COSHH guide

How to do a COSHH assessment when there is no safety data sheet

You can and should assess a workplace health hazard even when no supplier safety data sheet, or SDS, exists for it. COSHH applies to harmful substances used or created by work. HSE gives wood dust from sanding, silica dust from cutting, and welding fume as examples. A missing SDS is a reason to gather evidence from the material, process and authoritative guidance, not a reason to leave the COSHH register blank.

Cutting a concrete block creates a cloud that was not packaged and sold to you as that cloud, and an SDS for the base material does not describe the exposure created by every method of working it. This guide is about the assessment method for process-generated substances. Separate asbestos and lead regimes may apply to some work. HSE: COSHH assessment; HSE: COSHH FAQ.

Step 1: describe the material and task precisely

“Cutting stone” is too broad. Record the material and condition, the cutting or grinding method, tool, duration, frequency, work area, ventilation, number of people nearby and how waste is cleared. Describe changes of state. A wet product can become dust when dry and sanded, and a solid can become fume when heated. Include non-routine phases: set-up, tool cleaning, filter changes, sweeping and bag emptying can expose people who are not the primary operator. A well-controlled cut can still leave a dust problem if someone dry-sweeps the waste later. HSE: construction dust, CIS36.

Step 2: find authoritative hazard information

Ask suppliers about composition and foreseeable processing hazards, and check HSE substance, task and sector guidance. For construction dust, HSE distinguishes silica, non-silica and wood dust and explains that respirable crystalline silica is produced when concrete, brick and tile are cut, drilled or ground. If composition is uncertain and the consequence could be serious, obtain competent advice or test the material before work proceeds. Lack of information can be a reason for a more cautious investigation, not a “no SDS, low risk” entry. Do not copy a workplace exposure limit from a similar-looking material without checking the actual substance. HSE: construction dust FAQ; HSE: workplace exposure limits.

Step 3: map every exposure route and person

Inhalation is often the first concern, but consider skin and eye contact and ingestion from contaminated hands or surfaces. Draw a simple “source to person” path: where the contaminant begins, how it leaves the process, and who stands in that path. A process enclosure might protect the operator while dust escapes when a guard is opened; RPE for the operator does not protect a colleague walking through. Describe the group in full, for example “operators, nearby fitters, cleaning staff and occupants of the adjacent room”. HSE: good control practice.

Step 4: prevent or adequately control exposure

Start with prevention. Ask whether the material or process can be changed so less hazardous dust or fume is created, for example a component supplied at the right size instead of cut on site, a wet or lower-emission method, or an enclosed process. Where emissions remain, capture them close to source with properly designed local exhaust ventilation, known as LEV. PPE is a supporting control where other measures do not adequately control exposure, not an automatic substitute for source control. Name the critical conditions that make the controls effective and what happens if one fails. “Stop cutting if water flow stops” beats “use water where possible”. Plan dust-free cleaning and avoid dry sweeping of hazardous dust. HSE: COSHH control.

Step 5: check controls, then document and review

Inspection and maintenance of extraction, observation of actual work, worker feedback and exposure monitoring may all contribute, but do not set a sampling date without a decision question. Where LEV is a key control, verify it is suitable, used correctly, maintained and examined and tested as required. HSE notes that examination and testing of ventilation should happen at least every 14 months by a competent person. Record the process-generated substance, task, people, routes, controls, limits or guidance used, monitoring and surveillance decisions, responsible people and review triggers. Review regularly, and also when a new material, tool, process, location, production rate or worker group changes. Do not treat a software 12-month default as a legal rule. HSE: exposure monitoring.

FAQs

Can I write a COSHH assessment without an SDS?

Yes. Assess the harmful substance in the form produced by the work. HSE's FAQ specifically addresses process-generated substances without an SDS, using wood dust as an example. Gather hazard information from the material, process, supplier and authoritative guidance, then evaluate actual exposure and controls.

Is dust always covered by COSHH?

Dust can be a hazardous substance depending on what it is and how the work creates exposure. HSE identifies silica, non-silica and wood dust and explains COSHH covers activities that expose workers to harmful dust. Identify the material and task rather than treating every dust identically; other regulations may apply to particular materials.

Does a supplier SDS cover cutting or welding fume?

It may provide useful information about inputs, but it does not automatically describe emissions from your exact process and conditions. Assess what is generated and how workers encounter it, and seek competent advice when composition or control requirements are uncertain.

Can software generate the assessment?

Software can organise the questions, draft a task record, link evidence and track review dates. It cannot discover an unknown material, measure an exposure or verify extraction performance. A manager should review the draft against the actual process before workers rely on it.

Where Complys fits

Complys can help create a task-specific COSHH draft and track its review dates. It cannot discover an unknown material, measure exposure, verify extraction performance or replace competent judgement. The responsible person must check the draft against the actual material, method and controls before use.

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