COSHH for hospitality: the cleaning chemical paperwork nobody enjoys

By Kristian11 May 2026

It was about 7pm on a Friday at Harbourside. Service had eased off, the floor team were starting close-down, and one of our newer kitchen porters came out of the back with his sleeve rolled up and a red blotch on his forearm. He had splashed sanitiser on himself decanting from a five litre into a trigger bottle. He had rinsed it under the tap, which was the right instinct, but when I asked him what the product was and how long he should keep it under water, he didn't know. Neither did the duty manager. Neither, embarrassingly, did I, not without going to look at the bottle.

It wasn't catastrophic. A bit of redness, gone by Sunday. But it could have been. And what struck me afterwards wasn't the splash, it was the fact that we had a stack of cleaning chemicals under every sink in two sites and nobody on shift could tell you the first aid for any of them. We had the Safety Data Sheets somewhere in a folder in the office. Nobody had ever opened it.

This guide is the COSHH conversation I wish someone had sat me down for in year one. What it actually means, what you need on paper, and what an EHO is going to ask you when they pull open the cupboard under your dish sink.

Why this matters

COSHH sits under the Control of Substances Hazardous to Health Regulations 2002, enforced by the HSE and, in practice for most cafés and restaurants, picked up by your EHO at routine inspection. It applies to almost everything you spray, pour, or wipe with: degreaser, sanitiser, oven cleaner, descaler, dishwasher rinse aid, bleach, drain unblocker. If it has a hazard symbol on the label, it is in scope.

What an inspector actually checks is straightforward. Do you know what chemicals are on site? Have you done a written assessment of the risks? Are the Safety Data Sheets accessible to staff? Are products stored safely and away from food? Has the team been trained, and can you prove it? Get any of those wrong and you are looking at, at best, a stern improvement notice. At worst, if someone gets hurt and you have nothing on paper, you are personally liable.

The other reason this matters is that hospitality has a young, transient workforce. The 17 year old who started last week is the one most likely to splash sanitiser on themselves. They are also the least likely to read a label unprompted. That gap is what COSHH is trying to close.

What COSHH actually requires you to do

Strip out the jargon and there are five things. Know your chemicals. Know the risks each one carries. Know the first aid response for each. Train your team. Prove you have done all of the above. That last one is the part most operators skip, and it is the part that matters when something goes wrong.

In practical terms, you need:

A list of every hazardous product on site (cleaning chemicals, but also things like CO2 for the dispense system, descaling acids, oven cleaners)
A current Safety Data Sheet for each product, accessible to staff
A written COSHH assessment for each product or task that uses one
Records that staff have been shown how to use, store, and respond to spills for each
Appropriate PPE available (gloves, eye protection where the SDS calls for it)

The assessment doesn't need to be a 20 page document. For a café it can be a one page sheet per product covering what it is, what it can do to you, how to use it safely, what to do if it goes wrong. A template you fill in. The HSE provides one. Plenty of suppliers do too. The point is having it written down, not winning a typography award.

How to actually use a Safety Data Sheet

Every chemical you buy from a proper supplier comes with an SDS available, usually as a PDF download from their site. They are long. Most are 10 to 16 pages of dense formatting, and most operators glance at them once and never again. That is a mistake but I understand why.

In practice, you only need five of the sixteen sections to run your café safely. Learn these and you can read any SDS in three minutes:

Section 2: Hazards identification. What this product can actually do to a human. Skin irritation, eye damage, respiratory issues. The hazard pictograms are here too.
Section 4: First aid measures. Eyes, skin, inhalation, ingestion. This is the section you want a laminated copy of near the chemical, not in a folder in the office.
Section 7: Handling and storage. Ventilation, what not to mix it with, what temperatures to store it at.
Section 6: Accidental release. What to do if you knock a bottle over. Whether you can mop it up or need to neutralise it first.
Section 8: Exposure controls and PPE. What gloves, what eye protection, whether you need ventilation.

The other sections (transport classifications, ecological data, regulatory info) matter for the manufacturer and the haulier. For you, on a Friday night, they don't. Print the five sections that do, stick them in a slim ring binder by the chemical store, and your team has something they can actually use.

The SDS folder in the office is for the inspector. The laminated first aid card by the sink is for your team.

Kristian

Storage: the cupboard under the sink problem

This is where most cafés fail an inspection, and where we failed for years before we tightened up. The classic café set-up is a cupboard under the dishwash sink with seven half-empty bottles, two with the labels peeled off, one decanted into an old San Pellegrino bottle because the trigger spray cracked.

What the EHO wants to see, and what COSHH actually requires:

Separate from food. Not in the dry store next to the flour. Not on the shelf above the prep table. A dedicated chemical area, even if it is just one labelled cupboard.
Locked or out of customer reach. If you have a customer toilet, the cleaning trolley does not live propped against the wall outside it. Kids reach for anything coloured and a sports cap bottle of pink degreaser looks like squash.
Original containers wherever possible. If you have to decant, the new container must be labelled with the product name and the hazard symbols. Not "blue stuff" written in marker. Decanting into food or drink containers is a straight fail.
Incompatibles separated. Bleach and acidic descaler in the same cupboard is how you get a chlorine gas incident. The SDS section 7 will tell you what not to store together.
Ventilated. Most cleaning chemical cupboards are fine, but if you store anything that off-gases (some oven cleaners, some drain products), it needs airflow.

At Welsh Back we ended up with a single shallow cupboard near the back door, labelled, locked when the building was empty, and with a laminated A4 sheet on the inside of the door listing what was in it and where the SDS first aid pages lived. Took an afternoon. Solved a problem we had been ignoring for three years.

Training the team and proving you did

The legal bit and the human bit are the same thing here. Every member of staff who uses or could come into contact with a hazardous substance needs to be trained, before they use it, and the training needs to be recorded.

For a small site, that record can be a signed sheet. Name, date, products covered, signature of trainer and trainee. Keep it for the duration of their employment plus a couple of years. If you do it as part of induction (which you should), you cover yourself on day one. The hard part is the refresher, especially when a new product comes in or a formulation changes. Most operators forget. We did, repeatedly, until we started running a quick five minute review at the start of each new starter's second shift and a quarterly all-team check.

The training doesn't need to be a course. It needs to cover: what the product is, where it lives, how to use it (dilution if applicable), what PPE to wear, what to do if it goes wrong, where the SDS is. Five minutes per product, in person, with the bottle in hand.

Common mistakes

Decanting into unmarked bottles: The single most common COSHH failure in cafés. If you transfer a chemical from its original container, the new container must carry the product name and the hazard symbols. Old water bottles are an automatic fail and a genuine safety risk.
SDS folder that nobody can find: Having the data sheets on the office computer is fine for the inspector. Useless at 7pm on a Friday when someone has splashed themselves. Put the first aid sections somewhere physical, near the chemicals.
Storing chemicals above or near food: A leaking degreaser bottle on the shelf above your flour bin is contamination waiting to happen. Dedicated chemical storage, separate from any food zone.
Assuming the supplier did the assessment for you: A supplier provides the SDS. They do not provide your written COSHH assessment. That is your job, because only you know how your team actually uses the product.
Training nobody after the initial induction: New starter gets shown the chemicals on day one. Six months later a new product arrives and nobody mentions it. Build a trigger into your process: new product = ten minute team brief, signed off.
No PPE actually available: The SDS says wear nitrile gloves and the box of gloves ran out three weeks ago. Make PPE part of your stock check, not an afterthought.

FAQs

Do I legally need an SDS for every chemical in my café?

You need access to an SDS for every hazardous substance on site, which in practice means almost every cleaning chemical. The supplier is legally required to provide it, usually as a PDF download. You don't need a printed copy of every SDS, but you do need a written COSHH assessment based on each one, and your team needs to be able to find the first aid information quickly if something goes wrong.

What does COSHH stand for?

COSHH stands for Control of Substances Hazardous to Health. It comes from the Control of Substances Hazardous to Health Regulations 2002, which sit under the Health and Safety at Work Act. For hospitality it covers cleaning chemicals, sanitisers, descalers, oven cleaners, dispense gases like CO2, and anything else hazardous that staff might be exposed to. Food itself is generally not covered, even allergens, which sit under separate regulations.

How often should the COSHH assessment be reviewed?

At minimum, review your COSHH assessments annually. You should also review whenever something changes: a new product comes in, a supplier reformulates an existing one, a process changes, or an incident happens on site. Many operators tie the annual review to another fixed date, like the food safety management system review or the start of the financial year, so it actually gets done rather than slipping.

Who needs to be trained on COSHH?

Anyone who uses, handles, or could be exposed to a hazardous substance. In a café that is realistically every member of staff, because everyone wipes down a surface or empties a sanitiser bucket at some point. Training should happen before they first use the product, ideally at induction, and be refreshed when new products are introduced. Keep a signed record of who was trained on what, and when.