COSHH for hospitality: a practical guide
Every restaurant, pub, hotel and bar handles substances that can injure someone. Caustic oven cleaner and beer line cleaner can both blind, and they get used every week, often in a hurry, in a hot kitchen or a cramped cellar. COSHH is the set of regulations that says you must know what you have, assess the risk and control it. This guide covers what that means for a hospitality venue, from the kitchen and the cellar to the pool plant room if you have one.
What COSHH requires in a hospitality venue
The Control of Substances Hazardous to Health Regulations 2002 apply to any workplace using substances that can harm health. For a restaurant, pub, hotel or bar the duty comes down to five things: know which substances you use, hold the safety data sheet for each, assess how each could hurt someone on your premises, put controls in place, and tell the people who use them. The HSE does not expect a small restaurant or a village pub to run a laboratory-grade system. It does expect you to be able to answer "what is in that cupboard, what would it do to someone, and what have you done about it".
Hazardous substances in a typical venue
- Oven and grill cleaners: often caustic, used hot, in kitchen corners with little ventilation.
- Sanitisers, and dishwasher and glasswasher detergents: irritants at the least, and some combinations are dangerous. Bleach mixed with acidic descaler or with anything ammonia-based releases toxic gas.
- Descalers: acids, used on everything from the dishwasher and glasswasher to the coffee machine.
- Drain cleaners: caustic or acid, and dangerous if two different products meet in the same drain.
- Beer line cleaner, wherever you serve draught. It is usually a caustic (sodium or potassium hydroxide) solution that causes severe burns and eye damage, and in the cellar it is used in a tight space, in a rush, where splashes are likely.
- Pool and spa chemicals, in a hotel with a pool or spa: chlorine or bromine disinfectants and acid pH correctors. Chlorine products and acid release chlorine gas if they mix, which is why they are stored apart.
- Fuel gels and barbecue fluids, where you use them. CO2 and cellar gas sit alongside COSHH too, and asphyxiation in cellars is a recurring cause of death in this trade.
- Pest control products, whether a contractor applies them or you bought them over the counter.
Safety data sheets and pictograms
The supplier of every hazardous product must provide a safety data sheet on request, and most publish them online. The sheet gives you the hazards, the first-aid response and the handling requirements. The orange-red diamond pictograms on the label (corrosive, flammable, health hazard and the rest of the GHS set) are the shorthand for the same information. Your register then lists each product with its sheet, its pictograms, where it is stored, who uses it and what your controls are. Keep it where staff can get to it in seconds. A first-aider dealing with a caustic splash cannot wait while someone goes to find the folder in the office.
What a COSHH assessment looks like in practice
A COSHH assessment in hospitality comes down to a few honest answers for each substance:
- How does it get used here, by whom, and how often? Two trained people cleaning the ovens or the beer lines once a week is a different risk from "whoever is on".
- What is the harm route: splash to skin or eyes, breathing fumes, swallowing from a mislabelled container?
- Could a safer product do the job? Some oven and line cleaners come in lower-hazard formats, and the assessment is where you consider them.
- What controls apply: dilution instructions followed, gloves and eye protection provided and worn, ventilation, nothing ever decanted into drinks bottles, storage locked away from food.
- What is the emergency response: eye-wash access for caustics, the first-aid steps from the data sheet, and who knows them?
Write it down substance by substance; a paragraph each is fine. Review it when a product or process changes, and on a sensible cycle otherwise, and train the people involved. The failures you find in hospitality are all avoidable: line cleaner decanted into an unmarked lemonade bottle, chemicals stored over food, no gloves in the kitchen or the cellar, and a new starter given the oven or the lines to clean because nobody said it needed training first.
Where responsibility sits
The employer holds the duty, which in most venues means the operating company, with the manager on the ground carrying it out. If a contractor cleans your lines or looks after your pool, they bring their own assessment for that job, but the substances stored on your premises are still yours to control. Like every other compliance record in the building, the register has to outlast the people who keep it. Tie each substance to a location, put the reviews on a schedule, and attach the sheets to the register itself, so they are not sitting in the inbox of a manager who has since left.
This guide is general information for UK hospitality operators, not legal advice. Requirements can differ by premises and local authority: your fire risk assessment, your food safety management system and your local EHO are the authorities on your own site.