COSHH (Control of Substances Hazardous to Health Regulations 2002) is the regulatory backbone of any UK cleaning tender. It is enforced by the Health and Safety Executive. Buyers ask for documented evidence at SQ stage and quality stage, not just a tick-box. Safety Data Sheets attached to the bid. Risk assessment per substance and per task. PPE matrix mapped to product. Named training records. Workplace Exposure Limit (WEL) evidence from HSE EH40 on substances in scope. Lapsed COSHH evidence on any submitted bid is the most common reason cleaning tenders fail at SQ even when the price and method statement are credible.
The cost of getting COSHH wrong is bigger than a lost bid. HSE 2024/25 data: 1.9 million UK workers suffer work-related ill health each year. Around 13,000 deaths annually are linked to past chemical and dust exposures. Improvement Notices, Prohibition Notices, and prosecutions are HSE's enforcement levers. A buyer's compliance team will check your COSHH evidence carefully because the cost of a chemical incident on a public-sector site sits on them.
- COSHH Regulations 2002 set the legal floor. HSE enforces. Most council and NHS cleaning tenders verify your COSHH evidence at SQ stage.
- Buyers want named evidence: Safety Data Sheets attached, risk assessment per substance, PPE matrix mapped to product, training records by operative, WEL data from HSE EH40.
- BS EN 1276 (bactericidal) and BS EN 14476 (virucidal) standards reference your disinfectant choices. Name them in the method statement, not just "approved disinfectant".
- HSE EH40 is the official Workplace Exposure Limit publication. Reference WELs on substances in scope (e.g. ammonia 25 ppm long-term, chlorine 1 ppm short-term).
- Health surveillance is required where exposure is significant. Evidence of operative health checks shows the buyer you take it seriously.
- Common tender failures: SDS more than 12 months old, no PPE matrix, generic "COSHH-compliant" copy without named substances, no training-record dates.
- Storage and handling on site: COSHH cabinet rated to fire-resistance, lockable, ventilated, separated from food storage. Reference site-by-site.
Every employer shall ensure that the exposure of his employees to substances hazardous to health is either prevented or, where this is not reasonably practicable, adequately controlled.
COSHH Regulations 2002, Regulation 7(1)
What's in this guide¶
- What COSHH covers in a cleaning context
- The 8-step COSHH compliance process buyers verify
- The COSHH evidence pack tender buyers ask for
- BS EN 1276 / EN 14476 / EH40: how to reference each
- Common COSHH violations that lose tenders
- How to integrate COSHH into your method statement
- Storage, handling, and incident response
What COSHH covers in a cleaning context¶
COSHH applies to substances hazardous to health used or generated at work. In a cleaning context that means almost every product on the trolley plus several site-generated dusts and aerosols.
| Substance | Where it appears | Key control |
|---|---|---|
| Sodium hypochlorite (bleach) | Toilet and washroom disinfection, NHS isolation rooms (1,000ppm) | Never mix with acids; ventilation; nitrile gloves; eye protection; spill kit |
| Quaternary ammonium compounds (QACs) | Surface disinfectants, BS EN 1276 standard cleaners | Skin contact protection; respiratory if spraying; manufacturer's contact time |
| Hydrochloric / phosphoric acid | Limescale removers, urinal cleaners | Splash protection (visor + apron); ventilation; never mix with bleach |
| Solvents (e.g. graffiti removers) | External cleaning, council estate work | Respirator (organic vapour cartridge); skin protection; flammability storage |
| Floor stripper (sodium hydroxide / metasilicate base) | Floor restoration, polish removal | Caustic burn risk; PPE: rubber gloves, splash apron, eye protection |
| Cleaning dust (fibrous, respirable) | Dry vacuuming, dust mopping, especially on older council estates | HEPA-filtered vacuum, RPE if asbestos suspected, water-mist for dry dust |
| Biological hazards (bodily fluids, sharps, clinical waste) | NHS environments, public toilets, custody suites | PPE protocol per HTM 07-01 (NHS) or equivalent; sharps box protocol; immunisation records |
Common substances hazardous to health on a UK cleaning contract.
The 8-step COSHH compliance process buyers verify¶
- Identify the hazards. Build a substance register: every chemical product on the contract, every site-generated dust or biological hazard, with its hazard classification.
- Decide who might be harmed and how. Operatives, site users, contractors, members of the public on a council estate. Document exposure routes (inhalation, skin contact, ingestion, injection).
- Evaluate the risk. Severity x likelihood, with reference to the EH40 Workplace Exposure Limit where one applies. Document the assessment per substance and per task.
- Decide on precautions. Hierarchy of controls: eliminate, substitute, engineering controls (ventilation, enclosure), administrative controls (training, signage, PPE), in that order.
- Implement the controls. PPE issued, training delivered, ventilation engineered. Records dated and signed by operative and supervisor.
- Monitor exposure. For substances with WELs, periodic monitoring (e.g. ammonia in batch dilution areas). Health surveillance for sensitisers (e.g. asthmagens) per HSE guidance.
- Train operatives. Initial COSHH awareness training, by-product induction, refresher annual. Records dated.
- Plan emergency response. Spill kit on every trolley, eye-wash station accessible within site, named first-aider with current ticket, HSE RIDDOR reporting protocol on incidents.
The COSHH evidence pack tender buyers ask for¶
| Evidence | What good looks like | What fails |
|---|---|---|
| Safety Data Sheets (SDS) per product | All SDS dated within last 12 months, version-controlled, accessible to operatives, attached as appendix to bid | SDS more than 12 months old, missing for products in the bid, only stored in head office |
| Substance register | One row per product / hazardous material: name, manufacturer, hazard class, EH40 WEL if applicable, where used, how stored | No register; spreadsheet without WELs; doesn't match the SDS library |
| COSHH risk assessment per substance | Substance-by-substance assessment with likelihood, severity, controls, residual risk, reviewer name and date. Reviewed at least annually. | Generic single risk assessment for "all chemicals"; reviewed more than 24 months ago |
| PPE matrix | Product-by-product PPE specification: gloves (nitrile rating), eye protection (EN 166 grade), apron, respirator (FFP class), footwear | Generic "appropriate PPE" wording; no glove specification; no respirator class |
| Training records by operative | Initial COSHH awareness, by-product induction, refresher dates, all by named operative, signed by trainer | Spreadsheet of names without dates; refresher overdue by 12+ months |
| Health surveillance records | Where exposure to sensitisers (asthmagens) is significant, evidence of medical surveillance, periodic checks, doctor's referral protocol | No health surveillance on contracts that include floor stripping or solvent work |
| Spill response plan | Site-by-site spill kit inventory, escalation flow, RIDDOR-reportable incident protocol, named on-call manager | Generic "we will follow our procedures"; no site-by-site inventory |
COSHH evidence the buyer's compliance team verifies on a UK public-sector cleaning tender.
BS EN 1276, BS EN 14476, EH40: how to reference each¶
| Standard | What it covers | When to cite |
|---|---|---|
| BS EN 1276 | Bactericidal efficacy of chemical disinfectants and antiseptics. Tests against named bacteria. | Method statement disinfectant choices for general areas, washrooms, food prep environments |
| BS EN 14476 | Virucidal efficacy. Tests effectiveness against named viruses. | NHS clinical environments, ED, mental health units, COVID / outbreak protocols |
| BS EN 13727 | Bactericidal in medical area | NHS clinical specifically, paired with EN 14476 |
| BS EN 1500 | Hygienic hand rub | Hand hygiene products on healthcare contracts |
| HSE EH40 (Workplace Exposure Limits) | Long-term and short-term exposure limits for ~500 substances. Ammonia 25 ppm LTEL, chlorine 1 ppm STEL, formaldehyde 2 ppm LTEL. | COSHH risk assessment for substances in scope; cited in operational controls |
Standards UK cleaning tenders reference and what each one covers.
Naming the standard does not score points by itself. Naming the standard plus your named product that meets it scores. Example: "Bactericidal disinfection per BS EN 1276 using [Product Name], with verified 5-minute contact time per the manufacturer's instructions and the COSHH risk assessment dated [date]".
Common COSHH violations that lose tenders¶
- Outdated Safety Data Sheets. SDS must be reviewed annually. SDS more than 12 months old in the bid pack signals that the operational COSHH library is also out of date.
- Generic "COSHH-compliant" wording without named substances. Buyer's compliance team can't verify a generic claim. Name the product, name the SDS, name the WEL.
- Missing PPE specification. "Appropriate PPE" tells the buyer nothing. Specify glove type and nitrile thickness, eye protection EN 166 grade, respirator FFP class.
- No training record dates. A list of names is not training evidence. Each operative needs an initial training date plus refresher dates within the last 12 months on substances in scope.
- No health surveillance on contracts with sensitiser exposure. Floor strippers, certain solvents, and biocides include known asthmagens. Buyers expect ongoing surveillance for operatives in regular contact.
- Storage gaps. COSHH cabinet must be lockable, fire-resistant, ventilated, separated from food storage. On-site reality must match the method statement description.
- Incident-response generic. "We will follow our procedures" loses points. Name the spill kit per trolley, name the eye-wash station location, name the on-call manager and the RIDDOR escalation flow.
Integrating COSHH into the method statement¶
COSHH evidence sits in two places on a UK cleaning tender bid. First, attached to the SQ as the substance register, SDS library, and risk assessments. Second, woven into the method statement as named products with named standards and named PPE per task.
The eight-section method statement structure that scores 8-9/10 on UK public-sector marking matrices is in the cleaning method statement guide. The COSHH section is one of those eight; it lives between equipment and quality monitoring in the canonical structure.
Storage, handling, and incident response¶
Buyers' compliance teams sometimes audit storage on site. The method statement promises must match the operational reality.
- Storage cabinets: lockable, fire-resistant, ventilated, separate from food storage and patient-accessible areas. Bunded if liquid volumes are significant.
- Decanting and dilution: only by trained operatives, in named dilution areas, with PPE matrix posted on the wall. No drinking-bottle decants. Dilution rate verification per shift.
- Transport between sites: products in original containers (or correctly-labelled refillables), secured, segregated from food and personal effects in vehicles, no overnight in unlocked vehicles.
- Disposal: empty containers cleaned and disposed under the Hazardous Waste Regulations 2005 if they meet the threshold. Some councils accept empty triple-rinsed containers as general waste; others require return to supplier.
- Incident response: spill kit on every trolley (granular absorbent for liquids, neutralising agent for acids/alkalis), eye-wash station within 10m of dilution areas, on-call supervisor for evening shifts, RIDDOR-reporting protocol for serious incidents.
What to do this week¶
- Audit your Safety Data Sheets. Anything more than 12 months old: request the current version from the manufacturer. Date-stamp every SDS.
- Build (or refresh) your substance register. One row per product or hazardous material: name, manufacturer, hazard class, WEL if applicable, where used, how stored.
- Score your last 5 lost tenders against the COSHH evidence-pack table above. The pattern usually reveals one or two systematic gaps.
- Update your PPE matrix to product-by-product detail: glove type and nitrile thickness, eye protection EN 166 grade, respirator FFP class.
- Run a refresher COSHH training session for any operative whose last record is more than 12 months old. Record date, attendees, by-product topics, and trainer name.
Sources
- COSHH Regulations 2002 (legislation.gov.uk) · Statutory framework for control of substances hazardous to health
- Health and Safety Executive (HSE) COSHH guidance · HSE practical guidance and compliance materials, free download
- HSE EH40/2005 Workplace exposure limits · Official UK long-term and short-term exposure limits for ~500 substances
- BS EN 1276 (BSI) · European standard for chemical disinfectants and antiseptics, bactericidal activity
- BS EN 14476 (BSI) · European standard for chemical disinfectants and antiseptics, virucidal activity
- RIDDOR (Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013) · Statutory reporting framework for serious workplace incidents including chemical exposure
- PPE Regulations 2002 (legislation.gov.uk) · Personal Protective Equipment at Work Regulations; underpins PPE matrix on COSHH risk assessments
FAQs
Frequently asked questions
- COSHH stands for the Control of Substances Hazardous to Health Regulations 2002. It is the UK statutory framework for managing exposure to hazardous substances at work, enforced by the Health and Safety Executive. On UK cleaning tenders, COSHH compliance is verified at SQ stage and quality stage. Buyers want documented Safety Data Sheets per product, risk assessments per substance, PPE matrix, training records by operative, and Workplace Exposure Limit evidence from HSE EH40 on substances in scope. Generic "we follow COSHH" copy loses points. The buyer's compliance team checks because the cost of a chemical incident on a public-sector site sits with them. Lapsed COSHH evidence is the most common reason cleaning tenders fail at SQ even when the price and method statement are credible.
- Five things at SQ stage. First, a substance register listing every chemical product on the contract with manufacturer, hazard classification, EH40 Workplace Exposure Limit if applicable, where used, and how stored. Second, Safety Data Sheets per product, dated within the last 12 months. Third, COSHH risk assessment per substance with likelihood, severity, controls, residual risk, reviewer name and date. Fourth, PPE matrix mapped product-by-product: glove type and nitrile thickness, eye protection EN 166 grade, respirator FFP class. Fifth, training records by operative with initial COSHH awareness, by-product induction, and refresher dates within the last 12 months. Health surveillance records also for contracts with sensitiser exposure (floor strippers, certain solvents, biocides).
- BS EN 1276 covers bactericidal efficacy of chemical disinfectants and antiseptics. BS EN 14476 covers virucidal efficacy. On UK cleaning tenders, you reference BS EN 1276 for general areas, washrooms, food preparation environments where bacterial control is the main concern. You reference BS EN 14476 for healthcare environments, ED, mental health units, and outbreak protocols where viral control is in scope. Most NHS contracts require disinfectants meeting both standards, with verified contact times per the manufacturer's COSHH risk assessment. BS EN 13727 is paired with EN 14476 for medical areas in particular. BS EN 1500 covers hygienic hand rub products. Naming the standard alone does not score; naming the standard plus your named product that meets it does.
- EH40/2005 Workplace exposure limits is the HSE publication listing official UK long-term (8-hour reference period) and short-term (15-minute reference period) exposure limits for around 500 named substances. Examples: ammonia 25 ppm LTEL and 35 ppm STEL, chlorine 1 ppm STEL, formaldehyde 2 ppm LTEL. Tender packs ask for EH40 references because they want evidence the contractor has assessed exposure against the legal floor, not just provided a generic risk assessment. The right reference pattern in your bid: "Sodium hypochlorite (bleach) used at 1,000ppm for terminal cleaning of FR1 isolation rooms. EH40 WEL: chlorine 1 ppm STEL. Ventilation maintained at minimum 6 ACH (air changes per hour) per the COSHH risk assessment dated [date]."
- Outdated Safety Data Sheets. SDS must be reviewed annually under COSHH, and buyers' compliance teams check the date on every SDS in the bid pack. SDS more than 12 months old signals that the operational COSHH library is also out of date, which fails SQ. Second most common: generic "COSHH-compliant" wording without named substances. The buyer can't verify a generic claim. Third: missing PPE matrix. "Appropriate PPE" tells the buyer nothing; specify glove type and nitrile thickness, eye protection EN 166 grade, respirator FFP class. Fourth: no training record dates. A list of operative names is not evidence; each operative needs initial training date plus refresher dates within the last 12 months. Fifth: storage gaps where the method statement promise doesn't match site reality (lockable, fire-resistant, ventilated cabinets separated from food storage).