COSHH for Cleaning Products: UK Employer Duties Under HSE Rules (2026)

Quick answer: The Control of Substances Hazardous to Health Regulations 2002 (COSHH) cover most UK workplace cleaning products. Employer duties: maintain a register of products and their hazards, complete a risk assessment for each (or each process), implement exposure controls, train staff, supply appropriate PPE, monitor exposure, and provide health surveillance where indicated. HSE inspects these records during workplace visits — and the cleaning sector accounts for a meaningful share of COSHH prosecutions every year.

"It's just a cleaning product" is the line HSE inspectors hear most often before they issue improvement notices. Bleach, ammonia, descalers, drain unblockers, disinfectants — every one of them is a COSHH-regulated substance the moment a UK employee uses them at work. This guide is what every UK employer should know before the inspector arrives.

What COSHH covers

COSHH 2002 applies to any substance classified as hazardous under the GB CLP Regulation that's used, stored, or generated in a workplace. For cleaning, that includes:

• Bleach (sodium hypochlorite) — corrosive, toxic on contact and inhalation
• Ammonia-based cleaners — corrosive, respiratory irritant, dangerous mixed with bleach (chlorine gas)
• Descalers (acidic) — corrosive, eye and skin damage
• Drain cleaners (alkaline or acidic concentrates) — severe burns risk
• Oven cleaners (caustic) — corrosive
• Disinfectants (quaternary ammonium, glutaraldehyde) — sensitizers, respiratory effects
• Solvent cleaners (benzene-free degreasers) — flammable, vapour exposure
• Dust from sweeping or stripping — silica, asbestos potential, lead in older buildings

The five COSHH duties for employers

1. Assess the risks — for every hazardous substance and every process where it's used
2. Decide what precautions are needed — substitution, engineering controls, PPE, training
3. Prevent or adequately control exposure — favour elimination/substitution before PPE
4. Ensure controls are used and maintained — including PPE inspection, ventilation servicing
5. Monitor exposure where appropriate — air monitoring, health surveillance, biological monitoring

Safety Data Sheet (SDS) — the foundation

Every supplier of a hazardous chemical must supply an SDS in 16 sections. The sections most relevant for COSHH:

• Section 2: Hazard identification and CLP classification
• Section 3: Composition / ingredients
• Section 4: First aid measures
• Section 7: Handling and storage
• Section 8: Exposure controls / PPE
• Section 11: Toxicological information
• Section 13: Disposal

Keep an SDS for every product on site, in a single accessible folder (digital or paper). Inspectors will ask "show me the SDS for this bottle" — you should produce it within minutes.

Risk assessment — what good looks like

Per process or per product, document:

• Product name, supplier, SDS reference
• Hazard classification (corrosive, toxic, irritant, sensitiser, flammable)
• Who uses it (named roles, contractor categories)
• How they use it (decanting, dilution, application, frequency)
• Identified risks (skin contact, inhalation, splashes, mixing accidents)
• Existing controls (ventilation, dilution practice, PPE, signage)
• Adequacy assessment of those controls
• Recommended additional controls
• Review date and trigger conditions

Substitution — the first thing to consider

HSE expects employers to ask: "is there a less-hazardous alternative?" Examples that pass scrutiny:

• Replacing concentrated bleach with diluted hypochlorite tablets
• Using citric acid descaler instead of hydrochloric acid
• Steam cleaning instead of solvent degreasing
• Microfiber cloth and water for routine surface cleaning

If substitution is feasible and not implemented, that's a finding at HSE inspection.

Decanting and dilution

The single most-cited cleaning sector COSHH issue: chemicals decanted into unlabelled bottles. Every decanted container must:

• Carry the same hazard pictograms and signal words as the original
• Show product name and concentration if diluted
• Be opaque or otherwise prevent inadvertent reuse
• Be disposed of properly when empty

Training records

Every staff member using cleaning products needs documented training. Records show:

• Who was trained, when, by whom
• Products and processes covered
• Practical demonstration recorded
• Refresher schedule

HSE inspections routinely sample staff and ask "show me how you'd dilute X" — visible competence is the test.

PPE

The SDS specifies minimum PPE per product. Common requirements:

• Bleach: chemical-resistant gloves (nitrile, not latex), eye protection, apron
• Descalers: acid-resistant gloves, face shield, apron
• Drain cleaners: gauntlets, face shield, full-cover apron, ventilation
• Disinfectants: gloves; respiratory protection if spray-applied

PPE issue records (size, type, replacement schedule) and inspection logs are part of the audit trail.

Health surveillance triggers

Required where:

• Workers handle respiratory sensitisers (some disinfectants, formaldehyde-based)
• Skin sensitisers in regular contact (some quaternary ammonium compounds)
• Substances with long-term health effects (formaldehyde, glutaraldehyde)

Surveillance ranges from simple skin checks to occupational health questionnaires to lung function testing.

Cleaning contractors and sub-contractor duties

If you engage a cleaning contractor on your site, you remain responsible for the workplace under section 4 of HSWA 1974. Contract should require:

• Contractor's COSHH register and risk assessments for products used on your site
• Training records for staff working on your site
• SDS access
• Incident reporting back to you

Common mistakes

1. Decanted spray bottles with no labelling
2. Bleach and ammonia stored adjacent — lethal if mixed
3. SDS folder out of date by 3+ years
4. Risk assessment in template form not customised for the actual site
5. No record of PPE issue or inspection
6. "Always done it this way" used as a defence at inspection

FAQs

Are over-the-counter cleaners exempt because they're "consumer products"?

No. The hazard classification doesn't change between consumer and workplace use. COSHH applies once the product enters the workplace.

Do offices need COSHH for cleaning?

Yes. Office cleaners use the same chemicals — bleach in toilets, descaler in kettles, disinfectant on desks. The risk assessment may be light-touch, but it must exist.

What if a member of the public is exposed?

HSWA section 3 protects non-employees. An exposure incident affecting a customer or contractor is reportable under RIDDOR if it meets the criteria (over-7-day injury, hospital admission, dangerous occurrence).

How do I record a near-miss?

In the COSHH incident log, with date, product, exposure route, person affected, immediate action, and follow-up. Near-misses without injury still drive risk assessment review.

Related guides

• COSHH assessment records: UK employer duties
• Site accident book: UK legal requirements
• Work at height regulations

Sources and further reading

• HSE: Control of substances hazardous to health
• COSHH Regulations 2002
• GB CLP Regulation (retained EU)
• HSE: Cleaning industry safety guidance

Last reviewed 2026-04-28 by Jamie Dawson, Editor. Corrections: corrections@logbook.co.uk