COSHH for a Cupboard of Reagents: The Record a Small Lab Must Keep

The Control of Substances Hazardous to Health Regulations 2002 apply to any employer whose work could expose people to substances that harm health, and keeping those substances on the premises is part of that work ^[1]. A small laboratory with one cupboard of reagents is inside the regulations just as a university chemistry department is ^[3]. What differs is the amount of paperwork, not whether there is any.

This article covers the records side: what an assessment is built from, when it must be written down, what a register of stored substances needs, and how often it is reviewed. It deliberately says nothing about how to handle any particular compound. That belongs in your own assessment and your own written procedures, built from the supplier's safety data sheet.

What COSHH asks of anyone storing chemicals

HSE summarises the employer's duties as a sequence: identify the hazards, assess the risks, put control measures in place, make sure they are used and kept in good working order, give workers information, instruction and training, arrange monitoring and health surveillance where needed, and plan for emergencies ^[3]. The substances in scope include dusts, gases and fumes that can be breathed in, and liquids, gels and powders that can reach the skin or eyes. Lead, asbestos and radioactive substances fall outside COSHH because each has its own regulations.

The legal core is regulation 6. An employer must not carry out work liable to expose employees to a substance hazardous to health unless it has made a suitable and sufficient assessment of the risk and put in place the steps needed to control it ^[1]. For a small lab, the work includes receiving, storing, moving and disposing of materials, not only using them.

HSE's Approved Code of Practice and guidance on the regulations, published as L5, is the reference an inspector works from ^[6]. It is long, and the parts a small lab needs first are those on assessment and records.

From safety data sheet to assessment

Every assessment starts with what the substance is. HSE's advice is to identify harmful substances by reading product labels and safety data sheets, and to ask the supplier if in doubt ^[4]. By law, suppliers must provide an up-to-date safety data sheet for a substance that is dangerous for supply ^[5].

The step people skip is the next one. HSE is explicit that a safety data sheet is not a risk assessment, and that its information is there to help the employer make its own ^[5]. The data sheet describes the substance. The assessment describes your work with it: how much you hold, where, who has access, what could go wrong in your room, and what you do about it.

The fourth row is where handling detail belongs, in your organisation's own document. The general discipline of writing a standard operating procedure applies to it; this article stops at the register.

When the assessment must be written down

Where an employer has five or more employees, regulation 6 requires it to record the significant findings of the assessment as soon as practicable after it is made, together with the steps taken to meet the control requirements ^[1]. HSE adds that even with fewer than five employees it makes sense to write down what steps have been taken ^[4].

For a small lab the practical answer is to write it down regardless of headcount. An assessment that exists only in one person's head does not survive their holiday, and cannot be shown to anyone who asks. A recorded assessment for a reagent store usually covers:

• The substances or groups of substances covered, cross-referenced to their safety data sheets.
• Where and how they are stored, including the separation of incompatible materials.
• Who has access, and what information and training they have had.
• The control measures relied on, and how and when they are checked.
• What happens in a spill, fire or other emergency involving the store.
• The date, the name of the assessor and the next review date.

Storage deserves its own line. HSE's guidance is to plan the storage of materials, use appropriate containers, check that they are correctly labelled, and keep incompatible materials, such as acids and caustics, apart ^[4]. A fridge or cupboard holding research materials is part of the assessed area, not a neutral box.

The substance register

COSHH does not prescribe the format of an inventory, but an assessment covering "all reagents in cupboard B" is only as good as the list of what is in cupboard B. The register is what makes the assessment checkable.

The same fields that make a COSHH register useful make a traceability record useful, and many small labs keep the two in one place. Entries are most defensible when they are made at the time, in the manner of contemporaneous laboratory records, rather than reconstructed the week before an audit.

The last field matters when material expires or is no longer needed. The register line closes when the substance leaves the store, and from that point the waste rules take over, with their own paperwork.

Review, and records with long lives

The assessment must be reviewed regularly, and immediately if there is reason to suspect it is no longer valid, if there has been a significant change in the work, or if monitoring results show a review is needed. Where the review shows changes are needed, they must be made ^[1]. HSE gives staff changes, process changes, new equipment and incidents as typical triggers ^[4].

A new substance arriving in the store is a change. So is a revised safety data sheet from a supplier, a move to a different room, or a new person with access. A review date written on the assessment makes "regularly" concrete. Many small labs set it annually and review sooner whenever a trigger occurs.

If exposure monitoring is ever carried out, its records have their own retention rules: at least 40 years from the last entry where they record the personal exposures of identifiable employees, and at least five years in any other case ^[2]. Most small stores will never need monitoring, but it is worth knowing those periods exist before somebody clears out a folder.

What an inspector asks

An inspection of a small lab's chemical store tends to follow the paper trail. The questions are predictable, and each one maps to a record above.

1. What do you store here? Answered by the register.
2. What information do you have on this one? Answered by the current safety data sheet.
3. What is your assessment for this store? Answered by the recorded assessment.
4. When was it last reviewed, and what changed? Answered by the review record.
5. Who works here, and what have they been told? Answered by the training and information records.
6. What happens if this spills? Answered by the emergency section of the assessment.

A lab that can answer those six from a single folder or system is in a good position. One that answers them from memory has an assessment problem, however good its practice at the bench.