HSE COSHH regulations: questions and practical solutions

COSHH (Control of Substances Hazardous to Health) is a core UK legal framework for managing risks from hazardous substances at work. For many sites, COSHH compliance becomes most visible when something goes wrong: a chemical spill, a leaking drum, a contaminated area, or exposure risk during cleaning and changeovers. This page explains COSHH in a question-and-solution format, with a focus on spill control, spill containment, bunding, drain protection, spill kits, and day-to-day operational controls commonly needed in manufacturing and regulated environments such as pharmaceutical production.

Q1. What are HSE COSHH regulations, and who do they apply to?

Solution: treat COSHH as a risk management system for hazardous substances

COSHH is the set of regulations that require employers to assess and control exposure to hazardous substances to prevent ill health. It applies across UK workplaces where substances can harm health, including liquids, powders, aerosols, vapours, fumes, mists, biological agents, and by-products of processes. HSE expects you to identify hazards, assess risk, implement controls, maintain controls, monitor exposure where appropriate, and prepare for incidents and emergencies.

Practical spill management link: spills are both an exposure route and an environmental release route. COSHH controls are strengthened by physical spill containment (bunds, drip trays, overpacks), rapid response (spill kits), and clear procedures for clean-up and waste handling.

Citation: HSE: COSHH overview and guidance

Q2. Does COSHH cover pharmaceutical manufacturing chemicals and cleaning agents?

Solution: yes, and spill control must match the substance and the process

In pharmaceutical and life science environments, COSHH commonly covers solvents (for example IPA, ethanol, acetone), acids and alkalis (CIP chemicals, pH adjusters), disinfectants, APIs and intermediates, laboratory reagents, and process additives. Many are flammable, toxic, corrosive, sensitising, or harmful to aquatic life. COSHH assessment should reflect not only the SDS but also the real operational context: transfer points, dosing lines, IBC taps, sample ports, drum pumps, decanting benches, waste solvent areas, and cleaning/changeover routines.

Spill control in pharmaceutical manufacturing often needs a fast, clean, and documented response to minimise downtime and protect product areas. Use targeted spill kits, controlled access to spill response equipment, and defined routes for contaminated waste.

Internal reading: Spill Control in Pharmaceutical Manufacturing

Q3. What does COSHH require you to do in practice?

Solution: follow a simple compliance workflow and evidence it

A practical COSHH compliance approach usually includes:

• Identify hazardous substances and where they are used, stored, transferred, or generated.
• Carry out COSHH risk assessments that consider exposure routes and spill scenarios.
• Implement controls (engineering, procedural, PPE, and spill containment) using the hierarchy of control.
• Maintain and inspect controls including bund integrity, drip tray capacity, drain covers, and spill kit replenishment.
• Provide information, instruction and training for safe handling and spill response.
• Plan for emergencies including spill response, first aid, isolation of drains, and safe disposal.
• Review and update assessments after changes, incidents, near-misses, new products, or new processes.

Citation: HSE COSHH guidance

Q4. How do spill kits help with COSHH compliance?

Solution: spill kits provide a controlled, repeatable response to exposure risks

Spill kits support COSHH by enabling a fast, standardised clean-up that reduces worker exposure and prevents spread. A COSHH-aligned spill kit strategy considers:

• Type matching: general purpose, oil-only, or chemical spill kits selected to match site chemicals and SDS advice.
• Location planning: place spill kits at high-risk points (decanting, loading bays, solvent stores, waste areas, lab benches).
• Contents for the task: absorbents, pads, socks, disposal bags, ties, PPE, and clear instructions.
• Response steps: stop the source if safe, contain, protect drains, absorb, collect, label and dispose correctly.
• Restocking and inspection: assign ownership and log checks so kits are always ready.

On higher control sites, spill response may need designated clean-up materials to prevent cross-contamination between areas. Your COSHH assessment should define what can be used where, and how waste is segregated.

Internal link: Spill Kits

Q5. What is bunding, and why does it matter for COSHH and spill control?

Solution: bunding reduces the chance of exposure and uncontrolled releases

Bunding is secondary containment that captures leaks and spills from stored liquids. While COSHH focuses on health, bunding supports COSHH controls by reducing spread, limiting slip hazards, and reducing the time workers spend dealing with a migrating spill. Bunding is also closely linked to environmental compliance duties where a spill could reach drains or watercourses.

Practical examples where bunding strengthens COSHH control:

• Drums and IBCs: use bunded pallets or bunded stores to capture leaks from taps, valves, or damage.
• Decanting stations: bund the transfer area to contain drips and splashes.
• Waste storage: bund waste solvent drums and intermediate waste containers to manage leakage risk.

Internal links: Bunding and Spill Containment | Drip Trays

Q6. How does drain protection fit into COSHH and spill response?

Solution: protect drains early to prevent wider harm and complex clean-up

A common spill escalation is when liquids reach a drain. Even if the immediate COSHH concern is exposure, a drain release can create additional hazards (vapours, confined space risk, wider contamination) and may trigger incident reporting and costly remediation. Your spill procedure should explicitly include drain protection steps, such as deploying drain covers, drain mats, absorbent booms, and temporary bunding, before or during absorbent deployment.

Site example: at loading bays and goods-in areas, keep drain covers near exits and external drainage points, not only inside the warehouse. For solvent handling, ensure that spill response includes ignition source control and ventilation where relevant.

Internal link: Drain Protection

Q7. What documentation do you need to show COSHH compliance after a spill?

Solution: build evidence into your spill control process

After a spill, COSHH-related documentation typically includes:

• Incident record (what, where, when, quantity, cause, affected people/areas).
• Actions taken (containment method, drain protection, absorbents used, PPE used).
• Waste handling records (segregation, labelling, temporary storage, contractor collection).
• Corrective actions (equipment repair, improved bunding, revised transfer methods).
• Review of COSHH assessment to reflect the lessons learned.

This evidence helps demonstrate that controls are effective, maintained, and continually improved, not just written down.

Q8. How do you choose the right spill control products for COSHH-controlled substances?

Solution: use your COSHH assessment and SDS to specify the control measures

Select spill control and spill containment products based on the hazards and the task:

• Corrosives: chemical absorbents, compatible containment, and appropriate PPE defined by the assessment.
• Solvents and flammables: fast containment, ignition control procedures, and suitable waste handling routes.
• Powders and dusts: prevention of airborne release, controlled clean-up methods, and suitable disposal.
• High cleanliness environments: pre-defined kit placement and dedicated materials to avoid cross-contamination.

Where multiple substances are present, standardise around clear spill kit labelling and location maps, and train teams using realistic spill scenarios from your own process steps.

Internal links: Spill Kits | Spill Containment and Bunding | Drip Trays

Q9. What are common COSHH spill-control gaps, and how do you fix them?

Solution: address predictable failure points before they become incidents

Common gaps include:

• Kits that do not match the chemicals (for example, general absorbents used where chemical absorbents are required). Fix: align spill kit type to the COSHH assessment and SDS.
• Spill kits stored too far from risk. Fix: position kits at points of use and transfer, not only in stores.
• No drain protection step. Fix: add drain covers and include drain isolation in the spill response checklist.
• Bunding absent or undersized in drum/IBC areas. Fix: implement bunded pallets, bunded stores, or bund upgrades and inspect regularly.
• Training is generic. Fix: run task-based spill drills (decanting, dosing, loading bay, waste handling) and refresh regularly.

Q10. Where can I get help improving COSHH spill preparedness on site?

Solution: audit your spill risks and standardise controls across departments

Start by walking the site with a simple checklist: identify where spills are most likely (transfer points, cleaning, waste storage, goods-in), what volume could be released, and how quickly it could reach a drain or walkway. Then standardise spill control: consistent spill kit locations, clearly labelled spill response instructions, bunding where liquids are stored, drip trays under leak points, and drain protection at vulnerable outlets.

If you want to build a more robust spill control programme that supports COSHH compliance, use these starting points:

• Spill Control in Pharmaceutical Manufacturing
• Spill Kits
• Drain Protection
• Bunding and Spill Containment

Note: This page provides general information to support COSHH spill control planning and does not replace a site-specific COSHH assessment or competent safety advice.

Citations: HSE COSHH guidance