COSHH for pubs: a practical guide.

What COSHH actually requires

The Control of Substances Hazardous to Health Regulations 2002 apply to any workplace using substances that can harm health. For a pub 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 in your actual premises, put controls in place, and tell the people who use them. The HSE does not expect a village pub to run a laboratory-grade system; it expects you to be able to answer "what is in that cupboard, what would it do to someone, and what have you done about it".

The usual suspects behind a bar

• Beer line cleaner: the serious one. Usually a caustic (sodium or potassium hydroxide) solution that causes severe burns and eye damage. Cellar use means confined space, haste and splash risk.
• Oven and grill cleaners: also commonly caustic, used hot, in poorly ventilated kitchen corners.
• Sanitisers and glasswasher detergents: irritants, and some combinations are dangerous. Bleach mixed with acidic descaler or with anything ammonia-based releases toxic gas.
• Descalers: acids, from the glasswasher to the coffee machine.
• Fuel gels and barbecue fluids where used, and CO2 and cellar gas, which COSHH sits alongside: asphyxiation in cellars is a real, recurring fatality in this trade.
• Pest control products, whether contractor-applied or bought over the counter.

Safety data sheets and pictograms

Every hazardous product's supplier must provide a safety data sheet on request, and most publish them online. The sheet tells 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. The register you keep is essentially: each product, its sheet, its pictograms, where it is stored, who uses it, and what your controls are. Keep it where staff can actually reach it; a first-aider dealing with a caustic splash needs the sheet in seconds, not in a folder in the office.

What an assessment looks like in practice

For each substance, honestly answer:

• How does it get used here, by whom, and how often? Line cleaning weekly by two trained keyholders 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 line cleaners come in lower-hazard formats; the assessment is where you consider them.
• What controls apply: dilution instructions followed, gloves and eye protection provided and actually worn, ventilation, never decanting 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 per 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 classic pub failures are all avoidable: line cleaner decanted into an unmarked lemonade bottle, chemicals stored over food, no gloves in the cellar, and a new starter cleaning lines because nobody said it needed training first.

Where responsibility sits

The employer holds the duty, which in a pub means the operating company, discharged by the manager on the ground. If a contractor cleans your lines, they bring their own assessment for the task, but the substances stored on your premises stay yours to control. Like every other compliance record in the building, the register only works if it survives staff change: substances assigned to a location, reviews on a schedule, and the sheets attached to the register rather than living in a departed manager's inbox.

This guide is general information for UK pub and restaurant 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.