How I Use the Cleaning Materials and COSHH Template with Customers in Pilla
COSHH is one of those areas where the gap between what's written down and what actually happens on the ground is wide. I've walked into businesses that have a COSHH folder sitting on a shelf, full of safety data sheets nobody has read, with staff pouring neat bleach into buckets wearing no gloves. The assessment exists. The control measures don't.
The problem is rarely that people don't care. It's that nobody has shown them what the products can do and what protection they need. That's what this article covers. I'll walk you through what the COSHH Regulations 2002 actually require of you, give you a template you can edit for your own operation, and point out the gaps I see most often when I review these policies with customers.
Key Takeaways
- What is COSHH in health and safety? COSHH stands for the Control of Substances Hazardous to Health Regulations 2002. It requires employers to assess and control exposure to hazardous substances, including cleaning products that can cause harm through skin contact, inhalation, or ingestion
- Why do you need a cleaning materials and COSHH policy? The COSHH Regulations 2002 place a legal duty on employers to protect workers and others from hazardous substances. An HSE inspector will check that you've assessed your cleaning products, documented control measures, and trained your staff on safe use
- How do you set it up in Pilla? Use the knowledge hub template below, edit it to match your operation, and share it with your team through the app so everyone has access and you can track who's read it
- How do you automate the follow-up? Set up Poppi to chase staff who haven't acknowledged the policy and flag when it's due for review
Article Content
Understanding What's Required of You
The Control of Substances Hazardous to Health Regulations 2002 apply to any substance that can cause harm through use at work. Cleaning products are the most common hazardous substances in most workplaces. Bleach, degreasers, oven cleaners, sanitisers, descalers: these are chemicals your staff handle daily, and the law says you have to assess the risks and put controls in place.
Your duty is twofold. You have to protect your employees who use these products, and you have to protect anyone else affected by your work activities. That includes customers, visitors, and contractors. If a member of staff mops a corridor with a product that gives off fumes and a customer walks through it, that's your problem.
The COSHH Regulations require you to assess every hazardous substance used in your workplace, document the risks and control measures, provide PPE where the assessment says it's needed, train staff on the hazards and how to protect themselves, and monitor whether your controls are working. This is not optional. It's a legal requirement, and an HSE inspector will want to see evidence of all of it.
What catches most businesses out is the assessment itself. A COSHH assessment is not a safety data sheet stapled into a folder. It's a documented evaluation of how a specific product is used in your workplace, who's exposed, what could go wrong, and what you've done about it. The safety data sheet is an input to the assessment, not a substitute for it. I've lost count of how many times I've seen a site manager hand me a stack of SDSs and say "that's our COSHH." It isn't.
The other piece that matters is product selection. The hierarchy of control applies here: if you can avoid the hazard altogether by choosing a less dangerous product, that's better than managing exposure to a more dangerous one. I worked with a pub chain that was using industrial-strength oven cleaner across all their sites because someone had ordered it once and it became the default. We swapped it for a product that did the same job with half the hazard rating. No change in cleaning standards, significant reduction in risk.
Setting It Up as a Knowledge Hub Entry
I've built a cleaning materials and COSHH template in Pilla covering product selection, COSHH assessments, PPE provision, staff training, spill response, storage, and monitoring. It gives you a structured starting point, but you need to edit it for your operation.
In the knowledge hub, create a new entry and tag it with "Health and Safety System". Use the same tag across all of your health and safety policies so they are grouped together and Poppi can track them as a set. Assign the entry to all teams so that everyone in the business can access it.
The template is designed to be edited, not just filed. Read through every section. Where it says something generic, replace it with what actually happens in your business. If you don't use cooking oils, remove that reference. If you have specific products that need specific PPE, name them. An HSE inspector wants to see that your policy reflects your operation, not that you've downloaded a generic document and changed the company name.
18. Use of cleaning materials
Control of Substances Hazardous to Health Regulations 2002
Company Name have a duty to protect the welfare safety and health of our employees. This includes working with cleaning and sanitising products to keep our venue clean and safe to prepare services for our clientele. We also have a duty to those who are affected by working practices which will intern include our cleaning protocols and products.
This will be achieved by applying the following safety arrangements:
Responsible persons to identify sanitising and cleaning products which are safe for the preparation of drinks and food stuff, and to avoid use of hazardous substances.
Identify protocols that minimise risk to our customers and ensure cleaning is undertaken regularly and where possible outside of opening hours.
Assess all products to identify if any products have the potential to cause harm when used.
Complete a documented risk assessment for any product used by employees identified as a hazardous substance following initial assessment.
Provide personal protective equipment to staff if identified as required (by risk assessment) for the safe use of the product.
Inform and train all staff on the hazards and risks from the substances with which they work and the use of control measures developed to minimise the risks.
Provide cleaning equipment and spill kits for accidental release of products used, including cooking oils.
Ensure adequate space is provided so the safe storage of cleaning equipment and personal protective equipment
Provide sluice facility for floor cleaning activities.
Monitor and review cleaning processes and control measures for their continued effectiveness.
Assessments/data sheets, which are retained by the Company Name, will be made available to all staff, these include information relating first aid provision. Where additional information is required on a product or process, Responsible Persons must contact the manufacturer for the safety data sheet or instruct a competent person within the organisation to undertake this task on their behalf.
All COSHH Assessments will include the new Hazard Symbols (Pictograms) as per the Code of Practice 2015.
*Responsible Persons are identified on the House Responsibility Chart section of the Health & Safety Policy.
This is a preview of the template. In Pilla, you can edit this to match your business.
What I'd want to see when reviewing this:
The product selection section should show that you've thought about alternatives. Choosing the least hazardous product that does the job is the first step in the hierarchy of control, and it should be obvious from your policy that you do this. If you're using a corrosive product, I'd want to know why a less hazardous alternative won't work.
The COSHH assessment requirement is the core of this policy. Every hazardous substance should have a documented assessment that includes the hazard pictograms (the CLP symbols under the Code of Practice 2015), the exposure routes, the control measures, and the PPE required. The assessment should be specific to how you use the product, not copied from the manufacturer's safety data sheet.
Staff training is the part that turns paper into practice. Your policy says you'll train staff on hazards, risks, and control measures. When I review this with customers, I want to see that training covers what the pictograms mean, what PPE to wear for which product, and what to do if something goes wrong. A member of staff who can't tell you what the corrosion pictogram means hasn't been trained.
Common mistakes I see:
The biggest one is confusing a safety data sheet with a COSHH assessment. The SDS comes from the manufacturer. The COSHH assessment is yours. It should describe how you use the product in your specific workplace, who's exposed, and what controls you've put in place. I see businesses file the SDSs and tick the box. That's not what the regulations require.
PPE provision without training is the second most common gap. Gloves are in the cupboard, but staff don't know which gloves go with which product, or they're using the wrong type. Chemical-resistant gloves for corrosive products and disposable nitrile for irritants are not interchangeable. The COSHH assessment should specify exactly what's needed, and staff should know where to find it.
Storage gets overlooked. Corrosive products stored above head height, incompatible chemicals next to each other, unlabelled containers transferred from bulk. I walked into a kitchen last year where bleach and an acid-based descaler were sitting side by side on the same shelf. Mixing those produces chlorine gas. The template covers storage requirements for a reason.
Spill kits are either missing or empty. The policy says you'll provide them. In practice, the kit was used six months ago and never restocked, or there isn't one at all. If you state in your policy that spill kits are available, they need to actually be there, stocked, and your staff need to know where they are.
Automate the Follow-Up with Poppi
Writing the policy is one thing. Making sure your team has actually read it is another. Poppi can handle the chasing so you don't have to.
If you mark the knowledge hub entry as mandatory, Poppi will track who's read it and who hasn't. You can set up automations to chase staff who are behind, notify managers when someone completes the policy, and get a regular report showing where the gaps are.
Here are three automations I'd set up for any knowledge hub policy:
Tom, you have 2 overdue policies to read and acknowledge
Overdue training reminders
Automatically chase team members who have mandatory policies they haven't read yet. Poppi sends the reminder so you don't have to.
Tom, you have 2 overdue policies to read and acknowledge
Emma has completed a mandatory policy
Video completion alerts
Get notified when a team member finishes reading or watching a policy, so you can track progress without chasing.
Emma has completed a mandatory policy
Training Report: 87% team completion. Tom and Sarah behind on 2 mandatory policies, due 3 days ago.
Training gap analysis
Get a regular AI report showing which team members are behind on mandatory policies and where the gaps are across your team.
Training Report: 87% team completion. Tom and Sarah behind on 2 mandatory policies, due 3 days ago.