Phoenix Journal · LEV & Air Quality
A COSHH assessment is meant to change what happens on the floor, not just fill a folder. Done properly it drives real controls; done as a box-ticking form, it protects nobody and convinces no inspector.
Ask what a COSHH assessment is and many people will point at a form. That is the root of most of the trouble. The Control of Substances Hazardous to Health Regulations 2002 do not ask for a document; they ask for a system, a structured way of finding out what hazardous substances a workplace involves and then deciding, and doing, what is needed to control them. The paperwork is only the record of that thinking. When the form becomes the point, the protection quietly disappears.
The HSE frames COSHH compliance as eight linked steps, and skipping any of them leaves a gap. In outline: identify the hazardous substances present, including those produced by processes such as cutting or welding; decide who could be harmed and how; evaluate the risks; put controls in place using the hierarchy of control, from elimination down to PPE; ensure those controls are used and maintained; monitor exposure where needed; carry out health surveillance where a substance can cause identifiable disease; and provide information, instruction and training, then review it all when anything changes. An assessment is suitable and sufficient only if it works through that whole chain, not just the first link.
Where assessments go wrong
The single most common failure is inverting the hierarchy. An assessment that identifies a hazard and concludes, in effect, that gloves and a mask will be issued, has skipped the entire question the regulations are built around: could this be eliminated, substituted, or engineered out first? The HSE has been clear that PPE-only solutions rarely demonstrate adequate control, and an assessment that reaches for personal protection before considering higher measures is usually inadequate on its face. Where a substance has a workplace exposure limit, keeping below it is only the minimum; for carcinogens, mutagens and asthma-causing substances, exposure must be reduced as low as reasonably practicable regardless of the limit.
The second common failure is treating the assessment as a one-off. A COSHH assessment is a living document that must be reviewed regularly and whenever something changes, a new substance, a modified process, a different pattern of work, an incident, or health surveillance results suggesting the controls are not holding. An assessment written once and filed for a decade describes a workplace that no longer exists. And because the controls it specifies are the whole point, the assessment has to connect to the systems that keep those controls working, rather than ending at the moment the form is signed.
That connection is where paperwork meets reality. The controls a COSHH assessment relies on must be maintained in efficient working order, and for engineering controls that duty is specific: under Regulation 9, local exhaust ventilation must be thoroughly examined and tested by a competent person at least every fourteen months, with records kept. Where exposure is uncertain, air monitoring confirms whether controls are working, and where a substance can cause disease, health surveillance provides an early warning. None of this is optional decoration; it is what turns a stated control into a proven one.
The substance in the room
The difference between a real assessment and a generic one shows the moment you apply it to an actual substance. Take welding fume: a proper COSHH assessment does not stop at issuing a mask, it works through capturing the fume at source, testing that extraction, providing fit-tested RPE for the residual and health surveillance for regular welders, which is exactly what managing welding fume beyond just buying extraction lays out. A template that could describe any workshop describes none of them well; the substance, the task and the controls have to be specific to the work actually being done.
The check that keeps it honest
The reason the fourteen-month LEV test matters so much is that it is the point where an assessment stops being a claim and becomes evidence, and it is one of the most common things inspectors find missing, a dusty extraction unit with a faded examination sticker and no recent record. Keeping that test current is part of the wider truth that controls protect people only while they actually function, which is also why how ventilation affects health, comfort and productivity is not a soft concern but a measurable one. A COSHH assessment done as it should be does not end when the form is filed; it ends, and begins again, every time the controls are checked and proven.
Questions
Identify the hazardous substances, decide who could be harmed and how, evaluate the risks, apply controls using the hierarchy of control, ensure controls are used and maintained, monitor exposure where needed, carry out health surveillance where relevant, and provide information, instruction and training, reviewing the assessment when anything changes. Missing any step leaves a gap.
If you have five or more employees, the significant findings of the assessment must be recorded. Even with fewer, writing it down is sensible. But the record is not the assessment itself; the assessment is the process of identifying and controlling the risk, and a written form that does not reflect real, maintained controls does not meet the duty.
Local exhaust ventilation must be thoroughly examined and tested by a competent person at least every fourteen months, with records kept, under Regulation 9 of COSHH. Some processes require more frequent testing. It is one of the most commonly failed areas at inspection, so the examination should be diarised and the certificate kept with the assessment.
Phoenix Duct Clean · by the numbers
The most common COSHH failure is LEV that is never tested. Phoenix supports extraction that is examined and evidenced, not just installed. UK-wide.