Safety Data Sheets for COSHH: What They Cover and What They Don't

A safety data sheet (SDS) is the essential starting point for a COSHH assessment — but it is not the assessment itself. Regulation 6 of the Control of Substances Hazardous to Health Regulations 2002 explicitly lists supplier health-effects information, including any relevant SDS, as one input among many that a "suitable and sufficient" risk assessment must consider. The assessment itself remains a separate legal requirement.

Scope note: The Control of Substances Hazardous to Health Regulations 2002 apply to most harmful substances, but lead and asbestos are covered by separate regulations. (HSE)

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What Is a Safety Data Sheet in the Context of COSHH?

A safety data sheet is a structured hazard communication document that suppliers provide for hazardous substances. It consolidates the chemical's classification, safe handling requirements, first-aid and emergency information, and — critically for COSHH purposes — toxicological data and occupational exposure information.

The document is sometimes called an MSDS (material safety data sheet) or PSDS (product safety data sheet). These are older terms for the same type of document; "SDS" is now the standard label aligned with the retained CLP framework. Whatever the name on the header, the function is identical: to communicate the hazard profile of a substance from the supplier to the user.

The COSHH Approved Code of Practice (sixth edition) takes account of regulatory changes following the introduction of REACH and CLP (European Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures). (COSHH ACOP, sixth edition) The CLP framework also mandates that a product label includes the relevant hazard statements in accordance with the classification of the substance or mixture — so the label and the SDS work together as the initial hazard signal. (Retained CLP Regulation (EC) 1272/2008, Article 21)

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The Difference Between a Safety Data Sheet and a COSHH Assessment

This is where most guidance goes wrong. The SDS is an input; the COSHH assessment is the legal output.

Regulation 6 of the Control of Substances Hazardous to Health Regulations 2002 sets out what a risk assessment must include. Supplier health-effects information — including any relevant SDS — is explicitly listed as one element. But regulation 6 also requires the assessment to consider the level, type and duration of exposure; the circumstances of the work including the quantities involved; activities such as maintenance where high exposure is possible; and any relevant workplace exposure limit. (COSHH 2002, regulation 6)

None of those things appear in an SDS. The SDS describes what a substance can do; the COSHH assessment establishes what it will do in your specific workplace, with your specific workers, doing your specific tasks.

Simply filing an SDS does not constitute a COSHH risk assessment. Employers with five or more employees must record the significant findings of the assessment as soon as practicable after it is made. (COSHH 2002, regulation 6)

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The 16-Section SDS Format Mapped to COSHH Assessment Needs

Safety data sheets in the UK follow a numbered 16-section format aligned with the retained CLP framework. The table below maps each section to its relevance for completing a COSHH assessment. This is the standard industry structure — it is not independently enumerated by number in the primary sources cited on this page, so treat this as a practical reference rather than a statutory list.

SDS Section	Title	COSHH Assessment Relevance
1	Identification	Product name, supplier contact — needed to request updates
2	Hazard identification	CLP pictograms, signal word, hazard statements — feeds reg 6(2)(a) hazardous properties
3	Composition / information on ingredients	Active substances and concentrations — relevant where WELs apply to individual components
4	First-aid measures	Informs emergency procedures section of the assessment
5	Fire-fighting measures	Relevant where DSEAR overlap applies
6	Accidental release measures	Informs spillage controls and waste disposal
7	Handling and storage	Supports identification of engineering and organisational controls
8	Exposure controls / personal protection	States any WELs and recommended PPE — directly feeds reg 6(2)(f)
9	Physical and chemical properties	Vapour pressure, boiling point — helps estimate inhalation risk
10	Stability and reactivity	Relevant for combined-substance assessments under reg 6(2)(j)
11	Toxicological information	Routes of entry, health effects by route — partially answers reg 6(2)(a) and (c)
12	Ecological information	Generally outside COSHH scope
13	Disposal considerations	Waste handling — supports safe-handling controls
14	Transport information	Generally outside COSHH scope
15	Regulatory information	Flags whether additional regulations (e.g. DSEAR) apply
16	Other information	Revision date — essential for document control and review

Most COSHH-critical sections: 2, 8, 9, and 11. Section 8 is where a supplier will list any applicable GB workplace exposure limits (WELs) — GB occupational exposure limits approved by HSE, set as concentrations of hazardous substances in air averaged over a set period of time, published in EH40. (HSE — EH40 workplace exposure limits)

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Where and How to Obtain Safety Data Sheets

HSE instructs employers to identify harmful substances by reading product labels and SDSs, and to contact their supplier if in doubt. (HSE — COSHH basics: assessment) In practice this means:

• Request it at point of purchase. Suppliers are required to provide hazard information; if no SDS arrives with a product, ask for it before use.
• Request the current version. SDSs are revised when new hazard data emerge or when classification changes under CLP. Always check the revision date in Section 16.
• For process-generated hazards, there is no SDS. Wood dust from sanding, silica dust from tile cutting, and fumes from welding are all cited by HSE as harmful substances produced by work processes — not by a product in a container. (HSE — COSHH basics: assessment) For these, hazard data must come from HSE guidance, trade associations, or EH40 directly.

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Worked Example: Using an SDS to Build a COSHH Assessment for a Cleaning Product Switch

Scenario: A facilities manager at a commercial building switches a cleaning operative from a water-based neutral floor cleaner to a stronger solvent-based degreaser for stripping an industrial kitchen floor. The manager obtains the SDS for the new degreaser.

Step 1 — Identify the hazards (SDS Sections 2, 3, 11)

The manager reads Section 2: the SDS shows a flame pictogram, an exclamation mark pictogram, the signal word "Warning", and hazard statements for flammable liquid and skin/eye irritation. Section 11 confirms the substance is absorbed through skin contact and by inhalation of vapour, with effects including dermatitis on repeated skin exposure and central nervous system depression at high vapour concentrations.

What the SDS answers: The hazardous properties required by regulation 6(2)(a) and the health effects by exposure route. What it cannot answer: Whether the vapour concentration reached in this specific kitchen during a 2-hour stripping task will approach the WEL.

Step 2 — Check the WEL (SDS Section 8 + EH40)

Section 8 lists the WEL for the solvent component. The manager cross-references EH40 to confirm the current GB figure. The SDS recommends nitrile gloves, chemical splash goggles, and general ventilation.

What the SDS answers: The relevant workplace exposure limit per regulation 6(2)(f) and the supplier's recommended PPE hierarchy. What it cannot answer: Whether the kitchen's existing fixed ventilation is sufficient, or whether local exhaust ventilation (LEV) is needed — that requires a site assessment.

Step 3 — Assess who is exposed and how (on-site assessment required)

The facilities manager must now answer questions the SDS cannot:

• The operative works the stripping task for 90 minutes per shift, twice weekly — duration and frequency per regulation 6(2)(c).
• The kitchen is accessed by kitchen staff re-entering after 20 minutes and by a maintenance contractor who services extraction equipment in the same space — other persons exposed per HSE guidance. (HSE — COSHH basics: assessment)
• Existing controls: general ventilation only, no LEV. This is assessed against the SDS-recommended controls.

Step 4 — Determine further controls (regulation 7 hierarchy)

Regulation 7 of the Control of Substances Hazardous to Health Regulations 2002 requires substitution to be considered first: can a less hazardous degreaser achieve the same result? If not, engineering controls (ventilation enhancement) take priority over PPE. (COSHH 2002, regulation 7)

Schedule 2A requires control measures to take into account all relevant routes of exposure — inhalation, skin absorption, and ingestion. (COSHH 2002, Schedule 2A) The SDS flagged all three routes; the assessment now decides whether each is adequately controlled in this kitchen.

Result: The SDS provided the hazard data. The COSHH assessment — completed by the facilities manager on-site — determined that improved ventilation was needed before the task began, that kitchen staff must be excluded during the task and for 30 minutes afterwards, and that the maintenance contractor must be briefed before their next visit.

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Gap-Analysis Checklist: What Every COSHH Assessment Must Cover That the SDS Alone Cannot Provide

Use this checklist when building a COSHH assessment from an SDS. The "SDS Supply" column reflects what is typically available from the document; your on-site assessment must address every "No" and "Partial" row.

COSHH Assessment Element	Regulatory Basis	SDS Supply	Where to Get the Gap Data
Hazardous properties of the substance	Reg 6(2)(a)	Yes — Sections 2, 3, 11	SDS sufficient
Health effects by exposure route (inhalation, skin, ingestion, injection)	Reg 6(2)(a); EH40	Partial — Section 11 covers generic toxicology; site-specific effects depend on task	Combine SDS with task observation
Relevant WEL	Reg 6(2)(f)	Partial — Section 8 lists WEL if one exists; ~500 substances have WELs in EH40	Cross-reference EH40 directly
Level and type of exposure	Reg 6(2)(c)	No — SDS cannot quantify airborne concentration in your workplace	Air monitoring or COSHH Essentials tool
Duration of exposure per shift	Reg 6(2)(c)	No	On-site task observation / work scheduling
Frequency of exposure (days per week)	Reg 6(2)(c)	No	Site records, operative interview
Circumstances of work / quantities used	Reg 6(2)(d)	No	Site walk and task briefing
High-exposure activities (e.g. maintenance)	Reg 6(2)(e)	No	Site assessment; ask maintenance teams
Other persons exposed (contractors, visitors, public)	HSE COSHH assessment guidance	No	Site assessment; access control review
Existing controls and their effectiveness	Reg 6(2)(g)	No	Inspection of ventilation, PPE stocks, SOPs
Combined exposure to multiple substances	Reg 6(2)(j)	Partial — Section 10 notes reactivity; combined health effects are not assessed	Cross-reference WELs; consider additive effects
Results of health surveillance	Reg 6(2)(h)	No	Occupational health records
Results of exposure monitoring	Reg 6(2)(i)	No	Air monitoring records
Carcinogen/mutagen ALARP requirement	COSHH 2002 / EH40	Partial — Section 2 flags CMR classification	Separate ALARP controls per reg 7(5)
Process-generated hazards (dust, fume, welding)	HSE COSHH assessment guidance	No SDS exists	EH40, HSE guidance, trade body data
Worker training and information needs	Schedule 2A(g)	No	Training records; toolbox talk content

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WELs, CLP Hazard Statements, and How They Appear in an SDS

Substances with WELs are hazardous to health. WELs are GB occupational exposure limits approved by HSE, expressed as concentrations in air averaged over a defined period, and published in EH40. (HSE — EH40 workplace exposure limits) Not every hazardous substance has a WEL — EH40 covers approximately 500 substances. Where a WEL is not listed, the absence does not mean the substance is safe; the assessor must still evaluate exposure against the hazard data in Sections 2 and 11 of the SDS.

For carcinogens, mutagens, and asthmagens, the COSHH standard is tighter: exposure must be controlled to as low as is reasonably practicable (ALARP), which goes beyond simply remaining below a WEL. (HSE — EH40 workplace exposure limits) The SDS Section 2 hazard statements — which must be included on product labels in accordance with the classification of the substance under the retained CLP Regulation (Retained CLP Regulation (EC) 1272/2008, Article 21) — will indicate CMR classification, prompting the assessor to apply the ALARP standard.

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Process-Generated Hazards: When There Is No SDS

Health hazards are not limited to substances already labelled as "hazardous." Some harmful substances are produced by the work process itself — wood dust from sanding, silica dust from tile cutting, and fumes from welding are all examples cited by HSE. (HSE — COSHH basics: assessment) For these there is no supplier and no SDS. Hazard data must be sourced from EH40 (which lists WELs for wood dust, silica, and welding fume), HSE topic-specific guidance, and relevant trade associations.

The COSHH assessment for a process-generated hazard is structurally identical to one built from an SDS — the same exposure-route, duration, frequency, and affected-persons questions must be answered. The SDS is simply absent as a starting point.

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Storing, Reviewing, and Updating SDSs Within a COSHH Management System

Decision Tree: Do You Need a New or Revised COSHH Assessment?

Work through this in order:

1. New substance introduced? → Yes: obtain SDS, complete new COSHH assessment before first use.

2. Supplier has issued a revised SDS? → Check Section 16 revision date. If classification, WEL data, or PPE recommendations have changed → review and update the COSHH assessment.

3. Significant change in the work process, quantities, or task frequency? → Regulation 6(3) of the Control of Substances Hazardous to Health Regulations 2002 requires the assessment to be reviewed forthwith where there has been a significant change in the work. (COSHH 2002, regulation 6) Review required.

4. Accident, near miss, or worker health concern linked to the substance? → HSE guidance explicitly lists accidents, near misses, and worker-reported problems as triggers for review. (HSE — COSHH basics: assessment) Review required.

5. Monitoring results exceed or approach the WEL? → Regulation 6(3) requires immediate review where monitoring results show it to be necessary. (COSHH 2002, regulation 6)

6. None of the above, and scheduled review date passed? → Conduct regular review to confirm assessment remains valid.

Practical document-control points

• Store the current SDS alongside the completed COSHH assessment — they are companion documents, not alternatives.
• Record the SDS revision date and the date your assessment was last reviewed.
• Ensure SDSs are accessible to workers using the substance, not locked in a manager's filing system. DSEAR — which overlaps with COSHH for substances that are both flammable and toxic — independently requires employers to give workers access to relevant safety data sheets as part of information, instruction and training duties. (hse.gov.uk/fireandexplosion/dsear-background.htm)
• Employers with five or more employees must record the significant findings of the COSHH assessment. (COSHH 2002, regulation 6)

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How RamsDocs Helps You Manage SDSs and COSHH Assessments Together

RamsDocs is designed to close the gap between holding an SDS and completing a legally structured COSHH assessment. The platform lets you:

• Attach your SDS directly to the COSHH assessment so the two documents are always version-matched and auditable.
• Work through every regulation 6 element in a guided assessment builder — prompting you to answer the exposure-duration, frequency, and affected-persons questions that the SDS cannot supply.
• Set SDS review reminders triggered by the revision date in Section 16, so a supplier update automatically flags a COSHH assessment review.
• Store assessments centrally with worker-accessible sign-off, supporting your information and training obligations.

RamsDocs assessment outputs are structured to be PC review-ready and designed to reduce COSHH rework. They do not constitute regulatory approval and must be reviewed and adapted to your specific site, task, and substance by a competent person.

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Frequently Asked Questions

Where can I find COSHH data sheets? Request them from your product supplier before first use. Most suppliers publish current SDSs on their websites. For process-generated hazards (welding fume, silica dust, wood dust), there is no SDS — use EH40 and HSE topic guidance instead.

What do you need a COSHH data sheet for? The SDS is your primary hazard-identification input. Regulation 6 of the COSHH Regulations requires the assessment to include information on health effects provided by the supplier, including any relevant SDS. It tells you what the substance can do; your assessment determines what it will do in your workplace.

What is the difference between a COSHH sheet and a safety data sheet? They are the same document described differently. "COSHH sheet" is informal shorthand sometimes used in the field. The formal document is the safety data sheet (SDS), formerly called an MSDS or PSDS. The SDS is an input to a COSHH assessment; it is not the assessment itself.

How do I get an SDS sheet? Ask your supplier. If one is not provided with the product, contact the supplier directly and request the current version. If the substance is unclear or unlabelled, HSE advises contacting the supplier before use.

Does holding a safety data sheet satisfy a COSHH risk assessment? No. Regulation 6 of the Control of Substances Hazardous to Health Regulations 2002 requires a suitable and sufficient assessment that considers — among other things — the level, type and duration of exposure; the circumstances of the work; and who else may be exposed. None of these can be answered by an SDS. The SDS is one input among many.

What must a COSHH assessment cover beyond the SDS? At minimum: how long and how often workers are exposed; all exposure routes (inhalation, skin, ingestion); who else may be in the area (maintenance workers, contractors, visitors); existing controls and their effectiveness; whether any WEL applies and whether it is likely to be approached; and — for carcinogens, mutagens, or asthmagens — whether exposure is controlled to ALARP.

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This page is provided for general guidance only. All information must be reviewed and adapted to your specific site, substances, tasks, and workforce by a competent person before use. Nothing on this page constitutes legal advice or confirms compliance with any regulatory requirement.