COSHH Regulation and Duties

Employer Duties Under COSHH

The Eight Employer Duties Set Out in the COSHH Regulations

The HSE summarises COSHH as a set of basic measures that every employer must work through, often described as the eight steps or eight duties. They run from assessing the risk through to making sure staff know what to do, and they map neatly onto how a kitchen, bar, or hotel actually handles chemicals. Reading the duties one by one is the easiest way to check whether your business is genuinely compliant or has just produced a document. This article walks through each duty and what it looks like in a hospitality setting.

Key takeaways

COSHH sets out a series of employer duties, commonly described as eight, that run from assessing risk to planning for emergencies.

The first duties are to assess the risk and decide on precautions, which together form the COSHH assessment.

You must prevent or adequately control exposure using the hierarchy of control, then keep those controls working.

Monitoring and health surveillance apply at the margins, such as significant flour dust or confined cellars.

Information, training, and emergency planning turn a written assessment into real protection, and training is the duty most often missed.

Assess the Risk and Decide on Precautions

The first duty is to assess the health risks created by hazardous substances in your business. This is the COSHH assessment itself: identifying every hazardous product and work-generated substance, working out who could be exposed and how, and judging whether your current controls are good enough. The second duty follows directly from the first, which is to decide what precautions are needed. In hospitality the precautions usually centre on substitution where a safer product exists, correct dilution, sensible storage away from food, and the right protective equipment for the people most exposed. These two duties are the foundation, because every other duty depends on knowing what you are dealing with and what you have decided to do about it. An assessment that does not lead to clear precautions has not discharged either duty.

Prevent or Control Exposure and Keep Controls Working

The third duty is to prevent exposure to hazardous substances, or where that is not reasonably practicable, to control it adequately. This is where the hierarchy of control applies: eliminate the substance, substitute a safer one, use engineering controls such as extraction, change the way the work is done, and only then rely on personal protective equipment. The fourth duty is to make sure control measures are used and kept in good working order. A spray system, an extraction canopy, or a stock of gloves only counts as a control if it is actually maintained and used. In practice this means checking that staff dilute correctly, that ventilation is running, and that protective equipment is available and in good condition rather than worn out and ignored.

Monitor Exposure and Carry Out Health Surveillance

The fifth duty is to monitor exposure where the assessment shows it is needed or where a workplace exposure limit applies and you cannot be sure it is being met. The sixth duty is to carry out health surveillance where there is a recognised risk to health that can be detected, such as certain skin or respiratory conditions. Most hospitality businesses will not need formal exposure monitoring, but the duties still matter at the margins: bakeries handling significant flour dust, or sites with confined cellars where carbon dioxide can build up, may need to think about both. The point is to recognise when ordinary controls are not enough and a more active check on exposure or on the health of the people involved becomes necessary.

Provide Information and Training, and Plan for Emergencies

The seventh duty is to give employees the information, instruction, and training they need: what the substances are, the risks, the controls, and what to do if something goes wrong. Training is the duty most often missed, because an assessment locked in the office trains nobody. The eighth duty is to prepare for accidents, incidents, and emergencies, which means having spill procedures, first aid for chemical contact, and clear steps for a gas leak or a major splash. Together these final duties turn a written assessment into something that protects people on the floor. An inspector who finds good controls but staff who cannot explain them, or no plan for a spill, will treat the information, training, and emergency duties as unmet.

What to do next

Audit your business against each duty in turn

Work through the duties one by one and mark which you can evidence, paying particular attention to training and emergency arrangements.

Check that controls are used, not just written

Spot-check dilution, ventilation, and protective equipment so the control duty is met in practice as well as on paper.

Write spill and exposure emergency steps

Set out what staff do for a spill, a splash, or a gas leak, and make sure first aid for chemical contact is in place.

Common mistakes to avoid

Mistake

Doing the assessment but skipping training

Instead

Information and training are a distinct duty. Brief staff on the substances they use and record it, or the assessment protects nobody.

Mistake

Assuming health surveillance never applies in hospitality

Instead

Most sites will not need it, but bakeries with flour dust and operations with confined cellars should consider whether monitoring or surveillance is warranted.

Frequently asked questions

How many duties does an employer have under COSHH?

The HSE describes COSHH as a set of basic measures, usually presented as eight: assess risk, decide precautions, prevent or control exposure, keep controls working, monitor exposure, carry out health surveillance, provide information and training, and plan for emergencies.

What is the most commonly missed COSHH duty in hospitality?

Information and training. Many businesses produce an assessment but never brief staff on the chemicals they use or record that briefing, which leaves the training duty unmet even where controls exist.

Do hospitality employers need health surveillance under COSHH?

Most do not, because their exposure is low and controlled. It becomes relevant at the margins, such as bakeries handling significant flour dust or sites where carbon dioxide can accumulate in confined cellars.

COSHH Regulation and Duties