How to Write a COSHH Risk Assessment for Chemical Storage Areas

How to Write a COSHH Risk Assessment for Chemical Storage Areas

The Control of Substances Hazardous to Health Regulations 2002 (COSHH) require employers to assess the risks posed by hazardous substances in the workplace and implement appropriate control measures. Chemical storage areas are one of the highest-risk environments in any industrial facility, making a thorough COSHH risk assessment not just a legal requirement — but a critical safety measure.

This guide walks you through what a COSHH risk assessment for a chemical storage area must include, and how to ensure it meets HSE expectations.

Legal Background

Under Regulation 6 of COSHH, employers must carry out a suitable and sufficient assessment of the risks to health from exposure to hazardous substances before work begins. This includes storage activities, not just active use. The Health and Safety at Work etc. Act 1974 and Management of Health and Safety at Work Regulations 1999 underpin these duties. HSE inspectors regularly review COSHH assessments during site visits, and inadequate documentation can result in improvement notices or prosecution.

The Eight Steps of a COSHH Assessment

The HSE recommends an eight-step approach to COSHH assessment. For chemical storage areas, this translates as follows:

• Step 1 — Identify substances: List every chemical stored in the area. Use Safety Data Sheets (SDS) to identify hazards. Include cleaning products, maintenance chemicals, and process chemicals.
• Step 2 — Identify who may be harmed: Consider storekeepers, maintenance workers, emergency responders, and anyone who may access the area — including contractors and visitors.
• Step 3 — Evaluate exposure risk: Assess the likelihood and severity of exposure via inhalation, skin contact, ingestion, or injection. Consider quantities stored, frequency of access, and container integrity.
• Step 4 — Assess current controls: Review existing measures — ventilation, PPE, segregation, bunding, and spill response equipment. Identify gaps.
• Step 5 — Decide additional controls needed: Apply the COSHH hierarchy of controls: eliminate if possible, substitute with a safer substance, implement engineering controls, then administrative controls, then PPE as a last resort.
• Step 6 — Record and implement: Document the assessment in writing. This is a legal requirement for employers with five or more employees under Regulation 6(4).
• Step 7 — Review periodically: COSHH assessments must be reviewed whenever there is reason to believe they are no longer valid — typically annually or after any incident.
• Step 8 — Monitor and health surveillance: For certain substances (e.g., those with Workplace Exposure Limits), monitoring of employee exposure and health surveillance may be required.

Chemical Storage Specific Considerations

Spill Response: An Essential COSHH Control

No COSHH assessment for a chemical storage area is complete without addressing spill response. Accidental releases are foreseeable events, and your assessment must include how spills will be contained, absorbed, and disposed of. Position appropriate chemical spill kits within the storage area, ensure staff are trained in their use, and reference the kits explicitly in your COSHH documentation.

Also consider spill pallets and bunded storage cabinets as engineering controls that should feature in your risk assessment. Having the right containment infrastructure in place before a spill occurs is far preferable to reactive cleanup.

A well-written COSHH risk assessment protects your workers, satisfies regulators, and demonstrates that your business takes chemical safety seriously.

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