10 Common COSHH Mistakes Small Businesses Make

The Mistakes That Get Businesses in Trouble

Most small businesses are not deliberately cutting corners on COSHH. They just do not realise what they are getting wrong until an inspector points it out — or worse, until someone gets hurt.

Here are the 10 most common mistakes, with practical advice on fixing each one.

1. Not Having COSHH Assessments at All

The most basic failure: knowing you use hazardous substances but never writing the assessment down. Verbal knowledge does not count. "We all know how to handle bleach" is not a COSHH assessment.

Fix: Start with your highest-risk substances and work through them one at a time. Our step-by-step guide walks you through the process. Five substances assessed this week is better than zero substances assessed perfectly next month.

2. Using Generic Templates Without Customisation

Downloading a template from the internet and filling in your company name is not a COSHH assessment. Inspectors can spot a generic copy instantly — the giveaway is usually control measures that do not match your actual workplace.

Fix: Use templates as a starting point for structure, but every field must describe your workplace, your products, and your tasks. If the template mentions "local exhaust ventilation" and you do not have any, do not leave it in.

3. Forgetting Process-Generated Substances

COSHH does not only cover bottled chemicals. If your work creates dust, fume, vapour, or mist, those are COSHH substances too:

Wood dust from cutting and sanding
Welding fume from MIG, TIG, or stick welding
Flour dust in bakeries
Silica dust from cutting concrete, stone, or brick
Diesel exhaust in warehouses or depots

Fix: Walk through your workplace and think about what substances your processes create, not just what you buy. If someone is breathing it in, it probably needs assessing.

4. Missing or Outdated Safety Data Sheets

Your COSHH assessment is only as good as the information it is based on. If your SDS is from 2015 and the product has been reformulated since then, your assessment may be wrong.

Fix: Request current SDS documents from every supplier. Most now provide them online. Check the issue date — if it is more than 5 years old, ask for an update. Keep your SDS collection organised and accessible (not buried in a filing cabinet nobody opens).

5. Not Reviewing Assessments

A COSHH assessment is not a one-off task. Regulation 6(3) requires you to review your assessments regularly and whenever circumstances change. The HSE's Approved Code of Practice (L5) recommends reviewing at least annually as a general rule. An assessment from 3 years ago that nobody has looked at since is a compliance failure.

Triggers for review:

Annual review date reached
You change products, quantities, or suppliers
You change your work process or equipment
Someone reports health symptoms
An incident or near-miss occurs
New information about the substance becomes available

Fix: Set review dates on every assessment and put a system in place to track them. A calendar reminder works for 5 assessments. For 20+, you need something more reliable — like automatic email reminders (coming soon from COSHHmate).

6. Relying on PPE as the Only Control

"Wear gloves" is not a COSHH strategy. PPE is the last line of defence in the hierarchy of control, not the first. If your assessment lists PPE without considering elimination, substitution, engineering controls, or administrative measures, it is not following the regulations.

The hierarchy of control, in order of effectiveness:

Eliminate the substance
Substitute with something less hazardous
Engineering controls (ventilation, enclosure)
Administrative controls (procedures, training, restricted access)
PPE (gloves, goggles, respirators)

Fix: For every substance, ask: "Can we stop using this? Can we use a safer version? Can we ventilate better?" before jumping to "give everyone gloves."

7. Not Training Staff Before Exposure

COSHH regulation 12 requires you to provide information, instruction, and training to employees who may be exposed to hazardous substances. This means before they start the work, not during their first week on the job.

Common failures:

New starters handling chemicals on day one with no training
Training given but not recorded
Training given once and never refreshed
Training that covers PPE but not the actual hazards

Fix: Add chemical safety to your induction process. Document what was covered, when, and who attended. Refresh training whenever you change products or procedures, and at least annually.

8. No Chemical Register

A chemical register is not technically a legal requirement under COSHH, but it is almost impossible to manage your assessments without one. How do you know which substances you are using, where, and whether each one has a current assessment?

Fix: Create a single list of every hazardous substance in your business. For each one, record: product name, supplier, hazard classification, where it is used, and whether it has a current COSHH assessment. This is your chemical register. Keep it in one place, not scattered across spreadsheets on different computers.

COSHHmate is being built to manage your chemical register automatically as you add substances — read more about what a chemical register should include.

9. Ignoring Health Surveillance Requirements

Certain substances require you to put exposed workers under health surveillance. The most common triggers in small businesses are:

Respiratory sensitisers (isocyanates, wood dust, flour dust) — require lung function testing
Skin sensitisers (PPD in hair dye, epoxy resins, cement) — require skin checks
Substances with specific medical surveillance (lead, certain pesticides)

Many small businesses either do not know health surveillance is required or assume it only applies to large factories.

Fix: Check Section 11 of the SDS for each substance. If it mentions sensitisation, occupational asthma, or occupational dermatitis, health surveillance is likely required. The HSE's health surveillance guidance has the detail.

10. Keeping Assessments Where Nobody Can Find Them

Your COSHH assessments are useless if the people who need them cannot access them. An assessment locked in the office manager's filing cabinet does not protect the cleaner working at a client site at 6am.

Fix: Make assessments accessible to every worker who could be exposed. Options: pin summaries near the point of use, keep a site folder with all relevant assessments, or use a digital system where staff can look up any assessment on their phone.

The Cost of Getting It Wrong

HSE enforcement action is not theoretical. The HSE's annual prosecution statistics show that businesses are regularly fined for health and safety failures, with COSHH-related prosecutions resulting in penalties from several thousand pounds to six-figure sums depending on the severity of the breach. And those are just the cases that reach court — improvement notices and prohibition notices are far more common.

Beyond fines, a worker developing occupational asthma or dermatitis because of inadequate COSHH controls can lead to civil compensation claims, increased insurance premiums, and the loss of good employees.

Getting COSHH right is cheaper than getting it wrong. Use our COSHH Cost Calculator to see what your business spends on manual compliance.

Start Fixing These Today

Pick the mistake that applies most to your business and fix it this week. If you do not have assessments at all, start with your top 3 most hazardous substances. If you have assessments but have not reviewed them, pick the most overdue one and update it.

COSHHmate is being designed to prevent most of these mistakes by default — the guided builder will cover every required field, the chemical register will be built automatically, and review reminders will arrive by email so nothing slips. Join the waitlist to be first to know when COSHHmate launches.