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Control of Substances Hazardous to Health (COSHH) Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} effectively manages substances hazardous to health in accordance with the Control of Substances Hazardous to Health (COSHH) Regulations 2002. This policy provides clear procedures to identify, assess, and control risks associated with hazardous substances in the workplace to protect service users, employees, and visitors from harm.

This policy ensures compliance with:

• Control of Substances Hazardous to Health Regulations 2002 (COSHH) – duties to assess and prevent or adequately control exposure to hazardous substances, provide information/instruction/training, and ensure emergency arrangements.
• Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999 – general duties to protect staff and others affected by our activities through safe systems of work and suitable risk assessment.
• Regulation and Inspection of Social Care (Wales) Act 2016 and the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017 (as amended) – including requirements that policies/procedures are kept up to date and that risks to individuals’ health and safety are identified and reduced so far as reasonably practicable.
• Welsh Government Statutory Guidance for care home and domiciliary support service providers (Version 3, March 2024) – including expectations regarding health & safety, infection prevention and the safe handling and disposal of clinical/hazardous waste.
• Environmental Protection Act 1990 and associated waste duties – arrangements for the safe segregation, storage, and disposal of hazardous/clinical waste via approved routes.

2. Scope

This policy applies to:

• All employees, including care workers, cleaning staff, and managers handling hazardous substances.
• Service users who may come into contact with hazardous substances.
• Visitors, contractors, and external professionals who may access hazardous materials.

It covers:

• Identification of hazardous substances.
• Risk assessment procedures.
• Safe handling, storage, and disposal of hazardous substances.
• Personal protective equipment (PPE) requirements.
• Staff training and emergency procedures.

3. Identification of Hazardous Substances

Hazardous substances in a domiciliary care setting may include:

• Cleaning agents and disinfectants (e.g., bleach, ammonia, surface sanitisers).
• Medical substances (e.g., cytotoxic drugs, oxygen therapy).
• Personal care products (e.g., alcohol-based hand sanitisers, nail polish remover).
• Pesticides and insecticides used for infection control.
• Waste materials, bodily fluids, and infectious agents.

4. Risk Assessment Procedures

4.1 COSHH Risk Assessments

• A COSHH risk assessment must be carried out before using any hazardous substance.
• Risk assessments should identify:
  • The hazardous properties of the substance.
  • Potential routes of exposure (inhalation, skin contact, ingestion).
  • Control measures required to prevent harm.
  • Emergency procedures in case of exposure.
• Assessments must be reviewed annually or sooner if substances change or new risks emerge.

COSHH assessments must apply the hierarchy of control: eliminate the substance/task where possible; substitute with a less hazardous product; reduce exposure through safer methods (e.g., dilution controls, ventilation, closed containers), safe systems of work, and PPE/RPE only as a last line of defence. Where relevant, assessments must consider Workplace Exposure Limits (WELs), the need for health surveillance, and arrangements for inspection, maintenance and replacement of any control measures (including PPE/RPE). Any required checks (e.g., condition of gloves/eye protection, expiry dates, ventilation/engineering controls if used) must be recorded.

4.2 Assessing Service User Risks

• If hazardous substances are used in a service user’s home, a risk assessment must be completed.
• Alternative, less hazardous products should be used where possible.
• Service users must be informed of potential risks and provided with safety advice.

Where cleaning or personal care tasks are undertaken using products supplied by the individual/household, staff must only use products that are clearly labelled and in their original container. If a product is decanted, unlabelled, or appears inappropriate/high-risk, staff must not use it and must escalate to their manager to agree a safer alternative and update the risk assessment and care/support documentation as required.

5. Safe Handling, Storage, and Disposal of Hazardous Substances

5.1 Handling and Use of Hazardous Substances

• Only trained staff should handle hazardous substances.
• Manufacturer’s instructions and Safety Data Sheets (SDS) must be followed at all times.
• Decanting chemicals into unlabelled containers is strictly prohibited.
• Hand hygiene procedures must be followed after handling hazardous substances.

5.2 Storage of Hazardous Substances

Hazardous substances must be stored safely and securely in a way that reflects where the service is delivered:

• Office/base storage (where the service stores products): substances are kept in a designated locked cupboard/room, in original containers with labels intact, segregated from food/medicines, and protected from heat.
• In staff vehicles (where applicable): only minimal quantities are transported, kept upright in a closed, leak-resistant container, out of direct sunlight/heat, and never left unsecured where unauthorised persons could access them.
• In an individual’s home: the service does not routinely “store” hazardous substances; however, where service-supplied products are left in the home (exceptional/needs-led), this must be risk assessed, agreed with the individual/representative, and stored to minimise access by children/pets and anyone at risk (e.g., cognitive impairment).

Stock checks are completed at a frequency proportionate to risk and usage, and at least monthly where the service holds central stock.

5.3 Disposal of Hazardous Substances

• Expired or unwanted substances must be disposed of in accordance with environmental regulations.
• Chemical waste must never be poured down drains or mixed with other substances.
• Clinical waste and sharps: where generated through our activities, waste must be segregated and disposed of via the agreed clinical waste route (e.g., the individual’s prescribed sharps bin/collection arrangements or an approved contractor route where applicable).
• Spillages: spillages of hazardous substances or body fluids must be managed immediately using the correct PPE and method, in line with the relevant COSHH assessment and infection prevention procedures.
• Documentation: disposal arrangements must be recorded where required (e.g., incident records for spillages/exposures, and any waste transfer documentation where the service uses a contractor route).

6. Personal Protective Equipment (PPE) Requirements

• Staff handling hazardous substances must wear appropriate PPE as identified in risk assessments, including:
  • Gloves when handling cleaning agents or bodily fluids.
  • Face masks and eye protection when using strong disinfectants.
  • Aprons to prevent contamination of clothing.
• PPE must be:
  • Used correctly and not shared between staff.
  • Disposed of after each use following infection control guidelines.

7. Staff Training and Competency

• All employees must complete COSHH training during induction and receive annual refresher training.
• Training must cover:
  • Identifying hazardous substances.
  • Correct handling and storage procedures.
  • Using PPE effectively.
  • Emergency procedures for exposure incidents.
• Competency assessments will be conducted regularly to ensure staff compliance.

8. Emergency Procedures for Exposure Incidents

8.1 What to Do in Case of Exposure

If a staff member or service user is exposed to a hazardous substance:

1. Move to a safe area and assess the severity of the exposure.
2. Follow first aid procedures:
   • Skin contact – Wash with water and remove contaminated clothing.
   • Eye exposure – Rinse with clean water for at least 15 minutes.
   • Inhalation – Move to fresh air and seek medical attention if breathing is affected.
   • Ingestion – Seek emergency medical help immediately.
3. Report the incident to the Registered Manager and complete an Incident Report Form.

The Registered Manager will consider whether the incident is reportable under RIDDOR (to the Health and Safety Executive) and whether it meets the threshold for notification to CIW under the service’s notifications procedure. Where CIW notification is required, it must be made without delay (usually within 24 hours) and in the required format.

8.2 Spill Management

• Minor spills should be cleaned using appropriate PPE and absorbent materials.
• Major spills must be reported immediately and cleaned by trained personnel.
• Chemical spill kits must be available on-site for emergency use.

9. Monitoring and Compliance

• The Registered Manager is responsible for ensuring all COSHH procedures are followed.
• Quarterly safety audits will be conducted to assess compliance with COSHH regulations.
• Service user feedback will be used to ensure safe management of hazardous substances.
• CIW inspections will assess the effectiveness of COSHH management.

Monitoring arrangements will evidence that risks to the health and safety of individuals and staff are identified and reduced so far as reasonably practicable, and that improvements are acted upon according to the level of risk.

10. Records and document control

We will maintain clear records to evidence safe COSHH management and to support inspection and governance oversight. This includes:

• a register of hazardous substances used/supplied by the service and the associated Safety Data Sheets (SDS);
• completed COSHH assessments and review dates;
• staff training/competency records relating to COSHH and safe use of PPE;
• incident/near-miss reports relating to hazardous substances (including spillages/exposures) and actions taken;
• audit findings and improvement actions.

Records are stored securely and retained in line with the service’s record retention arrangements.

11. Related Policies

This policy should be read in conjunction with:

• Health and Safety at Work Policy (DCW16).
• Infection Prevention and Control Policy (DCW17).
• Risk Management and Assessment Policy (DCW18).
• Emergency and Business Continuity Plan (DCW19).
• Safe and Secure Business Premises Policy (DCW42).

12. Policy Review

This policy will be reviewed annually or sooner if required by legislative changes, CIW regulations, or operational needs.

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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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