COSHH, the Control of Substances Hazardous to Health Regulations, deliberately excludes asbestos. Asbestos has its own regulations, currently the Control of Asbestos Regulations 2012, and lead has its own too for the same reason: they are hazards specific enough to need their own rules. A COSHH assessment that lists asbestos as one substance among many has been written by somebody who has not read either instrument.
Why asbestos is not covered by the COSHH regulations
COSHH covers substances hazardous to health generally, and it excludes those that have their own regulatory regime, including asbestos and lead. That is not a lesser standard: the asbestos regulations are more prescriptive than COSHH, with a licensing system, a notification regime, mandatory training, air monitoring and clearance procedures that COSHH has no equivalent of.
What covers asbestos instead
The Control of Asbestos Regulations 2012 and its Approved Code of Practice L143. They carry the duty to manage in non-domestic premises, the requirement to identify before work, the licensing of higher risk work, training duties, exposure limits and the rules on waste and clearance. The Health and Safety at Work etc. Act 1974 sits behind all of it.
What a business should do
Keep the two apart in your paperwork. Cleaning chemicals, dusts, fumes and biological agents go in the COSHH assessment. Asbestos goes in the asbestos register, the asbestos risk assessment and the management plan, with its own named owner and its own review interval. Cross reference them if you like, but do not merge them.
Training is separate: COSHH awareness is not asbestos awareness
COSHH training does not satisfy the asbestos training duty. Anyone whose work could foreseeably disturb asbestos has to have asbestos awareness training, and anyone doing non-licensed or licensed work needs more than that. It is a specific duty in the asbestos regulations rather than a general one.
A COSHH risk assessment template free download will not cover asbestos, and here is why
Asbestos is expressly outside COSHH: it has its own regulations, its own licensing regime, its own training requirement and its own survey and register duties, and the general COSHH duty does not apply to it. So a coshh risk assessment template free pack, however complete, has no row that discharges anything for an asbestos containing material, and filling one in for a textured ceiling is evidence of a duty misunderstood rather than met. What the two regimes share is the shape of the thinking, which is why the mistake is easy: identify, assess, prevent or control, monitor, train, review. What they do not share is the paperwork.
Other questions people ask
Is asbestos a COSHH substance?
No. It is expressly outside COSHH because it has its own regulations, which are more demanding rather than less.
Do I still need a COSHH assessment?
Yes, for everything COSHH does cover. It simply will not include asbestos, which belongs in its own assessment and register.
Which regulations apply to asbestos?
The Control of Asbestos Regulations 2012 in Great Britain, supported by the Approved Code of Practice L143.
What substances does coshh include besides asbestos?
Almost anything hazardous to health that people are exposed to at work, and the list is wider than a shelf of labelled bottles. Chemicals and their fumes, yes, but also dusts generated by the work such as flour, wood and silica, mists and vapours from processes, fumes from welding and engines, and biological agents. Asbestos, lead and radioactive substances are the exceptions that sit under their own regulations instead. The test is whether the work creates it and somebody breathes it, swallows it or gets it on their skin.
What are the COSHH employers responsibilities, in order?
Assess before use, and the order matters because most failures are sequence failures. Find out what hazardous substances are present, including ones produced by the work such as dust, fume or vapour rather than only what is bought in. Assess the risk from how they are actually used. Prevent exposure where reasonably practicable, by not using the substance or by substituting a safer one, and only then control it by enclosure, extraction, systems of work and, last, protective equipment. Maintain and examine the controls, including the statutory examination of local exhaust ventilation. Monitor exposure and provide health surveillance where required. Inform, instruct and train. Plan for emergencies.
What is a COSHH assessment, as opposed to a safety data sheet?
The assessment is about your use of the substance; the data sheet is the supplier's description of the substance itself. So the assessment names the task, the amount, the frequency, the room and its ventilation, who is exposed and by which route, what the controls are and who checks them, and what happens on a spill or an exposure. It can be a page. What it cannot be is a folder of the supplier's sheets, which is the commonest arrangement mistaken for compliance and the one an inspector asks about first, because nothing in that folder mentions your building.