COSHH Compliance Checklist: Self-Audit Guide for UK Businesses

Why Self-Audit Before the HSE Does It for You

HSE inspectors can visit your workplace without notice. When they do, they follow a systematic approach — checking documentation, observing working practices, and interviewing staff. Businesses that have never self-audited their COSHH compliance are routinely caught out by gaps they did not know existed.

This checklist mirrors what an inspector would look for. Work through it honestly, note the gaps, and fix them. A self-audit that uncovers problems is far cheaper than an improvement notice that gives you 21 days to sort them out under threat of prosecution.

Use our free COSHH Compliance Checker for a quick initial score, then work through this detailed checklist for the full picture.

The Checklist

1. You Have Identified Every Hazardous Substance in Your Workplace

Walk through every area — offices, workshops, kitchens, storage rooms, vehicles, cleaning cupboards — and confirm that every hazardous substance is accounted for. This includes:

Commercial chemical products (cleaners, paints, adhesives, solvents, lubricants)
Process-generated substances (dust, fume, vapour, mist created by your work)
Biological agents (if applicable to your sector)

Common gap: Forgetting process-generated substances. Wood dust, welding fume, flour dust, and silica dust do not come in a bottle but absolutely require COSHH assessment. This is one of the most common mistakes businesses make.

2. You Have a Current Safety Data Sheet for Every Commercial Product

For each commercial chemical product on your list:

You hold an SDS from the manufacturer or supplier
The SDS is the most recent version (check the issue date — if older than 5 years, request an update)
SDSs are stored where relevant staff can access them (not locked in a manager's office)

What the inspector checks: They will pick a product off the shelf and ask to see the SDS. If you cannot produce it within a reasonable time, that is a finding.

3. You Have a Written COSHH Assessment for Every Substance

For each hazardous substance or group of similar substances:

A written COSHH assessment exists
The assessment is specific to your workplace, your tasks, and your products (not a generic template with your name added)
The assessment identifies the specific hazards (H-phrases from the SDS, not just "harmful")
The assessment identifies who is at risk and how (roles, exposure routes, duration)
The assessment documents control measures following the hierarchy of control
The assessment has a named assessor and a date
The assessment has a review date

Common gap: Assessments that list "wear PPE" as the only control measure without considering elimination, substitution, or engineering controls first. The hierarchy of control is not optional — it is a legal requirement.

4. Your Assessments Have Been Reviewed and Are Current

Every assessment has been reviewed within the last 12 months (or more recently if a trigger event occurred)
Reviews are documented — not just a new date on the front page, but a record of what was checked and whether changes were needed
Assessments have been updated following product changes, process changes, or reported symptoms
Previous versions are retained to show review history

What the inspector checks: They will look at the review date. If the last review was two years ago, they will ask what has changed since then — and whether you can demonstrate that nothing required an update.

5. You Follow the Hierarchy of Control

For each assessed substance, verify that your control measures follow the COSHH hierarchy:

You have considered elimination (can you stop using this substance?)
You have considered substitution (can you use a less hazardous alternative?)
Engineering controls are in place where needed (LEV, enclosure, water suppression)
Administrative controls supplement engineering controls (procedures, training, restricted access, signage)
PPE is used as a last resort, not the primary control

Common gap: Jumping straight to PPE without documenting why higher-level controls are not reasonably practicable.

6. Your Engineering Controls Are Maintained and Tested

If you rely on engineering controls (ventilation, extraction, enclosure):

Local exhaust ventilation (LEV) systems are tested at least every 14 months (COSHH Regulation 9)
LEV test records are kept for at least 5 years
Maintenance logs show regular servicing and filter replacement
Workers report faults or reduced performance, and there is a process for acting on reports
Any general ventilation systems relied upon as a control measure are functioning correctly

What the inspector checks: They will ask to see your LEV test certificate. If you rely on LEV and cannot produce a current test record, expect an improvement notice.

7. PPE Is Suitable, Available, and Used Correctly

Where PPE is specified as a control measure:

PPE is appropriate for the specific hazard (e.g., nitrile gloves for solvents, not latex; FFP3 masks for silica dust, not FFP1)
RPE (respiratory protective equipment) users have been face-fit tested for tight-fitting masks, and test records are available
PPE is available in sufficient quantities and correct sizes
PPE is stored properly and inspected for damage before use
Workers have been trained in correct donning, doffing, and disposal
There is a process for replacing worn or damaged PPE

Common gap: Face-fit testing. If your assessment specifies FFP3 masks but your workers have never been face-fit tested, those masks are not a valid control measure.

8. Staff Have Received COSHH Training

COSHH Regulation 12 requires information, instruction, and training for every employee who may be exposed:

All exposed workers have received COSHH training relevant to their role
Training was provided before first exposure (not weeks into the job)
Training covers: the hazards of the substances they work with, the controls in place, how to use PPE correctly, what to do in an emergency
Training records exist (date, content covered, attendees, trainer)
Training is refreshed when products, processes, or assessments change — and at least annually
Agency workers and temporary staff receive the same training as permanent employees

What the inspector checks: They will ask a worker on the shop floor what chemicals they use and what the hazards are. If the worker cannot answer, your training programme has a gap.

9. Health Surveillance Is in Place Where Required

For substances that cause occupational asthma, dermatitis, or other chronic conditions:

You have identified which substances trigger health surveillance requirements (check SDS Section 11)
Exposed workers are enrolled in an appropriate health surveillance programme
Surveillance is carried out by a competent person (occupational health nurse or doctor for lung function testing; trained supervisor for basic skin checks)
Health surveillance records are maintained for at least 40 years
Results are acted upon — workers showing early signs of disease are removed from exposure and referred for medical advice

Common gap: Not realising health surveillance is required at all. Many small businesses assume it only applies to large industrial operations. If your workers handle skin sensitisers, respiratory sensitisers, or carcinogens, check whether surveillance applies.

10. Emergency Procedures Are in Place

Spill response procedures exist for substances where a spill could cause harm
Appropriate spill kits are available and accessible near storage and use areas
First-aid arrangements cover chemical exposure (eyewash stations near corrosive substances, trained first-aiders who know the specific first-aid measures from the SDS)
Workers know what to do in an emergency — not just where the procedures are filed

11. Substances Are Stored Correctly

Hazardous substances are stored in appropriate containers with intact labels
Incompatible substances are separated (acids away from alkalis, oxidisers away from flammables)
Storage areas are ventilated where required
Containers are closed when not in use
No food or drink is stored with chemicals
COSHH storage areas are signed appropriately

Common gap: Decanted substances in unlabelled containers. If you transfer a substance from its original container into a smaller bottle for daily use, that bottle must be labelled with the product name and the key hazard information.

12. Your Chemical Register Is Complete and Current

While not a specific COSHH regulation requirement, a chemical register is the foundation of manageable COSHH compliance:

You maintain a single list of every hazardous substance across your business
Each entry records: product name, supplier, hazard classification, location of use, and whether a current assessment exists
The register is updated when new products are introduced or old ones discontinued
Someone is responsible for maintaining it

13. Assessments Are Accessible to Those Who Need Them

Workers can access the COSHH assessments relevant to their work (at the point of use, not only in the office)
Summaries or key control information are displayed where the substances are used
If you operate multiple sites, each site has access to its relevant assessments
If workers use mobile devices, consider digital access

Scoring Your Self-Audit

Work through each item and mark it as compliant, partially compliant, or non-compliant. Any item marked non-compliant is a priority fix. Partially compliant items need attention but may not require immediate action.

Focus areas by priority:

Fix immediately: Missing assessments for substances currently in use, missing SDSs, no training for exposed workers, required health surveillance not in place
Fix this month: Overdue reviews, incomplete assessments, PPE issues, LEV testing gaps
Fix this quarter: Documentation gaps, storage improvements, register updates, accessibility improvements

Keep Your Compliance Current

A self-audit is only a snapshot. The challenge is maintaining compliance over time as products change, staff turn over, and processes evolve.

COSHHmate is being built to make ongoing compliance manageable — with a guided assessment builder that covers every field on this checklist, a central chemical register that updates automatically, and email reminders before every review date. No more spreadsheets tracking spreadsheets.

Join the waitlist to be first to know when COSHHmate launches.

This checklist provides general guidance based on the COSHH Regulations 2002 and HSE published guidance. It does not constitute professional health and safety advice or a substitute for a competent person's assessment of your specific workplace.