Waiting for the HSE or the Environment Agency to identify gaps in your spill control arrangements is not a compliance strategy — it is a gamble with potentially severe financial and legal consequences. A structured self-assessment, conducted regularly by a competent person, allows you to identify weaknesses, address them proactively, and build a documented record of due diligence. This guide provides a practical framework for conducting a spill control audit at your site.
Why Self-Audit?
Under the Control of Substances Hazardous to Health Regulations 2002, employers are required to carry out suitable and sufficient assessments of the risks from hazardous substances and implement adequate control measures. Spill control is an integral part of those controls. Regular self-auditing demonstrates that you are actively managing compliance rather than passively relying on documentation that may no longer reflect your operational reality.
Who Should Conduct the Audit?
The audit should be led by a competent person — someone with sufficient knowledge of COSHH, spill control principles, and your site-specific operations. This could be your Health and Safety Manager, an Environmental Compliance Officer, or an external consultant. For smaller sites, a senior manager who has received appropriate training is acceptable, provided they approach the task rigorously and without bias towards convenient findings.
Spill Control Audit Checklist
| Audit Area | Key Questions | Compliant? |
|---|---|---|
| COSHH Assessments | Are all hazardous substances assessed? Are assessments current? | Yes / No / Partial |
| Spill Kits — Location | Are kits within 10m of storage/handling areas? Clearly signed? | Yes / No / Partial |
| Spill Kits — Condition | Are contents intact, unexpired, and sufficient for the worst-case spill? | Yes / No / Partial |
| Secondary Containment | Does bunding meet 110% capacity rule? Integrity intact? | Yes / No / Partial |
| Drain Protection | Are surface water drains protected or sealed in risk areas? | Yes / No / Partial |
| Staff Training | Have all relevant staff received spill response training? Is it documented? | Yes / No / Partial |
| Incident Records | Are past spills recorded? Were they investigated and learnings implemented? | Yes / No / Partial |
| Emergency Procedures | Are written spill response procedures in place and accessible? | Yes / No / Partial |
| Waste Disposal | Is contaminated absorbent waste disposed of correctly as hazardous waste? | Yes / No / Partial |
| Signage | Are chemical storage and spill response areas correctly signed? | Yes / No / Partial |
Step 1: Chemical Inventory Review
Begin by verifying that your chemical inventory is complete and current. Every substance on site should appear in your COSHH assessments, with a current Safety Data Sheet on file. Pay particular attention to new substances introduced since the last assessment review, and to any changes in quantities stored or processes used.
Step 2: Physical Inspection of Spill Kits
Walk every storage and handling area and physically inspect each spill kit. Check that the kit is the correct type for the substances nearby (general-purpose, oil-only, or chemical/hazchem), that the contents are complete and unexpired, and that the kit is accessible without obstruction. Replace any partially used or expired kits immediately. Our spill kit range includes replenishment packs for all standard kit formats.
Step 3: Secondary Containment Inspection
Inspect all bunds, drip trays, and spill decks for cracks, damage, and integrity. Verify that drain valves are closed and functional. Check for accumulated rainwater or residual contamination. Confirm that the containment capacity meets the 110% rule for the volumes stored. Where deficiencies are found, address them before the next inspection cycle. Browse our secondary containment products for replacement or upgrade options.
Step 4: Training Records Review
Confirm that all staff who may respond to a spill — not just designated first responders — have received appropriate training. Training should cover identification of the substance, correct PPE, use of the spill kit, containment priorities, and escalation procedures. Records of training must be retained and refreshed at regular intervals, typically every one to two years.
Step 5: Document Your Findings
Record the audit findings formally, noting compliant areas, non-conformances, and actions required. Assign responsibility and deadlines for corrective actions. Re-audit non-conforming areas after the remediation deadline. This documented audit trail is your evidence of active compliance management — exactly what an HSE or Environment Agency inspector will want to see.
How Often Should You Audit?
A full spill control audit should be conducted at least annually, with more frequent interim checks (quarterly as a minimum) of spill kit condition and secondary containment integrity. Any significant operational change — new substances, new processes, structural alterations, significant staff turnover — should trigger an unscheduled review.
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