COSHH Training Checklist for New Starters

Corrected on 2026-08-13: This post previously described COSHH Regulation 12 as "unambiguous" that training "must happen before first exposure". Regulation 12 contains no timing requirement at all — the phrase "before exposure" does not appear in it, or anywhere in the COSHH Regulations 2002. The before-exposure timing has been re-attributed to Regulation 6(1), which requires the steps needed to meet these Regulations to be implemented before the work is carried out, together with the widely-applied HSE expectation. The guidance itself is unchanged. Following re-verification against legislation.gov.uk/uksi/2002/2677/regulation/12 and /regulation/6.

Corrected on 2026-07-02: This post previously stated that COSHH Regulation 12(3) requires training to be repeated at appropriate intervals; in fact 12(3) requires training to be adapted to take account of significant changes in the work, so the refresher section has been reworded, following re-verification against legislation.gov.uk/uksi/2002/2677/regulation/12.

The Legal Requirement: Regulations 12 and 6

COSHH Regulation 12 states the duty plainly: every employer must provide suitable and sufficient information, instruction, and training to employees who may be exposed to hazardous substances. That is not optional.

The timing, though, is not in Regulation 12 — the words "before exposure" appear nowhere in it, or anywhere else in the COSHH Regulations. It comes from Regulation 6(1), which bars an employer from carrying out work liable to expose employees unless he has "made a suitable and sufficient assessment of the risk created by that work to the health of those employees and of the steps that need to be taken to meet the requirements of these Regulations" and "implemented the steps referred to in sub-paragraph (a)". Training is one of those steps. Taken with the widely-applied HSE expectation for induction, that is why training should be delivered before first exposure — not during the first week, not when there is a quiet moment, and not after an incident.

This post deals with the induction case specifically. For the wider picture — refreshers, agency staff, recordkeeping, and whether an online course discharges the duty — see our guide to COSHH training obligations.

The regulation specifically requires that employees are informed about:

The hazards of the substances they will encounter
The findings of the relevant COSHH assessments
The control measures in place and why they matter
How to use PPE correctly
Emergency procedures, including first aid

If a new cleaner starts on Monday morning and handles bleach at 7am without any chemical safety training, you have started work liable to expose an employee without implementing a step Regulation 6(1) required you to have in place first — and the Regulation 12 duty has not been discharged either. It does not matter that you planned to cover it in "next week's induction."

What COSHH Training Must Cover

A proper COSHH induction for new starters should work through these areas, tailored to the specific substances and tasks the employee will encounter.

1. Which substances they will be working with

Name every hazardous substance the new starter will use, be near, or could be exposed to. Show them the actual products and containers. For process-generated substances (dust, fume, vapour), explain where and when these occur.

A cleaner joining a contract cleaning company needs to know about every product on the cleaning trolley. A joinery apprentice needs to understand that the dust from cutting hardwood is a COSHH substance with its own health risks, even though it does not come in a bottle.

2. What the hazards are

Go through the specific hazards for each substance. Use plain language, not just H-phrase codes. "This degreaser is corrosive — it will burn your skin on contact and can cause permanent eye damage if splashed" is training. "It's got H314 on the label" is not.

Show them the product labels and explain the GHS pictograms. If your workplace has a hazard label decoder or reference sheet, point it out.

3. What the controls are and how to follow them

Walk through the control measures from each relevant COSHH assessment:

Engineering controls — show them the ventilation system, demonstrate how to turn it on, explain why it matters
Administrative controls — explain safe working procedures, dilution ratios, which products must never be mixed
PPE — show them where it is stored, how to put it on correctly, when to replace it, and why each item is needed

Do not just hand someone a pair of gloves. Explain that nitrile gloves protect against the specific chemicals they will handle, that latex does not provide adequate protection for some substances, and that gloves must be changed if torn, contaminated, or after a set period.

4. How to use, store, and dispose of substances safely

Cover the practical details:

Correct dilution ratios (measured, not guessed)
Never decant into unlabelled containers
Storage requirements (locked cupboards, separation of incompatible chemicals, temperature limits)
Disposal procedures (never pour chemicals down drains unless the SDS confirms it is safe)

5. Emergency procedures

Every new starter needs to know:

What to do if they get a chemical on their skin or in their eyes
Where the nearest eyewash station or clean water supply is
What to do if they or a colleague breathes in fumes and feels unwell
How to deal with a spill (and when to evacuate rather than attempt to clean it up)
Who to report incidents to

6. Health surveillance (where applicable)

If the new starter will be exposed to substances that require health surveillance — respiratory sensitisers like isocyanates, wood dust, or flour dust, or skin sensitisers like PPD in hair dye — explain what monitoring will happen, how often, and why. Emphasise that reporting early symptoms (skin irritation, persistent cough, breathlessness) is expected and encouraged, not a sign of weakness.

When Training Must Happen

As above, the timing does not come from Regulation 12 — it comes from Regulation 6(1)(b), which requires the steps needed to meet the COSHH Regulations to be implemented before the work is carried out. In practice that means training before the employee is first exposed to the hazardous substance. For most new starters, COSHH training is therefore part of day-one induction.

There are only three defensible approaches:

Pre-employment training — cover COSHH basics before the start date (practical for larger companies with structured onboarding).
Day-one induction — the new starter receives COSHH training as part of their first-day induction, before they begin any work involving hazardous substances.
Task-specific training before each new exposure — if the new starter will not encounter certain substances until later (e.g., a salon trainee who does not handle colour products for the first month), you can phase the training, but it must always come before first exposure.

What does not work: "We will cover it in the team meeting next Thursday." If the employee handles chemicals before that meeting, you have carried out work liable to expose them without first implementing a step Regulation 6(1) required to be in place.

How to Document COSHH Training

Undocumented training is, from a compliance perspective, training that did not happen. An HSE inspector who asks to see your training records will not accept "we told them verbally."

For each training session, record:

Field	Example
Employee name	Sarah Thompson
Date of training	7 May 2026
Trainer name	James Wilson, Operations Manager
Topics covered	COSHH induction: bleach, degreaser, descaler — hazards, controls, PPE, emergency procedures
Substances covered	Thick Bleach (sodium hypochlorite 4.5%), ProClean Degreaser, LimeAway Descaler
COSHH assessments shown	Yes — assessments #001, #004, #007 reviewed with employee
Employee signature	[Signed]
Trainer signature	[Signed]

Keep these records for as long as the employee works for you, plus a reasonable period after they leave. There is no statutory retention period specified in COSHH, but the HSE expects you to demonstrate a history of training provision.

Refresher Training Requirements

Initial training is not a one-off exercise. Regulation 12(3) requires that training be adapted to take account of significant changes in the type of work or methods used, and the HSE expects it to be refreshed so it stays effective. The regulations do not set a fixed refresher interval, but common good practice is:

At least annually as a general rule
Whenever you introduce a new hazardous substance to the workplace
When you change a product, supplier, or formulation (the hazards may have changed)
When you change a work process that affects how substances are used or the level of exposure
After an incident, near-miss, or health complaint related to chemical exposure
When a COSHH assessment is reviewed and updated — affected staff need to know what has changed

Annual refreshers do not need to repeat the full induction. A focused session covering any changes since last year, a reminder of key emergency procedures, and confirmation that controls are being followed is usually sufficient. Document the refresher the same way you document initial training.

Industry-Specific Training Content

The substances and risks vary by sector. Here is what COSHH training should emphasise for common SME industries:

Cleaning companies

Focus on: corrosive products (bleach, degreasers, descalers), correct dilution, never mixing chemicals (bleach + acid = chlorine gas), ventilation in enclosed spaces, glove selection and replacement frequency. See our guide on common COSHH mistakes — chemical mixing and lack of new-starter training are among the most frequent failures.

Hairdressing salons

Focus on: skin sensitisers (PPD in hair colour), respiratory sensitisers (persulphates in bleach powder), wet work dermatitis prevention, glove discipline (nitrile, changed between clients), ventilation at mixing stations, early reporting of skin changes.

Construction and trades

Focus on: silica dust (cutting concrete, stone, brick), wood dust (sanding, cutting), welding fume (see our welding fume COSHH assessment guide), solvent vapours from paints and adhesives, RPE fit testing, LEV use and maintenance.

Manufacturing

Focus on: process-specific chemical hazards, WEL awareness, RPE selection and fit testing, LEV checks, health surveillance schedules, COSHH assessment access points on the shop floor.

Food production

Focus on: flour dust (respiratory sensitiser, WEL of 10 mg/m³ inhalable dust), cleaning chemicals, ammonia in refrigeration systems, enzyme-containing products, bakery-specific asthma risks.

Common Failures Inspectors Find

These are the training-related issues that result in enforcement action:

No training records at all. Verbal training without documentation is treated as no training.
Training after first exposure. "We train them in their second week" is a breach if they handle chemicals in week one.
Generic, non-specific training. A PowerPoint about "chemical safety" that does not reference your actual substances, your actual assessments, or your actual control measures.
No refreshers. Training from 2022 with no evidence of updates since.
Training that ignores process-generated substances. Staff trained on bottled chemicals but not on the dust, fume, or vapour their work creates.

If you are unsure whether your COSHH knowledge covers the basics, our guide to what COSHH is is a useful starting point before designing training for others.

A Practical COSHH Induction Checklist

Use this checklist for every new starter who will be exposed to hazardous substances:

Making Training Manageable

For a small business, COSHH training does not need to be a formal classroom session. A 20-minute walkthrough of the relevant substances, hazards, and controls — done one-to-one by a supervisor who knows the assessments — is perfectly adequate. What matters is that the content is specific, the timing is right (before first exposure), and the record exists.

COSHHmate is being built to keep your COSHH assessments in one place where every team member can access them — which makes induction training straightforward. Show the new starter their relevant assessments on screen, walk through the key points, and record the training. No hunting through filing cabinets or shared drives.

If you want COSHH compliance that does not depend on one person remembering everything, join the waitlist to be first to know when COSHHmate launches.

This is general guidance based on the COSHH Regulations 2002 (in particular Regulation 12) and published HSE guidance. Verify the training requirements for your specific substances and processes against HSE guidance. Not legal or safety advice.