A Safety Data Sheet Isn’t a COSHH Assessment

Mark Cave

Picture this. A facilities manager asks for your COSHH assessment before you start on a rendered elevation at a school. You walk to the van and come back with a folder. Inside are the safety data sheets for your sodium hypochlorite, your DDAC biocide and your surfactant. Printed, tabbed, sixteen sections each. It looks thorough. And it isn't a COSHH assessment. Not even close.

Mark Cave

I'm Mark Cave from SoftWash UK. In an earlier episode, the one about the 240 things you need to get right, I said in passing that holding a safety data sheet isn't a COSHH assessment. A few of you came back and asked me to unpack that properly. So that's today.

Mark Cave

Let's start with what the regulator says. The HSE's own COSHH guidance states that a good safety data sheet does not substitute for carrying out and recording a COSHH risk assessment. That's not my opinion. That's the Health and Safety Executive. The data sheet is written by the chemical supplier, under UK REACH and CLP, to describe the product. COSHH Regulation 6 puts a different duty on you, as an employer or as a self employed contractor. You have to assess the actual risk to health from how you store, handle, dilute and apply that substance, in your working environment.

Mark Cave

The way I think about it, the data sheet is an input. The COSHH assessment is the output. The sheet gives you raw information about the substance. Your assessment takes that information and turns it into decisions about your task, your site and your people. A folder of inputs, with no output, means the real work hasn't been done.

Mark Cave

So what can't a data sheet tell you? Quite a lot. It describes the product as supplied. Take neat sodium hypochlorite at around 14 to 15 percent. The sheet covers that concentrate, in storage and transport. It has no idea how you'll use it.

Mark Cave

It doesn't know your task method. Are you decanting by hand, batch mixing in a tank, or drawing it through an inline proportioner like a Dosatron? Those are three different exposure pictures.

Mark Cave

It doesn't know your delivery. A low pressure fan nozzle, a chemical resistant wand, a water fed pole working at height. Low pressure does not mean zero exposure. Mist and spray drift off a gable wall can reach your eyes and your lungs, and that's exactly the sort of thing an assessment has to deal with.

Mark Cave

It doesn't know your working dilution. Neat concentrate at 15 percent is a very different risk from a working mix of 1.5 to 3 percent active on render or stone. It doesn't know whether you're mixing outdoors or in the back of an unventilated van with the doors shut. It doesn't know if you're a lone worker or have a ground crew. It doesn't know whether the people at risk are building occupants, school pupils, care home residents, pets, or pedestrians on the footpath next door. And it doesn't know there's a pond by the lawn border, or a surface water gully that runs straight to a local watercourse.

Mark Cave

Only you know those things, because you've been to the site. That's why the assessment has to be yours.

Mark Cave

Now, that doesn't mean the data sheet is useless. Far from it. It's where you get the facts, and a few sections matter most.

Mark Cave

Section 2, hazard identification. That gives you the pictograms, the signal word and the hazard statements, things like skin corrosion, serious eye damage and aquatic toxicity. Section 4, first aid. What exactly do you do for eye contact, skin contact or inhalation. Sections 6 and 7, accidental release and handling and storage. That's spill containment, ventilation and segregation, and yes, never store acids near hypochlorite. Section 8, exposure controls and personal protection. And section 11, toxicological information, which covers exposure routes and health effects.

Mark Cave

One tip on section 8. If it quotes exposure limits, cross reference them against the workplace exposure limits in the HSE document EH40. Don't just trust whatever the supplier sheet says, especially an older one.

Mark Cave

Then you build the assessment around your task. Here's how I'd structure it. First, the delivery risk. Say what you're spraying, how, and what it does to the air around you. That's where EN 166 splash goggles or a full face visor come in, not sunglasses. It's where chemical resistant gloves, nitrile to EN 374, come in, not ordinary builder's gloves.

Mark Cave

Second, mixing controls. Here's something many contractors overlook. Most chemical splash incidents don't happen while spraying the wall. They happen during decanting, container swaps and hose disconnections. So your assessment should say how you decant, how you keep containers upright and secure, and that you mix outdoors or at least with the vehicle doors open.

Mark Cave

Third, public and property safeguards. Exclusion zones, warning signage, closing windows on the building, turning off air handling intakes where you can, and thinking about where your hose lines run across walkways.

Mark Cave

Fourth, runoff and environmental planning. Work out which drains are surface water and which are foul. Use drain covers or bunding where it's needed, pre wet vegetation, and have clean water ready for flushing.

Mark Cave

Fifth, emergency preparedness. An accessible eyewash, a spill kit, clean emergency wash water, and a plan everyone on the job actually knows. Not a plan that lives in a drawer.

Mark Cave

Why does this matter commercially? Because facilities managers, commercial landlords, tier 1 contractors and local authorities will ask for RAMS and a specific COSHH assessment before they let you on site. If you hand over a supplier data sheet instead, that's an immediate red flag. It tells them you don't yet understand the difference. Hand over a proper, site specific assessment and you've told them you're a professional. That can be the difference between winning the work and being politely shown the gate.

Mark Cave

A tool like the RAMS pack we supply can give you a structure so you're not starting from a blank page. But it has to be adapted to the actual job. A template is a starting point, never a substitute for your own judgement.

Mark Cave

And that's really the bigger point. Professional softwashing is about understanding the process, not just buying chemicals. Podcasts like this are a good place to start. But if you're serious about offering this work properly, the CPD Certified Softwash Training Course at softwashing.uk takes you much deeper into chemical selection, safety, compliance, documentation and real world application. It's online, so you learn at your own pace. It was built from years of industry experience to help you avoid expensive mistakes. And completing it opens the door to becoming an Approved Softwash Applicator, with a directory listing and a place in the National Association of Softwash community.

Mark Cave

So here's a challenge before you go. Open that folder in your van. Pick one chemical and one real job you've got coming up. Write down the task, the dilution, the people nearby, and where the water goes. That's your first genuine COSHH assessment. Do it once, and you'll never look at that folder the same way again. Thanks for listening, and until next time, stay safe and keep cleaning smarter.