Can anyone help?
I am a facilities representative at a large hospital. Our contract cleaners store their cleaning chemicals on our premises. Who needs to undertake the COSHH Assessment & who needs to be trained in their use?
Answers and solutions:
The Control of Substances Hazardous to Health (COSHH) Regulations 1999 require employers to undertake assessments of any hazardous substances they or their employees use in the course of their work activities.

This includes any chemical products used for cleaning purposes, where they are classified as hazardous by the display of a 'Hazchem' sign. These small pictorial signs can often be seen both in the domestic and working environments, identifying products as 'Harmful', 'Irritant' or 'Flammable', for example. They are the small black-on-yellow signs on the label showing the hazard that the particular product represents.

Most chemical cleaning products represent some hazard to health. Often this is low risk, and can be suitably controlled by straightforward measures.

COSHH assessments are intended to identify the hazards associated with each individual product. A question often asked is why manufacturers cannot provide the COSHH assessments for their products. The answer is quite simple — the COSHH assessment undertaken by the employer must have regard to the type of use of the product and any other factor that may affect the level of risk that the use of the product presents.

For example, bleach may be used by one company to clean toilets where another may use it to clean inside kettles and coffee cups — two tasks which differ significantly in the hazard they present to the cleaner and the end user.

In the example raised by the question, the responsibility to undertake the COSHH assessments would be that of the person employing the cleaning staff (the contract cleaning company). The COSHH assessments should be undertaken for each product used, and should identify the hazards associated with the product. They should also identify the type of use and should highlight suitable control measures to manage the risk of injury or ill-health associated with the product. These could include training staff, safe ways of using the product and the provision and use of personal protective equipment (PPE) such as gloves or goggles.

The question notes that the contract cleaners store the chemicals at the hospital. The contractor therefore also has a responsibility to identify in the COSHH assessment where and how the products are to be stored, and to consider any risks this poses to visitors to the hospital and other staff. The assessment needs to highlight the necessary control measures the contract cleaning staff should adopt.

In addition, as the products are to be stored at the hospital, the contract cleaning company should make the COSHH assessments available to the hospital. If a spillage occurs and needs to be cleared by hospital staff in the absence of the contractors, the COSHH assessments may hold information that the hospital needs to ensure the clearance is undertaken safely.

In terms of training responsibilities, the contract cleaning company should undertake the training of all of their own staff on each of the products. In addition, if it can be reasonably anticipated that hospital staff may have need to come into contact with the products then they may also require training. However, it is the responsibility of the hospital to identify and arrange this training.

The hospital has a responsibility under the Health and Safety at Work Act 1974 to ensure it employs contractors who are competent to undertake work on its behalf. Part of fulfilling this responsibility would be for the hospital to ensure that COSHH assessments have been undertaken by the contract cleaners and that they are suitable and sufficient.