COSHH compliance starts with knowing what you've got on site

If you manage a building (a school, a care home, a leisure centre, a factory floor), there's a reasonable chance you're already thinking about COSHH. You know the regulations exist. You've probably got folders somewhere. Maybe a spreadsheet. Maybe a binder in a cupboard that someone started five years ago and hasn't quite kept up.

The Control of Substances Hazardous to Health Regulations 2002 are one of those compliance obligations that sit across almost every sector and almost every kind of premises.¹ Most premises managers have some form of COSHH management in place; the challenge is rarely awareness. It's making the work hold together under scrutiny.

What COSHH actually demands

The headline obligation is simple: if your staff work with or around substances that could harm their health, you need to assess that risk, control it, and be able to demonstrate you've done both.

In practice, COSHH compliance involves a cycle of obligations. You need a register of hazardous substances on site. You need to assess the risks each one poses. You need storage and control measures that are documented, accessible, and actually followed. You need Safety Data Sheets (SDS) from your suppliers, and those need to be available to the people who might need them. You need to train staff on the risks and what to do. If something goes wrong (a spillage, an exposure incident, an injury), you need to be able to tie the substance involved back to everything you know about it.

If you employ five or more people, the significant findings of your assessments must be recorded in writing. That's a legal requirement, not optional guidance.²

The register problem

Here's where most organisations run into trouble. COSHH isn't a one-time task. Substances change. New products come in. Staff turn over. The SDS that arrived with a delivery three years ago gets filed, or it doesn't. The control measures you wrote up get separated from the substance record they belong to.

What you end up with is a picture of compliance that looked complete at some point, and probably isn't anymore.

This matters across sectors. A school site manager is dealing with science lab reagents, cleaning chemicals, and art materials, and probably expects that information to be accessible to anyone who needs it, including cover staff who don't know where the folder lives. A care home has disinfectants, biological agents, and medicines in the mix. Facilities managers in commercial or industrial settings are often handling the most complex chemical inventories of any sector, with the highest turnover of products and suppliers.

The common thread is the register: the single, current list of what's on site, what it is, and what to do with it. That's often the weakest link.

Folders, spreadsheets, and missing links: the COSHH picture when the register has drifted from reality

Introducing Hazardous Materials in CalmCompliance

We've just added a Hazardous Materials register to CalmCompliance, and it's designed specifically to address this.

Each material gets its own record on your site: name, classification, description, supplier contact details, storage and control measures, and safety recommendations. Those last two matter most for COSHH: they're where the documented outputs of your assessment live, per substance, without getting split off from the record itself.

You can attach Safety Data Sheets directly to each entry. SDS are the foundation of any COSHH assessment, and keeping them attached to the substance record rather than in a separate filing system means they stay current and connected.

A few things that make this practical rather than just tidy:

QR codes on the floor. Every material gets a stable QR code you can print and attach to a cabinet, shelf, or container. Scan it and you get the full record on a mobile-friendly page: classification, storage guidance, SDS download, supplier contact. No login. For staff who need information in the moment, that's the difference between finding it and not finding it.

Incident linkage. When an incident involves a hazardous substance, investigators can link directly to the relevant material record as part of the investigation. That ties what happened to everything you know about the substance (its properties, its controls, its SDS) instead of a free-text description that may or may not match your register.

Bulk QR printing. From site settings, you can select multiple materials and generate a print run of QR codes in one go. Useful when you're labelling a new storage area or doing a periodic audit of your signage.

Hazardous materials, SDS, and controls in one register you can actually use

One register, actually used

The reason so many COSHH registers fall out of date is that they're disconnected from the work. They exist in a folder or spreadsheet that people consult when they're building the register, and then rarely again.

Attaching QR codes to physical locations means the register gets consulted every time someone needs information about a substance. Linking to incidents means it gets referenced when something goes wrong. That ongoing use is what keeps a register accurate: gaps show up instead of staying hidden.

COSHH compliance is ultimately about being able to show, at any point, that you know what's on site, that you understand the risks, and that you've put the right controls in place. A register that people actually use is what makes that possible.

Hazardous Materials is available now as part of the Risks module in CalmCompliance. If you'd like to know more about how it fits into your compliance setup, get in touch.

References

¹ HSE, Control of Substances Hazardous to Health Regulations 2002 (as amended). The regulations apply to virtually all substances hazardous to health across all sectors and employer sizes, with limited exceptions (asbestos, lead, and radioactive substances each have their own separate regulations). https://www.hse.gov.uk/coshh/

² COSHH Regulations 2002, Regulation 6. All employers must carry out a suitable and sufficient assessment of the risks from hazardous substances. Those employing five or more employees must record the significant findings of that assessment in writing, in a form accessible to safety representatives and inspectors. https://www.hse.gov.uk/coshh/basics/assessment.htm