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HCS32-Safe Handling of Hazardous Substances (COSHH) Policy

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Safe Handling of Hazardous Substances (COSHH) Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} complies with the Control of Substances Hazardous to Health Regulations 2002 (as amended), the Health and Safety at Work etc. Act 1974, and other relevant health and safety requirements relating to hazardous substances used, stored, handled or encountered in the course of providing care at home services in Scotland. This includes the assessment of risk, prevention or adequate control of exposure, provision of information, instruction and training, arrangements for accidents, incidents and emergencies, and the monitoring and review of control measures where required.

This policy should also be read in line with the Health and Social Care Standards: My support, my life, the Social Care and Social Work Improvement Scotland (Requirements for Care Services) Regulations 2011, relevant Care Inspectorate guidance for support services (care at home), and the Scottish Social Services Council (SSSC) Codes of Practice effective from 1 May 2024.

As a home care provider, we are committed to ensuring that all hazardous substances used or encountered during care provision—whether for cleaning, personal care, or infection control—are handled, stored, and disposed of safely, and that staff are fully trained and competent in their use.

This policy also supports our compliance with the Health and Social Care Standards, particularly:

Where substances are supplied in Great Britain, labels, hazard pictograms and safety data sheets must be interpreted in line with the GB CLP regime.

2. Scope

This policy applies to all staff employed by or contracted to work on behalf of {{org_field_name}}, including:

It also applies to any contractors or professionals who use substances as part of their work in the homes of people we support, and includes:

The principles in this policy apply across all environments, including our own administrative premises and the private homes in which care is delivered.

This policy applies both to substances supplied by {{org_field_name}} and to hazardous substances already present in a person’s home where staff may reasonably be exposed.

3. Related Policies

This policy should be read in conjunction with:

4. Policy Statement

{{org_field_name}} is committed to ensuring that no person—whether staff or individuals we support—is placed at unnecessary risk due to exposure to hazardous substances. We aim to:

We believe that preventing harm from hazardous substances is integral to protecting human health, dignity, and the delivery of safe, high-quality care.

5. Understanding COSHH in a Home Care Setting

In a domiciliary care environment, hazardous substances are often part of routine tasks such as:

Although care is provided in someone else’s home, {{org_field_name}} remains legally and ethically responsible for ensuring that staff are supported and equipped to work safely with any hazardous substance they are likely to encounter.

In care at home services, staff often work in environments that are not under the direct control of the provider. {{org_field_name}} will therefore assess foreseeable risks in partnership with the person supported and, where appropriate, their representative, while respecting the person’s home, rights, choices and dignity. Where hazardous substances in the home present a risk to staff or others, the service will agree proportionate control measures and record these in the relevant risk assessment and, where appropriate, in the person’s personal plan.

6. Efficient Management of Hazardous Substances

6.1. Identification and Inventory

We maintain an up-to-date inventory of all hazardous substances that may be used by our staff in the course of their duties. This includes:

The inventory is reviewed regularly, and a record is kept of where each product is used, by whom, and for what purpose.

Staff are expected to report any additional substances they encounter that are not on the inventory so that a risk assessment can be undertaken.

The inventory must identify the product name, purpose, location of use, hazards, date added, review date, and the current safety data sheet reference. Current safety data sheets must be readily accessible to staff electronically or in hard copy at all times.

6.2. COSHH Risk Assessments

For each identified hazardous substance, we complete a COSHH risk assessment.

This involves:

COSHH assessments must be suitable and sufficient, specific to the task and setting, and completed by a person with adequate knowledge, training and experience. Assessments will identify the hazardous substance, routes of exposure, persons at risk, existing controls, further actions required, first-aid measures, spill procedures, disposal arrangements, and whether health surveillance or exposure monitoring is required.

COSHH assessments will be reviewed at least annually and sooner where:

Where staff exposure presents a foreseeable risk of dermatitis, asthma or other work-related ill health, {{org_field_name}} will consider and implement appropriate health surveillance in line with COSHH requirements.

6.3. Hierarchy of Control

{{org_field_name}} will control exposure to hazardous substances by applying the hierarchy of control. In order of priority, we will:

PPE will not be relied upon as the sole control measure where more effective control is reasonably practicable.

6.4. Health Surveillance and Monitoring

Where the COSHH assessment identifies a reasonable likelihood of work-related ill health, such as dermatitis, asthma or other adverse health effects arising from exposure to hazardous substances, {{org_field_name}} will put in place appropriate health surveillance and/or exposure monitoring in line with legal requirements and specialist advice where necessary.

Staff must report symptoms such as skin irritation, breathing difficulties, headaches, dizziness or other suspected adverse effects without delay. Records of health surveillance, where undertaken, will be kept confidentially and in accordance with data protection and records management requirements.

6.5. Safe Storage and Labelling

All hazardous substances provided by {{org_field_name}} are stored in:

In the homes of people we support, staff are encouraged to identify where products are stored and report any concerns (e.g., unlocked cleaning agents within reach of vulnerable individuals). These are then discussed with the individual and, if appropriate, their family or representative to promote safer arrangements.

Hazardous substances must be kept in their original containers wherever possible. They must never be decanted into food, drink or unmarked containers. If decanting is exceptionally necessary for immediate operational reasons, the receiving container must be suitable, secure, and fully labelled with the product name, hazards and key precautions in line with the supplier information.

6.6. Link to Personal Plans and Environmental Risk

Where hazardous substances in a person’s home create a foreseeable risk to the person, staff or others, this must be reflected in the person’s environmental risk assessment and, where relevant, their personal plan. This may include safe storage arrangements, products that staff must not use, products that may only be used by others, required ventilation, PPE, actions to take following accidental exposure, and who to contact in an emergency.

Any agreed control measures must respect the person’s rights and choices while ensuring staff are not expected to work in unsafe conditions.

6.7. Personal Protective Equipment (PPE)

Personal protective equipment is not the first or only control measure under COSHH and must not be used as a substitute for safer systems of work where exposure can be prevented or otherwise adequately controlled. PPE will be provided and used where the risk assessment shows that residual risk remains after other control measures have been considered or applied.

Depending on the substance and task, PPE may include:

Staff must be trained in the correct selection, safe use, removal, disposal, replacement and reporting of defects in PPE. Managers must ensure suitable PPE is available, in date where relevant, and compatible with the task being undertaken.

6.8. Training and Staff Competence

All staff receive training on COSHH as part of their induction, which includes:

Refresher training is provided annually or following a review of policy, an incident, or the introduction of a new hazardous substance.

Supervisions and team meetings are used to reinforce learning and to reflect on any challenges faced when working in people’s homes.

Agency staff, temporary staff and contractors must receive sufficient COSHH information and local induction before undertaking relevant tasks. Competence should be confirmed in practice where staff are required to use higher-risk products or undertake non-routine tasks.

6.9. Spillage, Exposure and Emergency Response

In the event of a spillage, accidental exposure, or suspected adverse reaction to a hazardous substance, staff must:

The manager will consider whether the incident is reportable under RIDDOR and whether any review of the COSHH assessment, care plan, personal plan, training, supervision or product use is required.

6.10. Reporting and Statutory Notifications

All spillages, accidental exposures, near misses and symptoms of possible work-related ill health must be reported internally in accordance with {{org_field_name}}’s incident reporting procedure.

The Registered Manager, or delegated senior person, will determine whether the circumstances require notification to external bodies, including reporting under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR), notification to the Care Inspectorate, referral to commissioning bodies, or other safeguarding or professional reporting processes as required.

7. Responsibilities

Registered Manager

The Registered Manager has overall responsibility for ensuring effective COSHH arrangements are in place across the service. This includes ensuring suitable policies, assessments, training, supervision, monitoring, review, incident follow-up and improvement actions.

Delegated COSHH Lead / Competent Person (where appointed)

The delegated lead is responsible for maintaining the hazardous substances inventory, obtaining and updating safety data sheets, coordinating COSHH assessments, supporting managers and staff with control measures, and escalating concerns where risks are not adequately controlled.

Supervisors / Coordinators

Supervisors and coordinators must ensure staff have access to current risk assessments, understand safe systems of work, have the required PPE and equipment, and are not allocated tasks for which they are not trained or competent.

Care and Support Staff

Staff must follow COSHH assessments, manufacturer instructions, training and safe systems of work; use control measures and PPE correctly; report defects, unsafe storage, spillages, symptoms, incidents and near misses promptly; and stop work and seek advice where they believe exposure is not adequately controlled.

People We Support and Representatives

People we support should be involved, wherever possible, in decisions about managing hazardous substances in their home. Where a person lacks capacity or needs support with decision-making, their representative, welfare proxy or others with legal authority should be involved as appropriate and in line with relevant Scottish legislation and principles.

8. Policy Review

This policy is reviewed at least annually, and sooner where:

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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