Why Generic Risk Assessment Templates Fail the COSHH Test
Every week, UK HSE inspectors find chemical storage risk assessments that are generic, outdated, and completely detached from the actual hazards on site. These documents fail not because they are malicious, but because their authors did not understand what a COSHH-compliant risk assessment for chemical storage is legally required to contain. This guide sets out every section required by law, the specific content that must go in each, and the most common deficiencies that lead to enforcement action under Regulation 3 of the Management of Health and Safety at Work Regulations 1999 (MHSWR 1999) and Regulation 6 of COSHH 2002.
The Legal Basis
The duty to carry out a COSHH assessment derives from COSHH Regulation 6. It must be 'suitable and sufficient' — the legal standard established by MHSWR Regulation 3(1). 'Suitable and sufficient' means the assessment must:
- Identify the significant risks arising from the substances stored
- Identify the control measures needed to adequately control those risks
- Be proportionate to the nature and scale of the hazard
- Be reviewed and revised when it is no longer valid
A document that ticks boxes without engaging with the actual substances and actual storage conditions at your site is not suitable and sufficient, regardless of how many pages it contains.
Section 1: Scope and Purpose
State clearly what the assessment covers: which storage area, which substances, which activities (decanting, mixing, loading, cleaning). If the assessment covers an entire chemical store with 30 different substances, that is one assessment. Each substance or substance group should be addressed in its own section. Include:
- Site address and specific storage location (room number, bay, area name)
- List of all substances assessed (with SDS reference and revision date)
- Activities involving each substance
- Names of persons who may be exposed
Section 2: Substance Identification and Hazard Profile
For each substance, document the following — sourced from the current Safety Data Sheet (SDS). Note that SDSs must comply with UK REACH Regulation (SI 2020/1577) and have been issued or reviewed after 31 December 2020 for UK compliance:
| Field | Source | Why It Matters |
|---|---|---|
| CAS number | SDS Section 1 or 3 | Unique substance identifier — ensures correct WEL is referenced |
| GHS/CLP hazard classification | SDS Section 2 | Determines which COSHH controls are required |
| WEL (8-hr and 15-min) | SDS Section 8 / EH40 | The compliance target for airborne exposure controls |
| Skin/eye hazard (HP notation) | SDS Section 8 | Determines PPE requirements and need for liquid containment |
| Flash point (if applicable) | SDS Section 9 | Triggers DSEAR assessment duty |
| Carcinogen/sensitiser flag | EH40 / SDS Section 2 | ALARP duty; biological monitoring may be required |
| Emergency first aid measures | SDS Section 4 | Informs emergency procedures and first aid provision |
Section 3: Exposure Assessment
State how workers may be exposed: inhalation, skin absorption, ingestion, injection (high-pressure systems). For each route, assess the likely exposure level — not just theoretical but based on the actual quantities used, how they are handled, and the existing control environment. Reference the hierarchy of controls under COSHH Regulation 7:
- Elimination or substitution
- Total enclosure
- Partial enclosure with LEV
- General dilution ventilation
- Work practices and administrative controls
- PPE (last resort only)
Section 4: Control Measures
For each exposure route and substance, document the control measures actually in place. Do not list aspirational controls — document what is implemented. For chemical storage, controls typically include:
- Secondary containment specification (volume, material, compatibility)
- Ventilation (LEV or natural; face velocity or air change rate; last test date)
- Container specification (sealed, vented, material compatibility)
- Segregation requirements (incompatible substances separated; distances recorded)
- Access control (restricted area, training requirement)
- PPE specification per substance (type, standard, maintenance/replacement frequency)
Section 5: Emergency Procedures
COSHH Regulation 11 requires special arrangements for accidents, incidents, and emergencies where exposure to hazardous substances could be significant. This section must specify:
- Spill response procedure (steps; who is responsible; what equipment is used)
- Spill kit type, contents, and location (within immediate vicinity of storage area)
- Evacuation procedure and assembly point
- First aid measures specific to the substances stored
- Emergency services information (which substances are present, in what quantities)
- Decontamination procedures
Section 6: Health Surveillance
COSHH Regulation 11 and Schedule 6 require health surveillance for specific substances — including those causing occupational asthma, dermatitis, and specific organ effects. If any substance in the storage area is a Schedule 6 substance, or if workers are regularly exposed to skin or respiratory sensitisers, health surveillance by an occupational health professional is a legal requirement, not optional.
Section 7: Review Trigger and Date
The assessment must state when it will next be reviewed. Reviews are required when: the substances or quantities change; new working practices are introduced; there is evidence that control measures are insufficient; a spill incident or near-miss occurs; or at a fixed interval not exceeding three years. The reviewer must be named and competent — competence under COSHH means knowledge of the specific substances, the workplace, and the control systems.
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