COSHH in Schools: From Paperwork to Real Assurance

In many schools, COSHH appears to be under control, until someone needs to evidence it.

A folder exists. Risk assessments were completed at some stage. Safety Data Sheets are stored somewhere on the system. Cleaning products are in use, catering chemicals are delivered regularly, and contractors attend site as expected.

Then an audit takes place, an incident occurs, or a senior leader asks for assurance, and gaps quickly become visible.

This is where many schools find the real challenge with COSHH. Not in understanding that duties exist, but in knowing whether arrangements are genuinely effective, current and consistently applied.

Why COSHH becomes difficult to manage

The Control of Substances Hazardous to Health Regulations 2002 require employers to prevent or adequately control exposure to hazardous substances. In a school setting, that sounds straightforward. In practice, responsibility is often spread across several areas, each operating differently.

Typical COSHH risks may sit within:

• Cleaning teams and contractors
• Catering operations
• Premises and maintenance work
• Science departments
• Design and Technology areas
• External specialist contractors

Each may hold products on site, introduce new substances, store items differently and manage records separately. Without clear oversight, it becomes easy for no one to hold the full picture.

Common gaps schools encounter

Across the sector, the same issues appear regularly:

• Registers that have not been updated when products changed
• Missing or outdated Safety Data Sheets
• Risk assessments copied forward without review
• Hazardous substances stored incorrectly
• Contractors using products with limited school oversight
• Unclear ownership of COSHH records
• Staff using substances without suitable instruction

None of these gaps are usually caused by a lack of care. More often, they are the result of limited time, competing priorities and fragmented responsibility.

Why contractor assurance matters

Many schools quite reasonably use external providers for cleaning, catering and maintenance. However, outsourcing a service does not outsource accountability.

Under the Health and Safety at Work etc. Act 1974, the employer still retains core duties to ensure health and safety is being managed.

That means schools should be able to answer practical questions such as:

• What hazardous substances are being brought onto site?
• Are suitable assessments in place?
• Are staff trained to use them safely?
• How are substances stored and controlled?
• What evidence supports that assurance?

If the answer relies on assumption rather than evidence, there is work to do.

What good COSHH management looks like

Strong COSHH management is rarely complicated. It is usually built on clear routines, ownership and regular review.

Schools should aim for:

• A current register of hazardous substances across all departments and contractors
• Up-to-date Safety Data Sheets that are easy to access
• Suitable and specific risk assessments
• Clear storage, labelling and control measures
• Defined responsibility for review and monitoring
• Staff awareness proportionate to their role
• Periodic checks to confirm practice matches paperwork

This moves COSHH from a static file to a live management system.

From compliance to confidence

When COSHH is well managed, the benefits go beyond legal compliance. Schools reduce avoidable risk, improve day-to-day control and make audits, inspections and leadership assurance far easier.

Most importantly, they create safer environments for staff, pupils and visitors.

How NASPM supports schools

At NASPM, we work with schools that want practical assurance, not paperwork for its own sake. That means helping leaders understand where risks commonly sit, what good looks like in practice, and how to build systems that stand up to scrutiny.

A useful starting point is a simple question:

If someone asked for evidence of effective COSHH management today, could you provide it quickly and confidently?

If not, now is the right time to review it.