Quick answer: A COSHH assessment for a cleaning contractor is not the product manufacturer SDS repackaged in a different format. It is a site and task-specific risk assessment that uses the SDS as a data source to assess how the product is actually being used, by whom, and what controls are appropriate for those conditions. A generic COSHH assessment that covers all your chemicals with one document is not COSHH compliant. This guide covers the correct process for writing a COSHH assessment that would withstand HSE inspection -- and that protects your business and your operatives.
COSHH assessments are one of the most commonly misunderstood compliance documents in the cleaning industry. Many contractors either do not have them at all, have a single generic document that covers all chemicals, or use the supplier SDS as the COSHH assessment itself. None of these approaches satisfies the legal requirement under COSHH Regulations 2002.
COSHH Regulation 6 requires employers to carry out a suitable and sufficient assessment of the risk to health from substances hazardous to health that their employees may be exposed to at work. Suitable and sufficient means specific to the task, the product and the conditions of use -- not generic.
The information you need before writing the assessment
Before writing a COSHH assessment for a cleaning chemical, you need:
- The current Safety Data Sheet for the product -- not the marketing literature. The SDS must be current -- from August 2026, updated GB CLP classifications apply to a range of cleaning and biocidal chemicals. If your SDS is dated before August 2026, check whether the classification has changed. See: Chemical reclassification August 2026
- Section 2 of the SDS -- the hazard identification. This tells you what the product is classified as under GB CLP. This is the starting point for your risk assessment -- not the product name or marketing claims.
- Section 8 of the SDS -- exposure controls and personal protection. This tells you what WEL (Workplace Exposure Limit) applies if any, and what PPE the manufacturer recommends for the intended use.
- How the product is being used -- dilution rate, application method (spray, mop, pressure washer downstream injection, manual wipe), duration of exposure, frequency of use, ventilation in the work area.
- Who is exposed -- cleaning operatives, bystanders, building occupants, members of the public.
The structure of a compliant COSHH assessment
A COSHH assessment for a cleaning chemical should cover:
1. Product identification
Product name, supplier, SDS date and version number, GB CLP classification from Section 2 of the SDS.
2. Tasks covered
Specific cleaning tasks for which this product is used -- for example kitchen degreasing, washroom sanitising, external softwash, mould treatment. A separate assessment (or separate section) for each distinct use.
3. Who is at risk and how
Cleaning operatives (direct exposure during application and dilution), bystanders and building occupants (indirect exposure from vapour, spray drift or residues), emergency scenario (spillage, splash).
4. Exposure assessment
How long are operatives exposed per task? How frequently? What is the application method and how does that affect exposure route (inhalation of spray mist vs skin contact from mopping)? Is there a WEL for any component of the product and is it likely to be approached at the dilution and use conditions specified?
5. Control measures
Working from the COSHH hierarchy:
- Elimination -- can the task be done without this chemical? (For biocides, can mould be removed mechanically before chemical treatment?)
- Substitution -- is there a less hazardous product that achieves the same result?
- Engineering controls -- ventilation, enclosed application systems
- Procedural controls -- dilution rates, minimum effective concentration, restricted access during application
- PPE -- gloves, eye protection, respiratory protection. PPE is the last resort, not the first response. Where RPE is required, each individual wearer must be face-fit tested for the specific RPE model they are using.
6. Emergency procedures
What to do in case of skin contact, eye contact, inhalation or spillage -- from SDS Section 4 (first aid) and Section 6 (accidental release).
7. Health surveillance
Is health surveillance required? COSHH Regulation 11 requires health surveillance where workers are exposed to substances that cause occupational diseases. Some cleaning chemicals -- particularly those causing occupational asthma (spray products containing isocyanates, some enzymatic cleaners) -- trigger this requirement.
8. Review date
COSHH assessments must be reviewed when there is reason to suspect they are no longer valid -- when a product changes formulation, when a new SDS is issued, when a worker is harmed, or when working practices change. The August 2026 GB CLP reclassification is a trigger for review of all COSHH assessments for affected products.
What a COSHH assessment is not
- It is not the SDS -- the SDS is a data source, not the assessment itself
- It is not a generic document covering all chemicals -- it must be specific to each product and each use
- It is not a one-off exercise -- it must be reviewed when circumstances change
- It is not based on marketing claims -- a product marketed as non-toxic still requires a COSHH assessment based on its actual SDS classification
Related guidance
COSHH Regulations 2002 | Biocide labelling compliance | Chemical reclassification August 2026 | Cleaning trade hub | H-Class extraction
