COSHH Compliance for London Commercial Cleaning Contractors: What Every Facilities Manager Must Verify
COSHH is one of those acronyms that sits very comfortably in facilities management vocabulary right up until the moment someone asks for specifics. Most people in the industry know it stands for Control of Substances Hazardous to Health, know in a general sense that it involves chemicals and paperwork, and could probably pick it out of a regulatory lineup. Fewer could say with confidence exactly what their cleaning contractor is legally required to have in place, what documentation they should be able to produce on request, or what the practical consequences look like when something has been missed.
This article is for that second group. COSHH compliance in commercial cleaning is not especially complicated once you understand its structure – but it is non-negotiable, it is regularly under-evidenced by contractors who really ought to know better, and it is ultimately the facilities manager’s problem when it goes wrong on their premises. Let’s go through what it actually requires, and what you should be verifying.
What COSHH Is – and Why Cleaning Is Squarely in Its Sights
The Control of Substances Hazardous to Health Regulations 2002 place a legal duty on employers to assess and control the risks arising from hazardous substances used at work. For most industries, COSHH sits in the background as a moderately relevant piece of legislation. For commercial cleaning, it is front and centre.
The reason is obvious: cleaning is a chemically intensive occupation. Disinfectants, bleach-based products, acidic descalers, solvent-based degreasers, enzyme treatments, drain cleaners, and specialist surface treatments are the everyday toolkit of a commercial cleaning operation. A number of these substances are corrosive, sensitising, or toxic at certain concentrations. Several can interact dangerously if stored or used incorrectly. And the people applying them are often working in confined spaces, using spray equipment that creates inhalable mists, and doing so across multiple premises in a single shift.
The Health and Safety Executive does not consider cleaning a low-risk activity, and neither should the facilities managers responsible for the buildings in which it takes place.
The COSHH Assessment – What It Must Actually Cover
The centrepiece of COSHH compliance is the risk assessment, which the regulations require to be “suitable and sufficient.” That phrase is doing quite a lot of work. In practice, it means the assessment must identify every hazardous substance used, consider the realistic ways in which workers could be exposed, evaluate the risk that exposure presents, and document the control measures in place to reduce that risk to an acceptable level.
For a commercial cleaning contractor, this means a separate COSHH assessment for each product in their inventory – not a single generic document covering “cleaning chemicals” as a category. A quaternary ammonium disinfectant, a sodium hypochlorite bleach solution, and a phosphoric acid descaler each present different hazard profiles, exposure routes, and control requirements. Lumping them together is not suitable, is not sufficient, and will not satisfy an HSE inspector.
The Control Hierarchy – PPE Is the Last Resort, Not the First
One of the most commonly misunderstood aspects of COSHH in cleaning is the control hierarchy. The regulations require employers to work through a prioritised sequence of control measures: eliminate the substance if possible, substitute it with something less hazardous, enclose the process to prevent exposure, apply engineering controls such as ventilation, and only then – as a last resort – rely on personal protective equipment.
This matters in practice because a great many cleaning contractors default to handing staff a pair of gloves and considering the matter resolved. Gloves are appropriate PPE and should absolutely be used. But if a particular product could be substituted with a less hazardous formulation without meaningful loss of efficacy – and in many cases it can – the regulations expect that substitution to have been considered and documented before PPE became the primary control. Facilities managers should ask to see evidence of this process, not simply a list of PPE issued.
Safety Data Sheets – The Document Every Contractor Must Hold
Every hazardous substance used by a cleaning contractor should be accompanied by a current Safety Data Sheet, or SDS – a standardised sixteen-section document provided by the manufacturer that covers the substance’s properties, hazards, safe handling requirements, storage conditions, exposure limits, first aid measures, and emergency procedures.
Safety Data Sheets are not optional background reading. They are the foundational reference document for the COSHH assessment, and they must be current – suppliers update them when formulations change or new hazard data emerges, and an SDS from 2015 may no longer accurately reflect the product being used today.
Facilities managers should verify that their contractor holds a current SDS for every product used on their premises. This is a straightforward request. Any contractor who cannot produce these documents, or who produces documents that haven’t been reviewed in several years, is operating a COSHH programme that is incomplete at its foundation.
Staff Training – What Workers Must Actually Know
A COSHH assessment sitting in a folder in a contractor’s office is not, by itself, compliance. The regulations require that workers are informed, instructed, and trained on the risks from the substances they use and the control measures in place. In practical terms, this means cleaning staff must understand what the hazardous substances in their kit actually are, what health effects exposure can cause, how to use them safely, what PPE is required and why, and what to do in the event of an accidental spill, splash, or ingestion.
This is worth scrutinising carefully, because COSHH training in cleaning is an area where the gap between what contractors claim and what workers actually know can be substantial. A laminated sheet on the cleaning trolley does not constitute training. A signature on an induction checklist from three years ago is not sufficient for a worker now using a different product range on a different contract.
Dermatitis and Occupational Asthma – The Real Risks at Stake
It’s worth pausing on why the training requirement exists, because the health consequences of inadequate COSHH control in cleaning are genuine and well-documented. Occupational contact dermatitis – skin damage caused by repeated exposure to cleaning chemicals, particularly wet work and detergent contact – is one of the most prevalent occupational illnesses in the UK. Occupational asthma caused by sensitisation to spray cleaning products, particularly certain disinfectants and fragranced formulations, is a recognised and serious condition.
These are not theoretical risks dressed up in regulatory language. They are conditions that end careers. A cleaning operative who develops chemical sensitisation may find they cannot work with entire categories of product for the remainder of their working life. The COSHH framework exists to prevent this – and when it fails, it fails real people.
Storage, Labelling, and Segregation on Your Premises
COSHH compliance extends to how cleaning chemicals are stored in the buildings where they are used. This is an area where facilities managers have direct oversight and direct responsibility, regardless of whether the cleaning operation is outsourced.
Chemicals must be stored in their original, correctly labelled containers – not decanted into unlabelled bottles or repurposed food containers, which sounds like an obvious point until you check the cleaning cupboard on your fourth floor. Products that react dangerously with one another – bleach and acidic descalers being the classic example, which together produce chlorine gas with cheerful efficiency – must be segregated in storage. Quantities on site should be limited to what is reasonably needed for the work in hand, and storage areas should be secure, ventilated, and clearly signed.
Facilities managers should walk their cleaning storage areas periodically. What you find there tells you a great deal about the rigour of a contractor’s COSHH programme in practice rather than on paper.
Health Surveillance – When It Is Required and What It Involves
For certain categories of substance and exposure, COSHH requires employers to put health surveillance in place for affected workers. In a commercial cleaning context, this is most relevant where staff are regularly exposed to substances known to cause occupational asthma or dermatitis – which, given the product ranges involved, covers a meaningful portion of the industry.
Health surveillance in this context does not necessarily mean full medical examinations. For skin conditions, it can involve structured self-checks supported by management review, with escalation to occupational health when symptoms are identified. For respiratory risks, more formal spirometry testing may be appropriate. The important point is that a system exists, that it is documented, and that it is actually used – not simply listed in a COSHH policy as something the contractor “may implement where required.”
What Facilities Managers Should Be Asking For – and Verifying
Bringing this together into practical terms, here is what a facilities manager should expect to be able to verify from any commercial cleaning contractor operating on their premises.
A complete, product-specific COSHH assessment file, reviewed within the past twelve months or whenever the product range changes. Current Safety Data Sheets for every product in use on site. Evidence of COSHH training for all staff deployed to the contract, with records of when that training was delivered and refreshed. Documented PPE provision with evidence that the control hierarchy was worked through before PPE became the primary measure. Clear chemical storage arrangements on site that comply with segregation and labelling requirements. And, where relevant, a health surveillance protocol with records of how it is being implemented.
None of this is bureaucratic excess. COSHH enforcement by the HSE can result in improvement notices, prohibition notices, and prosecution. More significantly, a COSHH failure that results in a worker’s injury on your premises involves your organisation in liability questions that no facilities manager wants to be answering. The verification steps above are not onerous to request. A contractor who is genuinely compliant will produce this documentation without hesitation.
One who hesitates at length is telling you something important.
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