Food Safety Hazards

Cleaning Chemical Hazards in Food Businesses: COSHH & HACCP

Managing Cleaning Chemical Hazards Under COSHH and HACCP

Every food business uses cleaning chemicals, from washing-up liquid and surface sanitiser to industrial degreasers, oven cleaners, and drain unblockers. These chemicals are essential for maintaining hygiene, but they are also chemical hazards in their own right. Under HACCP, chemical residues on food contact surfaces or in food itself constitute a chemical hazard that must be controlled. Under the Control of Substances Hazardous to Health Regulations 2002 (COSHH), employers must assess the risks from hazardous substances and implement controls to protect workers. Getting chemical management right requires addressing both the HACCP and COSHH angles.

Key takeaways

Cleaning chemicals are both a COSHH obligation and a HACCP chemical hazard.

Every chemical in your premises must have a safety data sheet and a COSHH risk assessment.

Follow manufacturer dilution rates exactly. Overconcentrated solutions leave harmful residues on food contact surfaces.

All spray bottles and decanted chemicals must be clearly labelled with product name and hazard information.

Store chemicals in a dedicated area, separate from food, and never above food preparation surfaces.

COSHH Requirements for Food Businesses

COSHH requires every employer to assess the risks from hazardous substances used in the workplace and implement appropriate controls. For food businesses, this means: obtaining safety data sheets (SDS) for every chemical product used, conducting a COSHH assessment for each substance (covering hazards, exposure routes, who is at risk, and control measures), providing appropriate personal protective equipment (PPE) such as gloves and eye protection, training staff on safe handling, dilution, and first aid, and storing chemicals in a dedicated, locked or restricted area away from food and food preparation surfaces. COSHH assessments must be reviewed regularly and whenever a new product is introduced. Many food businesses fall short on COSHH compliance, particularly smaller operations that buy chemicals from cash-and-carry without requesting SDS documents. An Environmental Health Officer or HSE inspector can ask to see your COSHH assessments at any time.

Chemical Residues as a HACCP Hazard

In your HACCP hazard analysis, chemical residue from cleaning products on food contact surfaces is a chemical hazard at the preparation and service stages. The control measures are: using only food-safe cleaning and sanitising products on surfaces that will contact food, following manufacturer dilution rates (stronger is not better and can leave harmful residues), rinsing surfaces with clean water after using chemicals unless the product is specifically rated as "no-rinse" at the stated dilution, and allowing surfaces to air-dry or wiping with a clean, chemical-free cloth before food preparation begins. Particular care is needed with spray bottles. Mislabelled or unlabelled spray bottles are a common finding during inspections. Every spray bottle must be clearly labelled with the product name, dilution rate, and hazard warnings. Decanting chemicals into unlabelled containers is a COSHH violation and a food safety risk.

Storage, Separation, and Spill Management

Cleaning chemicals must be stored separately from food, food packaging, and food preparation areas. Use a dedicated, lockable cupboard or store room. Keep chemicals in their original containers wherever possible. If decanting is necessary (for diluted solutions), label the container immediately and clearly. Never store chemicals above food or food contact surfaces where a leak or spill could contaminate food. Separate incompatible chemicals (for example, bleach and acidic cleaners should never be stored together as mixing produces toxic chlorine gas). Have a spill kit available and train staff on how to respond to chemical spills. If a chemical spill occurs in a food preparation or storage area, remove all exposed food, clean up the spill according to the SDS guidance, and verify the area is safe before resuming food handling. Document the incident.

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What to do next

Collect safety data sheets for every chemical

Request the current SDS from the manufacturer or supplier for every cleaning product, sanitiser, and chemical used in your business. Store them in an accessible folder (physical or digital) that staff can reference.

Audit all spray bottles and containers

Walk through your premises and check that every spray bottle, bucket, and container holding a chemical is clearly labelled with the product name, dilution rate, and hazard pictograms. Replace or relabel any that are not compliant.

Review chemical storage for separation compliance

Confirm that all chemicals are stored away from food, below food storage (not above), and that incompatible chemicals (bleach and acids) are separated. Install a lockable chemical cupboard if you do not already have one.

Common mistakes to avoid

Mistake

Using a higher concentration of sanitiser "for extra safety"

Instead

Overconcentrated sanitiser leaves chemical residues on food contact surfaces. Follow the manufacturer dilution rate precisely. More is not better with chemical sanitisers.

Mistake

Storing cleaning chemicals in the kitchen near food

Instead

Chemicals must be stored in a separate, dedicated area. Even sealed containers can leak. A chemical stored on a shelf above open food is a contamination risk waiting to happen.

Frequently asked questions

Do I need COSHH assessments for washing-up liquid and hand soap?

Technically, COSHH applies to any substance that could be hazardous to health. For very low-risk products like standard hand soap, a brief assessment noting that the risk is minimal is sufficient. However, for concentrated sanitisers, oven cleaners, degreasers, and any product with hazard symbols on the label, a full COSHH assessment is required. In practice, it is simpler to assess everything and demonstrate a systematic approach.

What should I do if a chemical product is used on a food contact surface by mistake?

Remove all food from the affected area. Clean the surface thoroughly with clean water and a food-safe detergent to remove the chemical residue. Check the SDS for any specific decontamination instructions. Do not use the surface for food preparation until you are satisfied the residue has been completely removed. Discard any food that may have been contaminated. Document the incident and review your procedures to prevent recurrence.

Can I use bleach in a food business?

Sodium hypochlorite (bleach) is widely used in food businesses for sanitisation, particularly for norovirus decontamination. However, it must be used at the correct dilution, surfaces must be rinsed thoroughly with clean water after application (unless using a food-safe no-rinse formulation), and it must never be mixed with acidic products. Many food businesses prefer to use proprietary food-safe sanitisers that are specifically formulated for food contact surfaces.

Food Safety Hazards