COSHH training: what the law requires
What regulation 12 says COSHH training must cover, who needs it, when to give it again and how to show it was given. Checked against legislation.gov.uk and HSE guidance.
What COSHH training does the law require?
COSHH training is required by regulation 12 of the COSHH Regulations 2002: suitable and sufficient information, instruction and training for every employee liable to be exposed to a hazardous substance.
Regulation 12 lists what it must include. That means the substances by name and their risks to health, any exposure limit and access to the safety data sheets. It also covers the significant findings of your assessment, the precautions to take, and monitoring and health surveillance results.
COSHH does not ask for a certificate, an accredited course or a set number of hours. In practice, a general course written for everyone will not cover the findings of your own assessment, which regulation 12 requires. Induction, task briefings and toolbox talks can all form part of it, provided that together they are suitable and sufficient. The wider law is on the COSHH Regulations explained.
Cleaning and maintenance staff are included: HSE names them in its COSHH training guidance. A free online course with a certificate can cover the general theory, but not your products, your assessment or your precautions.
What regulation 12 says COSHH training must include
Regulation 12(2)Regulation 12(1) sets the duty: suitable and sufficient information, instruction and training. Regulation 12(2) lists what it must include, without limiting that duty. The wording below is quoted exactly from the current revised text on legislation.gov.uk.
| Item | What regulation 12(2) says | On a typical job |
|---|---|---|
| Names and risks | “the names of those substances and the risk which they present to health” | The products on the job by name, such as the two-pack floor paint, the resin anchor and the cleaning chemicals, and what each can do to health. |
| Exposure limits | “any relevant workplace exposure limit or similar occupational exposure limit” | Where a substance on the job, or the dust or fume the work makes, has a workplace exposure limit in EH40. |
| Safety data sheets | “access to any relevant safety data sheet” | Operatives know where the safety data sheets are and can read them. L5 accepts a plainer in-house summary, but the sheet must still be available. |
| Other law on the same substances | “other legislative provisions which concern the hazardous properties of those substances” | L5 gives REACH and DSEAR as examples, for substances that are also flammable, oxidising or explosive. Solvent thinners are a common case. |
| Your assessment | “the significant findings of the risk assessment” | What your own COSHH assessment found for this task, and the controls it relies on. No generic course can supply this. |
| Precautions | “the appropriate precautions and actions to be taken by the employee in order to safeguard himself and other employees at the workplace” | Using the on-tool extraction, wearing the specified gloves and RPE, and protecting the trades working nearby. |
| Monitoring results | “the results of any monitoring of exposure in accordance with regulation 10 and, in particular, in the case of a substance hazardous to health for which a workplace exposure limit has been approved, the employee or his representatives shall be informed forthwith, if the results of such monitoring show that the workplace exposure limit has been exceeded” | Air sampling results are shared with the employees liable to be exposed. An exceedance is reported at once, not at the next briefing. |
| Health surveillance results | “the collective results of any health surveillance undertaken in accordance with regulation 11 in a form calculated to prevent those results from being identified as relating to a particular person” | Anonymised group results from health surveillance, never one named person’s. |
| Group 4 biological agents | “where employees are working with a Group 4 biological agent or material that may contain such an agent, the provision of written instructions and, if appropriate, the display of notices which outline the procedures for handling such an agent or material” | Not met in ordinary trades work. Listed here because the regulation lists it. |
Regulation 12(3) adds that it must be adapted to significant changes in the type of work or the methods used. It must also suit the level, type and duration of exposure the assessment identifies. Source: COSHH regulation 12.
What HSE’s L5 adds to the list
HSE’s Approved Code of Practice, L5, spells out what instruction and training should let people do. Each row says whether the point is ACOP, HSE guidance or the regulation itself.
How and when to use the controls
The instruction must be sufficient for people to know how and when to use the control measures, and the defined methods of work. HSE’s INDG136 adds: show workers how to use controls properly and how to check they are working.
L5 ACOP, paragraph 265; HSE INDG136Gloves, masks and RPE
People need to know how to use PPE, and especially RPE. That includes removing and refitting gloves and masks, and how long gloves can be worn before liquid contamination is liable to permeate them. INDG136 adds that respirator users also need face fitting and training: see face fit testing.
L5 ACOP, paragraph 265; HSE INDG136Cleaning, storage and disposal
People need to know the cleaning, storage and disposal procedures, why they are required and when. L5’s example: clean contaminated PPE with water or a vacuum fitted with a HEPA filter, not with an airline. They also need to know the risks of using contaminated PPE.
L5 ACOP, paragraph 265Emergencies and spills
Training covers the procedures to follow in an emergency, prepared under regulation 13. INDG136 says to practise cleaning up spills safely before any spillage happens.
L5 ACOP, paragraphs 255 and 265; HSE INDG136Hygiene and health surveillance
Where appropriate, information also covers when to use the washing and hygiene facilities provided. It covers the purpose of health surveillance, the duty to attend at the appointed date and time, and access to personal health records.
L5 ACOP, paragraph 255Theory and practice
Training should include theory as well as practice. Training on controls and PPE should take account of the manufacturer’s recommendations and instructions. INDG136 is blunter: it is poor practice just to hand people a page of written information.
L5 ACOP, paragraph 266; HSE INDG136Pitched at the level of risk
Information must be comprehensible, under the Management Regulations. L5 guidance warns against giving so much information that it overburdens and confuses people. Where a substance is not particularly hazardous and exposure is adequately controlled, basic instructions and training may be all that is required.
MHSW regulation 10; L5 guidance, paragraphs 261 and 262Who needs COSHH training
Every employee liable to be exposed
The duty is owed to each employee whose work is liable to expose them to a substance hazardous to health. That includes the operative who only mixes the mortar or cleans out the spray gun.
COSHH regulation 12(1)Cleaning and maintenance staff
HSE names them in its COSHH training guidance. A cleaning operative using concentrates, a caretaker clearing drains and a maintenance fitter changing filters all need it. Where a decanted bottle is not labelled under other law, regulation 12(5) requires its contents and hazards to be clearly identifiable.
HSE, training for employeesOther people on the premises
So far as is reasonably practicable, the information and training duty extends to people who are not your employees but may be affected by the work. That applies only while they are on the premises where the work is done, such as other trades or the client’s staff.
COSHH regulation 3(1)Contractors working for you
HSE says a contractor coming on site needs to know the risks and how you control them. You also need to know what hazardous substances they bring. The Management Regulations require you to give their employer comprehensible information on the risks and your control measures. Anyone working in your undertaking who is not your employee must get appropriate instructions and comprehensible information on those risks.
MHSW regulation 12(1) and (3); HSEPeople doing your COSHH work
Anyone, employee or not, who does work connected with your COSHH duties needs suitable and sufficient information, instruction and training. That covers whoever writes the assessment, examines the LEV, takes air samples or runs health surveillance. L5 says they need adequate knowledge, training and expertise.
COSHH regulation 12(4); L5 ACOP, paragraph 269Supervisors and managers
HSE’s training leaflet says supervisors and managers may need training in the specific hazards of the work and how the risks are to be controlled. They are often the people checking that controls are actually used.
HSE INDG345The self-employed
Since 1 October 2015, COSHH applies to a self-employed person only if their work is of a prescribed description. That includes any work on a construction site and any activity that may put other people at risk. They are treated as both employer and employee, so in practice they need the regulation 12 knowledge for their own work. Monitoring and health surveillance do not apply to them. HSE adds that someone working under your control and direction may count as your employee for health and safety, even if self-employed for tax.
COSHH regulation 3(2) and (2A); SI 2015/1583; HSE INDG345Agency workers
The agency or employment business is often the legal employer. HSE says day-to-day responsibility sits with the business directing the work, as it is best placed to manage the risks. COSHH extends your information and training duty to them, so far as is reasonably practicable, on the premises where the work is done. You must give the worker comprehensible information on any special skills the job needs and any health surveillance required. The agency must be told the skills needed and the features of the job that affect health and safety. Agree who covers what before the worker starts.
COSHH regulation 3(1); MHSW regulation 15; HSEYoung workers and apprentices
Before employing anyone under 18, the assessment must be made or reviewed for them. It must take particular account of their inexperience, their exposure to chemical agents and the training they get. Work involving harmful exposure to toxic or carcinogenic agents is barred for them. The exception is someone over school age, where the work is necessary for their training, a competent person supervises and the risk is as low as reasonably practicable. HSE says to check they have understood their training, and that they may need closer supervision.
MHSW regulations 3(4), 3(5) and 19; L5 ACOP, paragraph 59; HSEWorkers with limited English or reading
Information must be comprehensible, so it has to reach people who read little English or none. HSE says it need not be in writing, or even in English, as long as the risks, precautions and emergency procedures are clearly communicated. Plain language, demonstration, hazard pictograms and a bilingual colleague or professional interpreter all help. Check that each person has understood. HSE’s INDG345 also names people with poor literacy and those with sight or hearing difficulties.
MHSW regulation 10; L5 guidance, paragraph 262; HSEWhen COSHH training is given and refreshed
No fixed interval in lawNo regulation sets a refresher period for COSHH training, such as yearly. The law ties training to events instead. These are the points at which it is due.
On recruitment
Health and safety training is given when someone is recruited. L5 guidance says new employees should have proper induction training, which should always cover emergency and evacuation procedures.
NoteMHSW regulation 13(2)(a); L5 guidance, paragraph 262.
On new or increased risks
Training is given when someone is exposed to new or increased risks. That includes a transfer, new responsibilities, new or changed work equipment, new technology or a new system of work. A decorator moving onto two-pack isocyanate coatings is a typical case.
NoteMHSW regulation 13(2)(b).
When the work changes significantly
Regulation 12 training is adapted to significant changes in the type of work or the methods used. L5 gives examples: a change in the amount of a substance used or produced, new control measures, new substances on site or automation.
NoteCOSHH regulation 12(3)(a); L5 ACOP, paragraph 263.
After the assessment is reviewed
People are told why the assessment was reviewed, how the work will change and what precautions to take.
NoteL5 ACOP, paragraphs 255 and 263.
When monitoring or surveillance results arrive
Monitoring results and collective health surveillance results are shared. If monitoring shows a workplace exposure limit exceeded, employees or their representatives are told forthwith.
NoteCOSHH regulation 12(2)(d) and (e).
Periodically, where appropriate
Health and safety training is repeated periodically where appropriate. HSE suggests monitoring training records so refresher training is given when needed.
NoteMHSW regulation 13(3)(a); HSE INDG345.
Training under the Management Regulations takes place during working hours. HSE’s INDG345 adds that it must not be at the employee’s expense. Section 9 of the 1974 Act bars charging employees for anything done or provided under a specific requirement of health and safety law, which includes regulation 12.
COSHH courses and certificates
Many people search for a free COSHH course with a certificate. The direct answer is that COSHH does not require one. Regulation 12 asks for suitable and sufficient information, instruction and training. Neither regulation 12 nor L5’s guidance on it mentions a certificate, an accredited course, a qualification or a minimum number of hours. Other regulations, such as those on asbestos, set training rules of their own.
L5 guidance leaves the method to the employer. It lists class or group tuition, individual tuition, and written instructions, including leaflets and courses. HSE’s INDG345 says training is not just about formal classroom courses, and that much effective training can be done in-house.
A general COSHH awareness course, free or paid, can help with the theory: what a hazardous substance is, how it enters the body, how to read a label. Its certificate shows the person completed that course. A course written for everyone will not know the significant findings of your own assessment, or the precautions for your products on your jobs. In practice, those parts of regulation 12 come from you or from a trainer you have briefed.
Open and distance learning and computer-based learning are among the methods INDG345 lists. L5 says training should include elements of practice as well as theory. In practice, the hands-on parts are best shown in person, such as fitting a mask, taking off contaminated gloves and running a spill drill.
A client or principal contractor may ask for a certificate as a condition of work. That would be a term of their contract, not a requirement of regulation 12. If you use an outside trainer or adviser, regulation 12(4) requires them to have suitable and sufficient information, instruction and training. L5 says that includes the particular circumstances of your work and the substances used.
How to record COSHH training
COSHH does not require a written training record, but HSE advises keeping basic training records. L5 guidance says why they help. Records work as a checklist that people get the right training at the right time, and they can help settle disputes about whether someone was told.
A useful record names the person, the date, the substances or task covered, who gave the training and how. A signature from each operative shows the briefing was received. Keep the version of the assessment it was based on, so the record shows what people were told and when.
Two common formats suit trades firms. A training matrix lists each person against the substances and processes they have been trained on, with the date. A signed toolbox talk register records the short briefings given on site.
Sources: HSE, training for employees working with substances hazardous to health; L5 guidance, paragraph 267; HSE INDG345.
Every data sheet to hand,
tied to the job that uses it.
In Unibuild, each hazardous substance holds its safety data sheet and its supplier, linked to the jobs, materials and purchase orders that use it. Review dates are tracked, every version is kept, and the current one is the one out on site.
When an auditor or a principal contractor asks for the COSHH register, it is a search by name or supplier, not a spreadsheet somebody else kept.
- A data sheet for every substance held with its supplier
- Tied to the job through the materials and purchase orders that use it
- Review dates tracked and every version kept
- Searched by product name or supplier
Free COSHH templates
Free to use and reuse, no sign-upCOSHH training: common questions
Is COSHH training a legal requirement?
Do I need a COSHH certificate?
Is a free online COSHH course with a certificate enough?
What should COSHH training cover?
Who needs COSHH training?
How often should COSHH training be refreshed?
Do cleaners need COSHH training?
Who can deliver COSHH training?
Can an employer charge employees for COSHH training?
Do I have to keep COSHH training records?
The COSHH guide
Read in any orderSources
Great Britain law and HSE guidance, read on the dates above. Northern Ireland has its own COSHH Regulations.
- COSHH Regulations 2002, regulation 12: information, instruction and training (legislation.gov.uk)
- COSHH Regulations 2002, regulation 3: duties (legislation.gov.uk)
- Management of Health and Safety at Work Regulations 1999, regulation 13: capabilities and training
- Management of Health and Safety at Work Regulations 1999, regulations 10 and 12: information
- Management of Health and Safety at Work Regulations 1999, regulation 15: temporary workers
- Management of Health and Safety at Work Regulations 1999, regulation 19: protection of young persons
- Health and Safety at Work etc. Act 1974, section 2: general duties of employers
- Health and Safety at Work etc. Act 1974, section 9: duty not to charge employees
- General Duties of Self-Employed Persons (Prescribed Undertakings) Regulations 2015, SI 2015/1583
- HSE L5, Control of substances hazardous to health, ACOP and guidance, sixth edition 2013
- HSE, Training for employees working with substances hazardous to health
- HSE INDG136, Working with substances hazardous to health: a brief guide to COSHH
- HSE INDG345, Health and safety training: a brief guide
- HSE, Health and safety for gig economy, agency and temporary workers: roles of suppliers and end user businesses
- HSE, Young people at work: training and supervision
- HSE, Employing migrant workers: help with language issues
The COSHH register,
tied to the job.
Unibuild keeps each substance’s data sheet and supplier against the jobs, materials and purchase orders that use it, with review dates tracked and every version kept.