COSHH Compliance for UK Pubs

Last updated: 12 April 2026

Most pub operators think COSHH is just about keeping bleach under the sink. They’re wrong. COSHH (Control of Substances Hazardous to Health) is a legal framework that covers cleaning products, pesticides, cooking oils, gas, and even some food additives—and getting it wrong can cost you your licence, a fine up to £20,000, or worse. The reason most pubs fail COSHH inspections isn’t ignorance; it’s that nobody explains what actually matters versus what’s just paperwork theatre. You need to understand what hazardous substances you’re using, where they’re stored, who’s using them, and what happens if something goes wrong. That’s it. Everything else flows from those four things. This guide covers the real COSHH requirements for UK pubs in 2026, what Environmental Health Officers actually check, and how to build a system that protects your staff and your business.

What Is COSHH and Why It Matters

COSHH stands for Control of Substances Hazardous to Health. It’s the legal framework under the Health and Safety at Work etc Act 1974 that requires employers to protect workers from chemical and biological hazards. In a pub, this means you have a legal duty to identify, assess, and control any substance that could harm your staff or customers.

The reason COSHH matters isn’t just legal compliance. It matters because your bar staff are handling substances daily that can cause serious injury: oven cleaners that burn skin, slip hazards from spilled cooking oil, inhaled fumes from industrial cleaners, and allergic reactions from food additives. A single injury can cost you thousands in compensation, closure orders, or reputational damage that drives customers away. More importantly, staff injuries are preventable with proper control measures.

I’ve personally reviewed COSHH systems at Teal Farm Pub in Washington, Tyne & Wear, where we operate wet sales, dry sales, quiz nights, and match day events with 17 staff across front of house and kitchen. The bar staff were handling multiple hazardous substances daily without even knowing which ones required special storage or what to do in an emergency. Once we mapped every substance and trained the team on practical controls, emergency incidents dropped to zero. It wasn’t complicated—it was just clarity.

Your Legal COSHH Obligations

Under the Control of Substances Hazardous to Health Regulations 2002 (as amended), you are legally required to:

• Identify every hazardous substance in your pub
• Assess the risk each substance poses to health
• Implement control measures to eliminate or reduce that risk
• Maintain and review your assessment at least every two years, or if your operations change
• Ensure all staff who work with hazardous substances receive adequate information, instruction, and training
• Keep Safety Data Sheets (SDS) for every hazardous substance and make them accessible to staff
• Provide appropriate personal protective equipment (PPE) if required
• Maintain health records if exposure monitoring is needed

If you fail to meet these obligations and an employee is injured, you can be prosecuted, fined up to £20,000, or face Crown Court prosecution with unlimited fines. More realistically, an environmental health inspection will identify gaps, issue enforcement notices, and you’ll be given a fixed timeframe to correct them. Non-compliance also affects your licensing renewal—Environmental Health Officers report to the licensing authority.

The good news: COSHH compliance is achievable for a small pub with a simple, documented system. You don’t need a dedicated health and safety manager. You need clarity about what you’re using and a way to train staff once.

Hazardous Substances in Your Pub

Most pub operators assume COSHH is about industrial chemicals. It’s not. A hazardous substance is anything that can cause harm to health—and that includes everyday cleaning products, cooking materials, and even some food items.

Common COSHH-Covered Substances in UK Pubs

• Cleaning products: Oven cleaners, drain unblockers, glass cleaners, degreasers, floor cleaners, toilet cleaners, bleach
• Cooking and bar materials: Cooking oils (disposal and handling), gas for cooking or heating, alcohol vapours in high concentrations
• Pest control: Any insecticide or rodent control chemicals used in your premises
• Food additives and allergens: Sulphites in wine, nuts in food prep areas, gluten cross-contamination (allergens are covered under a separate framework but interact with COSHH)
• Maintenance products: Paint, varnish, wood stain, adhesives, lubricants

To identify hazardous substances in your pub, walk through every area: bar, kitchen, toilets, cellar, storage, and outdoor bins. What chemicals or materials are present? What’s the label say? If it has a hazard warning symbol (skull and crossbones, flame, exclamation mark, etc.), it’s covered by COSHH. If you’re not sure, assume it is and check the Safety Data Sheet.

The most common mistake I see is pub operators treating “low-hazard” products (like general-purpose cleaners) as if they need no control at all. Even low-hazard substances require an assessment. Maybe the control measure is “store in original packaging” and “wash hands after use”—that’s still a documented control.

How to Conduct a COSHH Assessment

A COSHH assessment isn’t a form you fill in once and file away. It’s a five-step process you document and review regularly.

Step 1: Identify Hazardous Substances

List every substance in your pub that has a hazard warning label or is known to cause harm. Include:

• Product name and where it’s stored
• Who uses it and how often
• The quantity on-site

Keep the Safety Data Sheet (SDS) for each product. Suppliers are legally required to provide these free; if they don’t, ask for them or find a new supplier. The SDS tells you the chemical composition, hazards, safe use procedures, and emergency actions.

Step 2: Assess the Risk

For each substance, ask:

• How harmful is it? (Check the hazard classification on the label and SDS)
• How is it used? (Applied with a cloth, sprayed, heated, or poured?)
• Who’s exposed? (Bar staff, kitchen staff, cleaning contractors, customers?)
• How long is exposure? (5 minutes once a day, or continuous?)
• How much exposure? (Full bottle, diluted, small amount?)

Risk = Hazard × Exposure. A highly toxic substance used for 2 minutes once a month with proper ventilation is lower risk than a moderately toxic substance used daily without protection.

Step 3: Implement Control Measures

Control measures follow the hierarchy: eliminate the hazard, substitute with something safer, isolate it, engineer controls, and if none of those work, use personal protective equipment (PPE) and safe work practices.

Examples:

• Eliminate: Use a bar with built-in drain instead of manually emptying slops containing cleaning product residue
• Substitute: Replace caustic oven cleaner with less corrosive alternative
• Isolate: Store all cleaning products in a locked cabinet away from food prep areas
• Engineer: Ensure extraction fans in kitchen run during and 15 minutes after cooking with hot oil
• PPE: Provide gloves and eye protection when handling corrosive cleaners; ensure they’re accessible and staff know when to use them
• Safe practice: Document procedures: “Dilute oven cleaner 1:4 with water before use. Apply with cloth, not spray. Ensure 10-minute exposure to fumes in ventilated area only.”

The control measure must be proportionate to the risk. You don’t need a respirator for diluted general-purpose cleaner, but you do for concentrated drain unblocker or oven cleaner aerosol.

Step 4: Record Your Assessment

Document everything. A simple table works fine:

Substance	Location	Who Uses It	Risk	Control Measures
Oven cleaner (Product X)	Kitchen store cupboard	Kitchen staff, Monday–Friday mornings	High (corrosive, respiratory irritant)	Dilute 1:4 with water. Use cloth application only. Work in ventilated area. Gloves and eye protection provided. Staff trained annually. SDS accessible in kitchen.

Keep this document accessible to your team and Environmental Health Officers. Update it when you change products, procedures, or staffing.

Step 5: Review and Update

Review your COSHH assessment at least every two years, or whenever:

• You introduce a new product or substance
• You change how a substance is used (e.g., more frequent, different staff)
• An incident or near-miss occurs
• A staff member raises a concern
• Environmental Health Officer feedback suggests a gap

Document the review date and any changes made.

Staff Training and Communication

Paperwork is only half of COSHH compliance. The other half is staff who understand what they’re handling and why the controls matter.

Staff training is not a generic health and safety video watched once during induction. It’s practical, specific, and repeated when procedures change or new staff join.

What Training Should Cover

• Identification: Which substances they use in their role and where they’re stored
• Hazards: What harm each substance can cause (e.g., “This oven cleaner is corrosive—it will burn skin and eyes”)
• Safe use: How to use it safely: dilution, application method, PPE required, ventilation needed, time limits
• Storage: Where it’s kept, why it’s kept there, what to do if it spills or leaks
• Emergency: What to do if someone is exposed: rinse eyes with water for 15 minutes, call 111, get fresh air, call emergency if severe
• Access to information: Where the Safety Data Sheet is and how to read it

Make It Stick

At Teal Farm Pub, we found that one 30-minute group training session during induction wasn’t enough. Staff forgot details within weeks. What worked was:

• Laminated cards at each storage point showing the substance name, hazards, and safe use steps (laminated so they survive in a damp environment)
• Monthly toolbox talks (5-10 minutes) during staff meetings, rotating which substance is discussed
• Quick-reference posters in the kitchen and bar showing where PPE is, what to do in an emergency, and which products are hazardous
• Annual refresher training documented and signed off

Environmental Health Officers prioritise evidence of staff training over perfect paperwork. If an EHO asks a bar staff member “What should you do if this cleaning product splashes in your eyes?” and they answer correctly, you’ve shown compliance. If they have no idea, all the forms in the world won’t save you.

What EHOs Actually Check

When an Environmental Health Officer inspects your pub for COSHH compliance, they’re looking for three things:

1. Risk Assessment Documentation

They’ll ask to see your COSHH assessment. It doesn’t need to be fancy—a simple spreadsheet listing substances, risks, and controls is fine. What they’re checking for:

• Is there an assessment at all?
• Does it cover the substances actually in your pub?
• Are control measures documented and proportionate to the risk?
• Is it current (within two years)?

2. Safety Data Sheets (SDS)

They’ll ask where your SDS documents are. They should be:

• Readily accessible to staff (not in a filing cabinet in the office)
• Current versions (SDS are updated regularly)
• Available for every hazardous substance on-site

The most common COSHH failure is substances in use with no SDS available. If you can’t find the SDS, contact your supplier immediately or stop using the product.

3. Staff Knowledge and Practice

They’ll observe how staff actually use the substances:

• Are cleaning products stored safely and labelled?
• Are staff wearing appropriate PPE?
• Is there adequate ventilation in use areas?
• If asked, can staff explain safe use and emergency procedures?

An EHO will often chat informally with bar or kitchen staff and ask them about a substance they use. If they say “I don’t know, I just use it,” that’s a red flag. If they say “It’s a corrosive cleaner, I wear gloves, and if it gets in my eyes I’d rinse them under water for 15 minutes and call for help,” that’s compliance.

What They Don’t Usually Obsess Over

EHOs are less concerned with:

• Perfectly formatted forms (a simple list works fine)
• Colour-coded systems or fancy templates
• Generic risk assessments copied from the internet (unless they match your actual operations)

What matters is demonstrable understanding and practical control.

COSHH and Your Pub’s pub IT solutions guide

Some pub management software platforms now include COSHH tracking modules where you can store SDS documents, log training completion, and set reminders for assessment reviews. If you’re evaluating pub management software in 2026, ask whether it includes COSHH features. It’s not essential, but it reduces the admin burden—especially when managing 17 staff like we do at Teal Farm Pub.

For most pubs, a simple spreadsheet with printed SDS documents in a folder at the bar is sufficient. Don’t over-engineer it.

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