COSHH for cleaning contractors: what the regulations actually require

Every commercial cleaning contractor works with substances that fall under the Control of Substances Hazardous to Health Regulations 2002, usually shortened to COSHH — descalers, degreasers, disinfectants, floor strippers, even some concentrated glass cleaners. The regulations are enforced by the HSE, and most contractors know the acronym well. Fewer could say with confidence exactly what it requires them to have in place, beyond "staff have done the training."

What COSHH actually covers

COSHH isn't a single certificate or a one-off course. It's a duty to assess the risk from hazardous substances used, stored or produced during work, and to control that risk — through the product chosen, how it's used, what protective equipment goes with it, and how it's stored. For a cleaning contractor, that means every chemical in the store cupboard, in theory, sits behind an assessment somewhere.

The assessment, not just the certificate

A training certificate confirms a person has been told about hazardous substances in general. It doesn't, on its own, satisfy COSHH for a specific site and task. What the regulations actually ask for is a written assessment for each hazardous substance in a given use — what it's used for, the risk it poses, the control measures in place, and who's responsible for reviewing it. We've written more on what a COSHH risk assessment for a cleaning task actually needs to contain, because this is usually where the gap between "we did the training" and "we're actually compliant" opens up.

Safety data sheets sit underneath the assessment

Every hazardous product should come with a safety data sheet from the supplier or manufacturer, and that document is what a COSHH assessment is meant to be built on. If the SDS isn't current, isn't on site, or doesn't match the product actually in the cupboard because someone switched supplier eighteen months ago and nobody updated the file, the assessment sitting on top of it is only theoretically accurate. There's a fuller breakdown of what to actually keep on file and where.

Where contractors actually fall down

In practice, the gap is rarely a total absence of COSHH paperwork. It's usually partial: assessments that were done once, correctly, and never touched again.

• –Safety data sheets that don't match what's currently in the cleaning store, because a product was swapped for a cheaper equivalent without anyone updating the file
• –Assessments written for a task in general rather than the specific chemical and site it's actually used on
• –Training delivered once at induction with no refresher, so newer staff have no record at all and longer-serving staff are working from a course several years out of date
• –No clear record of which individual has actually been trained on which substance — a folder of certificates isn't the same as a searchable, current record
• –Storage and ventilation never formally assessed, even where the chemicals themselves are correctly documented

What a client audit tends to ask for

When a facilities client runs a compliance audit, COSHH is one of the first things checked, and it's usually checked by asking for specific documents rather than taking a general assurance at face value: current SDS for products in use on that site, the assessment behind them, and a record of who on the cleaning team has been trained and when. Contractors who can produce this in minutes, rather than promising to "dig it out and send it over," tend to come out of audits looking considerably more in control than the state of their actual practice might otherwise suggest. COSHH training itself is worth getting right for the same reason — a record that's easy to produce is only useful if it's also accurate.

This is a practical summary, not a substitute for HSE's own COSHH guidance, which sets out the legal detail and gets updated from time to time — worth checking directly if you're building an assessment from scratch.