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{{org_field_name}}
Registration Number: {{org_field_registration_no}}
Control of Substances Hazardous to Health (COSHH) Policy
1. Purpose
At {{org_field_name}}, we are committed to protecting people receiving support, staff, agency workers, volunteers, contractors and visitors from avoidable harm caused by exposure to substances hazardous to health. This policy sets out how hazardous substances are identified, assessed, controlled, stored, used, transported where applicable, and disposed of safely within our Supported Living service.
This policy applies to hazardous substances used or encountered during the delivery of care and support, including cleaning products, disinfectants, bodily fluids, clinical waste, sharps, medicines-related hazards, aerosols, gases, fumes, vapours, mists, dusts, biological agents and any other substance that may present a risk to health.
In supported living, care and support may be provided in a person’s own home or tenancy. COSHH controls must therefore be applied in a way that is safe, person-centred, proportionate, respectful of the person’s rights, and consistent with tenancy arrangements, mental capacity, consent, safeguarding duties, staff health and safety duties and CQC requirements.
The purpose of this policy is to ensure compliance with the Control of Substances Hazardous to Health Regulations 2002, the Health and Safety at Work etc. Act 1974, the Health and Social Care Act 2008, the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, CQC Fundamental Standards, HSE guidance and relevant infection prevention and control guidance.
2. Scope
This policy applies to all staff, agency workers, volunteers, contractors and managers who may purchase, handle, use, store, transport, encounter, clean up, or dispose of hazardous substances while working for {{org_field_name}}.
This includes work undertaken in:
- people’s own homes or tenancies;
- shared supported living accommodation;
- communal areas where staff provide support;
- office bases;
- vehicles used for work purposes;
- community settings where staff may support people with medicines, continence care, cleaning tasks, personal care or infection prevention measures.
The policy applies to substances supplied by {{org_field_name}}, substances used by staff during work activities, and substances already present in a person’s home where those substances may create a work-related risk. Where a hazardous substance belongs to the person receiving support, staff must not remove, restrict access to, or dispose of it without lawful authority, consent, best-interest decision-making where applicable, or safeguarding/legal advice where required.
3. Related Policies
- SL12 – Safe Care and Treatment Policy
- SL16 – Infection Prevention and Control Policy
- SL21 – Medication Management and Administration Policy
- SL34 – Confidentiality and Data Protection (GDPR) Policy
- SL19 – Fire Safety Policy
- SL17 – Good Governance Policy
- Health and Safety Policy
- Risk Assessment Policy
- Incident, Accident and Near Miss Reporting Policy
- Waste Management Policy
- Personal Protective Equipment (PPE) Policy
- Moving and Handling Policy, where hazardous exposure may arise from bodily fluids or contaminated equipment
- Safeguarding Adults Policy
- Mental Capacity Act and Consent Policy
- Lone Working Policy
- Business Continuity and Emergency Planning Policy
- Records Management Policy
- Staff Supervision, Training and Competency Policy
4. Legal and Regulatory Framework
Our COSHH arrangements are based on the following legislation, regulations and guidance, as applicable to Supported Living services in England:
- Health and Safety at Work etc. Act 1974 – the general duty to protect the health, safety and welfare of employees and others affected by work activities.
- Management of Health and Safety at Work Regulations 1999 – the duty to assess risks, implement preventive and protective measures, provide information and training, and review arrangements.
- Control of Substances Hazardous to Health Regulations 2002, as amended – the duty to assess hazardous substances, prevent or adequately control exposure, maintain control measures, monitor exposure where required, provide health surveillance where required, and provide information, instruction and training.
- Personal Protective Equipment at Work Regulations 1992, as amended by the Personal Protective Equipment at Work (Amendment) Regulations 2022 – the duty to provide suitable PPE where risks cannot be adequately controlled by other means, including duties extended to relevant workers. HSE confirms that the 2022 amendment extended PPE duties to limb (b) workers.
- Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR) – the duty to report specified work-related injuries, diseases, dangerous occurrences and certain exposures, including relevant biological-agent incidents.
- Health and Social Care Act 2008 – the statutory framework for regulation by the Care Quality Commission. The Act requires regulation to secure safe, appropriate-quality services and the health, safety and welfare of people receiving regulated activities
- Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – including Regulation 12 Safe Care and Treatment, Regulation 15 Premises and Equipment, Regulation 17 Good Governance and Regulation 18 Staffing. CQC lists these as Fundamental Standards for providers and managers.
- CQC Regulation 12: Safe Care and Treatment – requiring risks to people’s health and safety to be assessed and mitigated, staff to be competent, premises and equipment to be safe, medicines to be managed safely, and infection prevention and control risks to be managed.
- CQC Regulation 15: Premises and Equipment – requiring premises and equipment used by the service to be safe, suitable, secure and properly used.
- CQC Regulation 17: Good Governance – requiring systems and processes to assess, monitor and improve safety and quality, maintain accurate records, identify risks and act without delay.
- CQC Regulation 18: Staffing – requiring suitably trained, competent and skilled staff.
- Health and Social Care Act 2008: Code of Practice on the Prevention and Control of Infections and Related Guidance – applicable to registered providers of adult social care in England and used by CQC when judging infection prevention and cleanliness compliance.
- Classification, Labelling and Packaging requirements and Safety Data Sheet requirements – hazardous chemical products must be appropriately classified, labelled and accompanied by safety information where required. HSE states that Safety Data Sheets contain information needed to support COSHH risk assessment, but the SDS is not itself the assessment.
- Environmental Protection Act 1990, Hazardous Waste requirements and local waste-management requirements – relevant to safe disposal of hazardous, clinical, offensive, medicinal and chemical waste.
- Medicines legislation and pharmacy waste requirements, where medicines, medicated creams, cytotoxic/cytostatic medicines, sharps or contaminated medicine waste are involved.
5. Identifying Hazardous Substances
Hazardous substances in our Supported Living service may include, but are not limited to:
- cleaning agents, detergents, disinfectants, descalers, bleach-based products and sanitising products;
- products containing chemicals, including sprays, aerosols, solvents, air fresheners, laundry products and pest-control products;
- bodily fluids, including blood, vomit, urine, faeces, sputum and other potentially infectious material;
- biological agents, including bacteria, viruses, fungi and other micro-organisms that may cause infection, allergy, toxicity or other harm;
- clinical waste, contaminated dressings, continence products and waste from personal care;
- sharps, including needles, lancets, razors, broken glass or other items capable of puncturing the skin;
- medicines-related hazards, including cytotoxic or cytostatic medicines, medicated creams, transdermal patches, oxygen, medical gases and residues from medicines administration;
- fumes, vapours, gases, mists or dusts generated during cleaning, maintenance, accidental mixing of chemicals or environmental conditions;
- latex or other sensitising substances where relevant;
- substances brought into or stored in a person’s home which may create a risk to staff or others during support.
COSHH does not replace substance-specific legal requirements for asbestos, lead or radioactive substances. If staff suspect the presence of asbestos, lead, radioactive material, illegal substances, unknown chemicals, or any substance presenting serious or immediate danger, they must not handle it and must report the concern immediately to the Registered Manager for specialist advice.
All hazardous substances must be identified, assessed, and labelled clearly to prevent accidental exposure.
5.1 COSHH Inventory
The Registered Manager or delegated competent person must maintain a COSHH inventory/register of hazardous substances used or encountered through the service. The register must include:
- the product or substance name;
- where it is used or stored;
- who may be exposed;
- the current Safety Data Sheet, where applicable;
- the COSHH risk assessment reference;
- required control measures and PPE;
- first aid and emergency actions;
- disposal requirements;
- review date;
- any restrictions on use, including substances that must not be used by staff.
Staff must not introduce new hazardous substances for work use unless they have been approved by the Registered Manager or delegated competent person and a COSHH assessment has been completed.
6. Risk Assessment and Control Measures
A suitable and sufficient COSHH risk assessment must be completed before staff use, handle, store or dispose of any hazardous substance as part of their work. The assessment must be proportionate to the level of risk and must consider the specific environment in which support is provided, including where the person receives support in their own home.
The COSHH assessment must identify:
- the hazardous substance and its form, such as liquid, powder, vapour, gas, mist, dust, aerosol or biological material;
- the task or activity where exposure may occur;
- who may be harmed, including people receiving support, staff, agency workers, visitors, family members, contractors and others in the household;
- how exposure may happen, including inhalation, skin contact, eye contact, ingestion, injection or contamination through broken skin;
- the potential health effects, including acute harm, allergy, sensitisation, infection, burns, poisoning, respiratory effects or longer-term harm;
- the frequency, duration and level of possible exposure;
- whether there are workplace exposure limits or other exposure concerns;
- whether health surveillance or exposure monitoring is required;
- the control measures required to prevent or adequately control exposure;
- required PPE and how it must be used, stored, replaced and disposed of;
- safe storage, labelling and segregation arrangements;
- safe disposal arrangements;
- first aid, spill, exposure and emergency procedures;
- staff training and competency requirements;
- any person-specific risks, including allergies, respiratory conditions, cognitive impairment, sensory needs, behaviours that may increase risk, or risks to children, pets or visitors in the person’s home.
COSHH assessments must be reviewed at least annually and sooner if:
- a new substance, product or task is introduced;
- the Safety Data Sheet changes;
- there is an incident, near miss, exposure, spill or complaint;
- staff raise concerns or report symptoms;
- there are changes to the person’s needs, environment, equipment or care plan;
- infection prevention guidance changes;
- audit findings show non-compliance;
- legislation, HSE guidance or CQC guidance changes.
6.1 Implementing Control Measures
{{org_field_name}} will apply the hierarchy of control to prevent or adequately control exposure to hazardous substances:
- Eliminate the hazardous substance or task where reasonably practicable.
- Substitute with a safer product, safer concentration, safer form or safer process where possible.
- Reduce exposure by limiting the quantity used, frequency of use, number of people exposed and duration of exposure.
- Use safe systems of work, including written instructions, manufacturer’s instructions, dilution instructions, no-mixing rules, safe cleaning methods and safe disposal procedures.
- Use engineering or environmental controls where relevant, including ventilation, closed containers, spill trays or suitable storage.
- Maintain hygiene controls, including hand hygiene, cleaning schedules, safe management of contaminated items and prevention of cross-contamination.
- Provide information, instruction, training and supervision so staff understand the hazards, control measures and emergency procedures.
- Use PPE only where risks remain after other controls, ensuring that PPE is suitable, properly fitted where relevant, compatible with other PPE, available, maintained, replaced and disposed of safely.
Staff must follow the COSHH assessment and must not mix chemicals, decant substances into unlabelled containers, use substances for purposes not intended by the manufacturer, or use any product where the label or Safety Data Sheet indicates that it is not safe for the intended task.
6.2 Person-Centred COSHH in Supported Living
People receiving support may have their own cleaning products, personal care products, medicines, oxygen, continence supplies or other substances in their home. Staff must respect the person’s home, choices, privacy and rights while also following health and safety requirements.
Where a substance in a person’s home presents a risk, staff must:
- discuss the risk with the person in a respectful and accessible way;
- support the person to understand safer storage, use or disposal options;
- record the risk and agreed controls in the person’s care plan or environmental risk assessment;
- involve relatives, representatives, commissioners, landlords, health professionals or safeguarding teams where appropriate and lawful;
- consider mental capacity and best-interest decision-making where the person may lack capacity to understand the risk;
- escalate immediately where there is a serious or imminent risk to the person, staff or others.
Staff must not impose blanket restrictions. Any restriction on a person’s access to their own possessions or household products must be lawful, necessary, proportionate, risk assessed, documented and reviewed.
6.3 Safety Data Sheets and Manufacturer Instructions
Safety Data Sheets must be available for hazardous chemical products supplied or used by {{org_field_name}}. Staff must be able to access relevant COSHH assessments and key safety instructions at the point of use.
A Safety Data Sheet supports the COSHH assessment but does not replace it. The Registered Manager or delegated competent person must use Safety Data Sheets, product labels, manufacturer instructions and the circumstances of actual use to decide the controls required.
Staff must follow manufacturer instructions for dilution, contact time, ventilation, storage, incompatibilities, PPE, first aid and disposal. Products must not be used if the label is missing, unreadable, damaged, or inconsistent with the COSHH assessment.
7. Safe Storage and Handling of Hazardous Substances
7.1 Storage Procedures
- Hazardous substances supplied by {{org_field_name}} must be stored securely, safely and in accordance with the COSHH assessment, Safety Data Sheet and manufacturer instructions.
- In office bases or provider-controlled storage areas, hazardous substances must be stored in designated secure areas with restricted access.
- In a person’s own home, storage arrangements must be agreed with the person where possible and recorded in the person’s care plan or environmental risk assessment where staff are involved in using or managing the substance.
- Locked storage must be used where required by risk assessment, for example where there is a risk of accidental ingestion, misuse, self-harm, confusion, access by children or visitors, unsafe mixing, or harm to the person or others.
- Substances must be kept in original containers wherever possible, with clear labels, hazard pictograms and manufacturer instructions intact.
- Substances must not be decanted into drink bottles, food containers, unlabelled containers or containers that could cause confusion.
- Cleaning products must be stored separately from food, medicines, clinical supplies and personal care items unless the COSHH assessment confirms this is safe.
- Incompatible substances, such as bleach and acidic cleaners, must be stored and used separately and must never be mixed.
- Oxygen and medical gases must be stored in line with supplier instructions, fire safety requirements and the person’s care plan.
- Safety Data Sheets and COSHH assessments must be accessible to staff who use the substance.
7.2 Handling Procedures
- Staff must read and follow the COSHH assessment, product label, Safety Data Sheet and care plan before using or handling hazardous substances.
- Staff must only use substances for the intended purpose and in the way instructed by the manufacturer and the COSHH assessment.
- Chemicals must not be mixed unless the manufacturer specifically states this is safe. Bleach must never be mixed with acids, ammonia-based products, descalers or other cleaning agents.
- Staff must use the correct dilution, contact time and ventilation.
- PPE identified in the COSHH assessment must be worn correctly and changed or disposed of safely after use.
- Staff must avoid touching the face, eyes, mouth or personal items while handling hazardous substances.
- Hands must be washed or decontaminated after handling hazardous substances, after removing PPE, and after contact with bodily fluids or contaminated items.
- Sharps must not be passed hand to hand, bent, broken, recapped unless a specific safety device requires it, or placed in domestic waste.
- Contaminated laundry must be handled in line with infection prevention and control procedures and the person’s care plan.
- Staff must report damaged containers, missing labels, unexpected reactions, odours, spills, exposure, symptoms or unsafe storage immediately.
- Staff must not use any hazardous substance where they have not received appropriate information, instruction or training.
8. Disposal of Hazardous Substances
8.1 Waste Segregation and Disposal
Waste must be segregated, stored and disposed of safely in line with the waste risk assessment, local authority or waste contractor requirements, infection prevention and control guidance, medicines guidance and any specific instructions from healthcare professionals.
- Domestic waste must only be used for non-hazardous household waste.
- Offensive hygiene waste, such as non-infectious continence waste, must be managed according to local waste arrangements and the person’s care plan.
- Infectious or potentially infectious waste must be managed as clinical waste and disposed of through the correct clinical waste stream.
- Waste contaminated with medicines, cytotoxic or cytostatic medicines, medicated dressings, transdermal patches or similar items must not be placed in ordinary domestic waste unless pharmacy or waste guidance confirms this is appropriate.
- Sharps must be placed immediately into an approved sharps container that is correctly assembled, labelled, temporarily closed when not in use, stored safely and disposed of through an authorised route.
- Used PPE must be disposed of according to infection risk, contamination risk and current IPC guidance.
- Unused, unwanted or expired medicines must be returned to the supplying pharmacy or managed in line with the Medication Policy and local arrangements.
- Chemical products must not be poured down sinks, toilets, drains or placed in domestic waste unless the product instructions, Safety Data Sheet and local waste rules confirm that this is safe and lawful.
- Waste awaiting collection must be stored securely and must not create a risk to people receiving support, staff, visitors, children, pets or the public.
The Registered Manager must ensure that staff know the correct waste streams used by the service and that waste contractor records, where applicable, are retained.
8.2 Spill Management
Staff must respond to spills promptly, safely and in accordance with the COSHH assessment, Safety Data Sheet, infection prevention and control procedures and emergency instructions.
For any spill, staff must:
- assess the immediate risk and keep people away from the affected area;
- wear the PPE specified in the COSHH assessment or spill procedure;
- ensure ventilation where safe to do so;
- avoid direct contact with the substance;
- use the correct spill kit or cleaning method;
- dispose of contaminated materials through the correct waste stream;
- wash hands after removing PPE;
- report and record the incident or near miss.
Staff must not attempt to clean a spill where:
- the substance is unknown;
- the spill involves a large quantity of chemical;
- fumes, vapours, breathing difficulty, dizziness or eye irritation are present;
- there is a fire, explosion or oxygen-related risk;
- the spill involves cytotoxic/cytostatic medicines and staff are not trained or equipped;
- sharps or broken glass are present and safe equipment is not available;
- the staff member cannot manage the spill safely.
In these circumstances, staff must isolate the area if safe, support people to move away, contact the Registered Manager or on-call manager, and seek emergency assistance where required.
9. Staff Training and Competency
All staff must receive COSHH information, instruction and training appropriate to their role before they are required to use, handle, store, clean up or dispose of hazardous substances.
Training must include:
- what COSHH is and why it is relevant to supported living;
- how to identify hazardous substances, labels, hazard pictograms and warning information;
- how to access and follow COSHH assessments and Safety Data Sheets;
- risks from chemicals, biological agents, bodily fluids, clinical waste, sharps, medicines-related hazards and aerosols;
- safe use, dilution, contact time, ventilation and no-mixing rules;
- safe storage in provider-controlled settings and in people’s own homes;
- correct use, removal, storage and disposal of PPE;
- spill management and emergency actions;
- sharps safety and clinical waste procedures where relevant;
- first aid actions following exposure;
- incident, near miss, RIDDOR and CQC notification escalation routes;
- person-centred risk management, consent, mental capacity and safeguarding considerations.
Staff competency must be assessed where staff undertake higher-risk tasks, including handling clinical waste, sharps, cytotoxic/cytostatic medicines, oxygen, bodily-fluid spills, infectious waste or chemical spill management.
Agency workers and new staff must receive sufficient local information before undertaking tasks involving hazardous substances. Training and competency records must be retained and reviewed as part of governance audits.
10. Emergency Procedures for Exposure or Incidents
10.1 First Aid Measures
Staff must follow the Safety Data Sheet, COSHH assessment, product label and first aid guidance for the substance involved. Where there is any doubt, staff must seek medical advice immediately.
- Skin contact: Remove contaminated clothing where safe and rinse the affected skin with plenty of water. Seek medical advice if irritation, burns, pain, allergic reaction or symptoms persist.
- Eye exposure: Rinse the eye immediately with clean running water or eyewash for at least 15 minutes and seek medical advice.
- Inhalation: Move the person to fresh air if safe to do so. Seek urgent medical help if there is breathing difficulty, chest tightness, dizziness, collapse or ongoing symptoms.
- Ingestion: Seek medical advice immediately. Do not induce vomiting unless instructed by a medical professional. Keep the container, label or Safety Data Sheet available for healthcare professionals.
- Sharps injury or bite with blood exposure: Encourage bleeding gently where appropriate, wash with soap and water, cover the wound, report immediately, and seek urgent occupational health or medical advice.
- Exposure to bodily fluids or suspected infection risk: Follow infection prevention procedures and seek medical or occupational health advice where required.
Emergency services must be contacted where there is serious injury, breathing difficulty, loss of consciousness, suspected poisoning, chemical burns, significant eye injury, anaphylaxis, fire, explosion risk or uncontrolled exposure.
10.2 Reporting and Incident Documentation
All COSHH-related incidents, near misses, exposures, spills, unsafe storage concerns, missing labels, PPE failures, sharps injuries and waste incidents must be reported to the Registered Manager or on-call manager as soon as possible and recorded in the incident reporting system.
Incident records must include:
- date, time and location;
- person or staff member affected;
- substance involved, including product name and concentration where known;
- route of exposure, such as skin, eyes, inhalation, ingestion, injection or contamination;
- immediate actions taken;
- first aid or medical advice sought;
- PPE used;
- witnesses;
- whether the COSHH assessment was followed;
- whether the care plan or environmental risk assessment requires review;
- actions to prevent recurrence.
The Registered Manager must consider whether the incident requires:
- safeguarding referral;
- medical advice or occupational health referral;
- notification to the person’s representative, commissioner or health professional;
- RIDDOR reporting to HSE;
- CQC notification under the Care Quality Commission (Registration) Regulations 2009, where the incident meets the threshold for notification;
- duty of candour actions where the incident is a notifiable safety incident;
- review of the COSHH assessment, care plan, staff training or provider procedures.
Lessons learned must be shared with staff through supervision, team meetings, alerts, updated risk assessments or retraining where required.
10.3 RIDDOR, CQC Notifications and Safeguarding
The Registered Manager is responsible for reviewing COSHH-related incidents to decide whether external reporting is required.
RIDDOR reporting may be required for specified work-related injuries, occupational diseases, dangerous occurrences, or certain exposures to biological agents, carcinogens or mutagens. HSE guidance confirms that RIDDOR includes reportable incidents involving biological agents and dangerous occurrences.
CQC notification may be required where a COSHH-related incident results in serious injury, abuse or allegation of abuse, death, an event that stops or may stop the service from operating safely, or another notifiable incident under the Registration Regulations.
A safeguarding referral must be considered where unsafe storage, misuse, neglect, self-neglect, deliberate exposure, coercion, poor infection control, unsafe medicines handling, or environmental risks place a person at risk of abuse or neglect.
All external notifications must be recorded, including the date submitted, person responsible, reference number and follow-up action required.
11. Monitoring and Continuous Improvement
The Registered Manager will ensure that COSHH arrangements are monitored through the service’s governance systems. Monitoring will include:
- quarterly COSHH audits;
- checks that the COSHH inventory is current;
- checks that Safety Data Sheets are available and current;
- review of COSHH assessments and review dates;
- checks of storage arrangements in provider-controlled areas and, where agreed and relevant, in people’s homes;
- observation of staff practice where higher-risk tasks are undertaken;
- review of PPE availability, suitability, use and disposal;
- review of waste segregation and sharps arrangements;
- analysis of incidents, near misses, exposure events and staff concerns;
- review of staff training and competency records;
- review of actions from audits, incidents, complaints, safeguarding concerns and CQC feedback.
Audit findings must be recorded in an action plan showing the issue identified, action required, responsible person, timescale, completion date and evidence of completion.
Where audits or incidents identify immediate risk, the Registered Manager must act without delay to protect people and staff. Learning must be shared with staff and used to update COSHH assessments, care plans, training and procedures.
12. Confidentiality and Data Protection
COSHH-related records, including COSHH assessments, incident reports, exposure records, training records, audit records, health surveillance information and occupational health correspondence, must be stored securely in line with the Confidentiality and Data Protection Policy, UK GDPR and the Data Protection Act 2018.
Access must be limited to those who require the information for a lawful work purpose. Health information about staff or people receiving support must be handled confidentially and shared only where lawful, necessary and proportionate.
Records must be retained in line with {{org_field_name}}’s records retention schedule and any statutory or insurance requirements.
13. Roles and Responsibilities
The Provider/Nominated Individual is responsible for:
- ensuring that effective health and safety governance systems are in place;
- ensuring that COSHH risks are managed as part of safe care and treatment;
- ensuring sufficient resources are available for training, PPE, safe storage, waste disposal and audit;
- reviewing significant COSHH-related incidents and ensuring statutory notifications are made where required.
The Registered Manager is responsible for:
- implementing this policy;
- ensuring COSHH assessments are completed, reviewed and accessible;
- maintaining the COSHH inventory;
- ensuring staff receive training, supervision and competency checks;
- ensuring safe storage, use and disposal arrangements are in place;
- reviewing incidents, near misses and audit findings;
- ensuring required RIDDOR, CQC, safeguarding or commissioner notifications are considered and completed;
- ensuring learning is shared and embedded.
Senior staff/team leaders are responsible for:
- checking that staff follow COSHH assessments and care plans;
- escalating unsafe practice, missing information, storage concerns, spills or incidents;
- supporting staff to access PPE, spill kits and COSHH information;
- completing local checks as delegated by the Registered Manager.
All staff are responsible for:
- following COSHH assessments, care plans, product labels and Safety Data Sheets;
- using PPE correctly;
- not using substances they have not been trained or authorised to use;
- not mixing chemicals;
- reporting unsafe substances, missing labels, spills, exposure, symptoms, near misses and incidents immediately;
- respecting people’s homes and rights while escalating risks appropriately.
Contractors are responsible for:
- managing substances they bring into the service or a person’s home safely;
- providing risk assessments, method statements and Safety Data Sheets where required;
- ensuring their work does not place people receiving support, staff or others at risk.
14. Health Surveillance and Exposure Monitoring
The Registered Manager must seek competent health and safety or occupational health advice where a COSHH assessment identifies that exposure monitoring or health surveillance may be required.
Health surveillance may be required where staff are exposed to substances that can cause occupational asthma, dermatitis, sensitisation, infection or other identifiable health effects, and where there is a reasonable likelihood that exposure may occur despite controls.
Staff must report work-related symptoms promptly, including skin irritation, rashes, breathing difficulties, eye irritation, headaches, dizziness, allergic reactions, needlestick injuries or symptoms following exposure to bodily fluids or chemicals.
Health surveillance records must be kept securely and confidentially. Findings must be used to review COSHH controls, training, PPE and working practices.
15. Pregnancy, Young Workers and Individual Staff Risks
COSHH assessments must consider individual staff risks where relevant, including pregnancy, breastfeeding, young workers, asthma, allergies, dermatitis, immune suppression, disability or other health conditions that may increase vulnerability to hazardous substances.
Staff should inform their manager if they have a health condition or circumstance that may affect their safety when working with hazardous substances. Managers must handle this information confidentially and consider reasonable adjustments, occupational health advice or task restrictions where required.
Staff must not be required to undertake tasks involving hazardous substances where the risk assessment identifies that the task cannot be carried out safely.
16. Prohibited or Restricted Practices
The following practices are not permitted:
- mixing cleaning chemicals unless specifically authorised by the manufacturer and COSHH assessment;
- using bleach with acidic cleaners, descalers, ammonia-based products or other incompatible substances;
- decanting chemicals into drink bottles, food containers or unlabelled containers;
- using products with missing, damaged or unreadable labels;
- using substances for purposes not intended by the manufacturer;
- storing chemicals with food, medicines or personal care items unless risk assessed as safe;
- placing sharps in domestic waste;
- manually compressing waste bags containing clinical waste, sharps or contaminated items;
- cleaning up unknown chemical spills without appropriate advice, equipment and PPE;
- disposing of medicines, chemicals or clinical waste through inappropriate waste streams;
- removing or restricting a person’s own possessions without lawful authority, consent or appropriate best-interest/safeguarding process.
17. CQC Evidence and Records
To evidence compliance with CQC Fundamental Standards, {{org_field_name}} will maintain:
- current COSHH policy;
- COSHH inventory/register;
- COSHH risk assessments;
- Safety Data Sheets;
- staff COSHH training records;
- competency assessments for higher-risk tasks;
- PPE records where applicable;
- waste collection/contractor records where applicable;
- sharps disposal records where applicable;
- incident, near miss and exposure records;
- RIDDOR, CQC and safeguarding notification records where applicable;
- audit records and action plans;
- evidence of lessons learned and improvements made.
These records will support the service to demonstrate safe care and treatment, safe environments, effective staffing, infection prevention and control, medicines safety, good governance and continuous improvement.
18. Policy Review
This policy will be reviewed at least annually and sooner if required due to:
- changes in COSHH, health and safety, waste, medicines, infection prevention or adult social care legislation;
- changes to CQC guidance, HSE guidance, DHSC guidance or recognised best practice;
- introduction of new hazardous substances, equipment, medicines-related tasks or work activities;
- serious incidents, near misses, exposure events, outbreaks or spill events;
- safeguarding concerns linked to hazardous substances or environmental risk;
- audit findings or quality assurance concerns;
- staff feedback, complaints or whistleblowing concerns;
- changes in the service model, premises, supported living arrangements or people’s needs.
The Registered Manager is responsible for ensuring that the policy is implemented, monitored and reviewed, and that staff are informed of any changes relevant to their role.
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}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.