The Control of Substances Hazardous to Health Regulations 2002 require employers to assess and control exposure to hazardous substances. For field teams, the challenge is not writing the assessment: it is getting field workers to read it before they start work. This guide covers what COSHH requires, what the field worker challenge actually is, and how acknowledgement can be recorded on site.
The Control of Substances Hazardous to Health Regulations 2002 (COSHH) implement the Health and Safety at Work Act requirements for substances hazardous to health. They apply to all employers whose workers are exposed to hazardous substances in the course of work.
Regulation 6 requires the employer to make a suitable and sufficient assessment of the risks from exposure. Regulation 7 requires the employer to prevent or adequately control that exposure. Regulation 12 requires the employer to provide employees with suitable and sufficient information, instruction and training on the substances they work with, the risks of exposure, and the control measures in place.
Regulation 12 is the regulation that field teams most commonly fail to comply with, not because the assessment doesn't exist, but because the communication of it to the workers it covers doesn't happen.
COSHH covers a wide range of substances that field workers regularly use or encounter.
Solvents: Used in adhesives, cleaning products, paint strippers, and degreasers. Many solvents are flammable, can irritate skin and eyes, and can cause occupational asthma or neurological effects with repeated exposure.
Adhesives and resins: Used in pipe jointing, flooring, and construction. Isocyanate-based products (used in spray foam insulation and some adhesives) are a leading cause of occupational asthma and require specific respiratory controls.
Cleaning chemicals: Bleach, disinfectants, descalers, and caustic cleaners used by cleaning operatives and maintenance workers. Mixing cleaning chemicals (particularly bleach and acid-based products) can produce toxic gases.
Gases: Engineers working with gas appliances, refrigerants, or in confined spaces may encounter flammable gases, refrigerant gases, or atmospheric hazards.
Biological agents: Workers entering contaminated spaces, working in healthcare settings, or cleaning up after flooding may encounter biological hazards including Legionella, leptospirosis, and other pathogens.
Most firms that employ field workers have COSHH assessments. They were written when the H&S policy was set up, updated when products changed, and are filed on a shared drive or in the site folder. The workers they cover work with the products every day and have not read them since their induction, if they read them then.
This is not primarily a compliance failure. It is a communication failure. The assessment is written for a process. The worker carrying out the process does not have access to the assessment at the point of use. The information gap is where exposure incidents occur.
For site-specific hazard information, a product found at a client site, an unexpected substance encountered during a job, the gap is even wider. The pre-written assessment covers the worker's own products; it cannot cover what they find on site.
The acknowledgement workflow addresses the communication gap. Before a field worker starts a task involving a hazardous substance, the workflow asks them to confirm they have read the relevant COSHH assessment. Where the task involves site-specific hazards, the workflow asks them to identify and photograph any hazardous products found at the site.
The acknowledgement is timestamped. It is tied to the job reference. The record shows that the worker was made aware of the relevant assessment before work started. If an exposure incident occurs, the record is evidence that the information was communicated.
A COSHH acknowledgement workflow in Quickler asks the engineer, before they start the job, to confirm they have read the relevant COSHH assessments for the products they will use. Where the job involves a client site, the workflow asks them to identify any hazardous products encountered at the site and to photograph the product labels. The responses are timestamped and attached to the job record.
The workflow arrives in WhatsApp. The engineer responds as they would to any message. No login, no separate safety management system to open. The acknowledgement happens at the point of need rather than in an induction room three months ago.
The Control of Substances Hazardous to Health Regulations 2002 apply to all employers and self-employed persons who use or are exposed to substances hazardous to health in the course of work. This includes field workers who use cleaning chemicals, solvents, adhesives, gases, and biological agents. If a substance is used in the course of work and it poses a health risk, a COSHH assessment is required.
A COSHH assessment for field workers must identify the substances used or encountered, the nature and degree of exposure (route of exposure, quantity, duration, frequency), who is at risk, the control measures in place to reduce exposure, any PPE required, health surveillance requirements where applicable, and the emergency procedures if exposure occurs.
No. The COSHH Regulations require employers to ensure that employees are given suitable and sufficient information, instruction and training. A COSHH assessment written by the H&S manager and filed on the server provides no protection if the field worker using the substance has never seen it. The assessment must be communicated to the workers it covers.
It can serve as evidence of acknowledgement, provided the message includes sufficient information to identify the assessment (product name, job reference, date) and the worker's response is recorded. A timestamped WhatsApp exchange showing that the worker confirmed they had read the relevant assessment before starting work is more defensible than relying on an unsigned paper record filed months later.
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COSHH assessment — engineer records substances used, controls in place and any incidents on WhatsApp before starting the job.
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