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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Handling and Disposal of Hazardous Substances Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} complies with all relevant legislation, guidance and regulatory requirements relating to the procurement, handling, use, storage and disposal of hazardous substances and hazardous waste. This includes (but is not limited to): the Control of Substances Hazardous to Health (COSHH) Regulations 2002 (as amended); the Health and Safety at Work etc. Act 1974; the Management of Health and Safety at Work Regulations 1999; the Personal Protective Equipment at Work Regulations 2022; the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR); the Environmental Protection Act 1990 (including Section 34 Duty of Care); the Environmental Protection (Duty of Care) Regulations 1991 (as amended); the Waste (England and Wales) Regulations 2011 (as amended); hazardous waste consignment note requirements (where applicable); and the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 (as amended) and associated CQC guidance, including Regulation 12 (Safe care and treatment), Regulation 15 (Premises and equipment), Regulation 17 (Good governance) and Regulation 18 (Staffing/competence), including provider notification requirements where applicable. The policy aims to protect the health, safety, and welfare of the people we support, staff, visitors, and contractors by minimising risks associated with hazardous substances and ensuring responsible environmental management.

2. Scope

This policy applies to all staff, volunteers, and contractors who may come into contact with hazardous substances during their duties at {{org_field_name}}. It covers all areas where hazardous substances are used, stored, or disposed of, including cleaning products, medical waste, chemicals, bodily fluids, and other potentially harmful materials. This policy also ensures compliance with Care Quality Commission (CQC) Fundamental Standards regarding the safe handling of substances.

For CQC purposes, this policy supports compliance and evidence for:

• Regulation 12 (Safe care and treatment) – assessing and mitigating risks from hazardous substances and hazardous waste;
• Regulation 15 (Premises and equipment) – safe storage arrangements, availability and suitability of equipment (including PPE and spill response equipment), and maintenance of a safe environment;
• Regulation 17 (Good governance) – audits, monitoring, learning from incidents/near misses, and accurate record keeping; and
  relevant CQC notification requirements where an incident affects the health, safety or welfare of people using the service (including provider notifications where applicable).

3. Principles of Safe Handling and Disposal of Hazardous Substances

{{org_field_name}} is committed to ensuring a safe environment by adhering to the following key principles:

Identification and Risk Assessment

• A comprehensive inventory of all hazardous substances used within the organisation is maintained and regularly reviewed.
• COSHH risk assessments are conducted for all hazardous substances to determine potential health risks and necessary control measures.
• COSHH risk assessments must be reviewed at least annually and immediately when: a product changes; a new product or process is introduced; following an incident or near miss; where a person we support’s needs change; or where monitoring/audit identifies gaps. Control measures must follow the hierarchy of control (elimination/substitution; engineering controls; administrative controls; and PPE as a last line of defence). Where indicated by the COSHH assessment, health surveillance and/or exposure monitoring will be implemented and recorded.
• Safety Data Sheets (SDS) are available for all hazardous substances, providing information on safe handling, storage, emergency measures, and first aid procedures.
• People we support are assessed to identify any specific risks related to hazardous substances they may be exposed to within their care setting.

Storage and Labelling

• All hazardous substances are stored in designated, secure areas with restricted access, ensuring only trained and authorised staff can access them.
• Storage areas must be well-ventilated, temperature-controlled where required, and compliant with legal requirements to prevent contamination or accidental exposure.
• Correct labelling is applied to all hazardous substances in accordance with COSHH and the supplier’s classification and labelling requirements (including hazard pictograms, signal words, hazard statements and precautionary statements) as set out on the product label and SDS.
• Chemicals must never be stored in unlabelled containers or transferred to containers that may cause confusion (e.g., food or drink containers).
• Separate storage areas must be provided for different types of hazardous substances (flammables, corrosives, toxic substances, etc.) to prevent dangerous reactions.
• Storage areas must include secondary containment where there is a risk of leakage or spillage (e.g., bunded trays). Incompatible substances must be segregated in line with SDS guidance (for example, acids away from bleach; flammables stored appropriately). Keys/access controls and stock rotation (first-in/first-out and expiry checks) must be in place. Decanting is avoided where possible; where unavoidable, decanted containers must be immediately and fully labelled.

Safe Handling and Use

• Staff are provided with Personal Protective Equipment (PPE) such as gloves, masks, and eye protection when handling hazardous substances.
• All staff receive mandatory COSHH training covering how to handle hazardous substances safely, including manual handling techniques, ventilation requirements, and emergency procedures.
• Hazardous substances are only used for their intended purpose and in strict accordance with manufacturer guidelines and SDS instructions.
• Spill kits and emergency decontamination equipment are available, and staff are trained in their use.
• Chemicals and cleaning agents must not be mixed, as this can result in toxic fumes or dangerous reactions.
• Any spills or accidental exposure are reported immediately and managed according to emergency response procedures.

Disposal of Hazardous Substances

• Waste disposal procedures are carried out in accordance with the Environmental Protection Act 1990 (Section 34 Duty of Care) and associated waste duty of care requirements, ensuring waste is stored securely, accurately described, transferred only to authorised persons, and supported by the required documentation.
• Hazardous waste is segregated from general waste to ensure safe and appropriate disposal.
• Clinical and sharps waste is segregated at the point of use into the correct waste stream, placed into approved containers (e.g., UN-approved sharps bins where required), stored securely, and collected by an authorised waste contractor.
• Chemical waste disposal follows strict procedures, ensuring that hazardous chemicals are neutralised or disposed of through authorised waste management providers.
• Unused or expired medications are returned to a pharmacy or disposed of in line with the organisation’s Medication Management Policy.
• Regular audits are conducted to ensure hazardous waste is disposed of correctly and that staff understand their responsibilities.

Waste documentation, authorised carriers and retention

• For non-hazardous waste transfers, a waste transfer note (or a valid season ticket where used) must be completed and retained in line with duty of care requirements.
• For hazardous waste movements, a hazardous waste consignment note must be used where required.
• The Registered Manager (or delegated person) must verify that waste carriers/contractors are appropriately authorised and that the receiving site is permitted to accept the waste stream, and must retain evidence of these checks.
• Retention periods: waste transfer documentation is retained for at least two years and hazardous waste consignment documentation for at least three years (or longer where specific contractual/receiving-site rules require this).

Emergency Response and Spill Management

• Clear emergency response procedures are in place for managing hazardous substance spills, including containment, cleanup, and decontamination protocols.
• Emergency contact numbers for poison control, environmental agencies, and waste disposal contractors are readily available.
• Spill kits are available in all relevant areas, and staff are trained in their proper use.
• All incidents involving hazardous substances must be documented, investigated, and reviewed to prevent recurrence and improve safety measures.
• First aid measures for exposure to hazardous substances (e.g., eye washing, chemical burns) are clearly displayed and understood by all staff.

Incident reporting, escalation and external notifications

All hazardous substance incidents and near misses (including spills, splashes, chemical burns, suspected ingestion, sharps injuries, or exposure to bodily fluids/contaminants) must be reported immediately, recorded on the organisation’s incident reporting system, and reviewed for learning and prevention.

The Registered Manager will ensure that external reporting requirements are met, including:

• RIDDOR reporting where an incident meets reportable criteria;
• CQC notifications without delay where an incident affects the health, safety or welfare of people using the service and falls within provider notification requirements; and
• Duty of Candour processes are followed where a notifiable safety incident has occurred (including apology, explanation and written follow-up as required).

Where urgent medical advice is needed (e.g., poisoning, severe chemical burn, eye exposure), staff must seek immediate clinical advice (NHS 111/999 as appropriate) and follow SDS first aid measures.

Training and Staff Responsibilities

• All staff are required to complete mandatory COSHH training upon induction and attend refresher courses annually.
• Additional task-specific training is provided for staff handling high-risk hazardous substances.
• Staff must report any concerns regarding hazardous substances to their supervisor or the Health and Safety Lead immediately.
• Regular safety drills and scenario-based training sessions help ensure staff are prepared for handling hazardous substances safely.
• Staff are encouraged to suggest improvements to existing safety procedures and to report unsafe practices confidentially if necessary.

Monitoring and Compliance

• Regular COSHH risk assessments and audits are conducted to ensure compliance with hazardous substance regulations.
• Inspection checklists are used to monitor safe storage, handling, and disposal procedures.
• Accident and incident reports related to hazardous substances are reviewed by the Health and Safety Committee.
• Governance oversight includes: a scheduled audit programme (storage checks, PPE availability, SDS access, waste documentation and contractor authorisation checks); trend analysis of incidents/near misses; action plans with named owners and deadlines; and evidence that improvements are implemented and re-audited.
• Updates in legislation, CQC requirements, or industry best practices are incorporated into policies and training materials promptly.
• Non-compliance is addressed through training, supervision, and corrective action plans to improve adherence to safety protocols.

4. Definitions and classification

For the purposes of this policy:

• Hazardous substance includes any substance or mixture that may cause harm through inhalation, ingestion, injection, skin contact or absorption (including cleaning chemicals, aerosols, fuels, disinfectants, certain medicines, bodily fluids and contaminated materials).
• Safety Data Sheet (SDS) means the supplier’s Safety Data Sheet providing information on hazards, required control measures, safe handling and storage, emergency action, spill response and first aid.
• Hazardous waste is waste that has hazardous properties and must be managed, transferred and documented in line with hazardous waste requirements (including consignment documentation where applicable).
• Clinical waste includes waste arising from healthcare activities (for example, soiled dressings) and waste contaminated with bodily fluids that requires safe segregation and disposal.
• Sharps includes items capable of causing puncture wounds (e.g., needles, lancets, razors) requiring approved sharps containers.
• Sharps injury / exposure incident includes any needlestick injury, puncture wound, splash to eyes/mucous membranes, chemical burn, suspected ingestion, or other exposure requiring first aid and/or medical review.

Substances and waste streams must be classified and labelled in line with supplier information (including hazard pictograms, hazard statements and precautionary statements). SDS must be available to staff at the point of use.

5. Roles and Responsibilities

Registered Manager:

• Ensures compliance with all hazardous substances regulations and oversees staff training.

• Ensures Duty of Care compliance, including contractor authorisation checks, appropriate waste documentation (waste transfer notes/consignment notes where required), and record retention.
• Ensures appropriate external notifications are made where required (including CQC notifications and RIDDOR, as applicable) and that Duty of Candour processes are followed when relevant.

Health and Safety Lead:

• Conducts COSHH risk assessments, maintains SDS records, and monitors the safe handling and disposal of hazardous substances.

• Maintains the hazardous substances inventory, schedules COSHH review dates, and verifies that SDS are current and accessible at the point of use.
• Reviews incident trends and ensures learning is embedded into updated risk assessments, training and working practices.

All Staff:

• Responsible for adhering to safe handling procedures, reporting any incidents, and following disposal protocols.

Waste Management Providers:

• Ensures hazardous waste is disposed of in compliance with regulatory requirements.

Training Coordinator:

• Ensures all staff receive appropriate COSHH training and updates training materials as needed.

6. Related Policies

This policy should be read in conjunction with:

• SL11 – Safe Care and Treatment Policy
• SL16 – Health and Safety at Work Policy
• SL21 – Infection Prevention and Control Policy
• SL30 – Fire Safety and Emergency Evacuation Policy
• SL35 – Personal Protective Equipment (PPE) Policy
• SL40 – Medication Management and Administration Policy

7. Policy Review

This policy will be reviewed annually or sooner if legislative changes, CQC requirements, or organisational needs necessitate an update. The review will specifically consider updates to COSHH/HSE guidance, waste duty of care and hazardous waste requirements, and relevant CQC guidance for Regulations 12, 15, 17 and provider notifications, and will record the changes made and how staff have been informed and/or trained. Any updates will be communicated to all staff to ensure continued compliance with safe handling and disposal of hazardous substances. Non-compliance with this policy may result in disciplinary action.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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