's health. The paperwork exists to support that goal, but it should not consume all of your time. By automating the documentation process, you can focus more energy on the controls, monitoring, and training that make the real difference.

[Try swiftRMS free](https://app.swiftrms.co.uk/signup) and see how AI-powered RAMS generation handles COSHH compliance for your next project.

This guide was last updated in February 2026. COSHH regulations are subject to change, and you should always verify current requirements with the HSE's official COSHH guidance and seek professional advice for your specific circumstances.