Who Can Complete and Approve a COSHH Assessment?

A COSHH assessment can be completed by an employee or external adviser who has the knowledge, skills, experience and workplace information needed for the task. COSHH does not create one universal “licensed assessor” role. The employer remains responsible for ensuring the assessment is suitable and sufficient and that its controls are implemented.

Does a COSHH assessor need a specific qualification?

There is no single qualification that automatically makes someone competent for every COSHH assessment. Competence is proportionate to the substances, processes, exposure and control decisions involved.

HSE's step-by-step guidance explains that people doing work connected with the employer's COSHH duties need the necessary information, instruction and training (HSE HSG97). A simple, familiar cleaning task may be assessed in-house by a trained supervisor. A process involving respiratory sensitisers, uncertain exposure, complex LEV or biological monitoring may require an occupational hygienist, engineer or other specialist.

What should a competent COSHH assessor know?

The assessor must understand both source information and work as performed. They should be able to:

• identify substances hazardous to health, including process-generated dusts and fumes;
• verify that the SDS matches the product;
• describe quantity, frequency, duration and method;
• identify inhalation, skin, eye and ingestion routes;
• recognise everyone who may be exposed;
• apply relevant workplace exposure limits and authoritative guidance;
• choose controls in an effective order;
• understand how engineering controls work and fail;
• specify when monitoring, health surveillance or specialist advice may be needed;
• record uncertainty and stop where evidence is insufficient.

The assessor also needs access to operators, the workplace and records. A technically qualified person cannot produce a suitable task assessment from an SDS alone. HSE says an SDS does not replace the workplace-specific assessment (HSE COSHH FAQ).

Who should provide information to the assessor?

Assessment should draw on people who know the task, controls and affected workforce. Useful contributors include:

Consultation is evidence, not a transfer of the assessor's judgement. Conflicting accounts should be resolved by observation or further evidence.

Who can approve a COSHH assessment?

COSHH does not prescribe one universal internal approval title. The employer should define an approval route proportionate to risk and organisational structure.

An approver should have enough competence and authority to check that the assessment is complete, challenge unsupported assumptions, allocate resources and stop work where controls are inadequate. Approval by a manager who cannot evaluate the technical content should be paired with competent technical review.

A useful approval check asks:

1. Does the assessment match the exact product and task?
2. Are exposure routes and people complete?
3. Are controls feasible, installed and evidenced?
4. Are actions owned and funded?
5. Are workers informed and trained before use?
6. Are review triggers and document history defined?

The COSHH workflow can support distinct author, reviewer and approver roles without turning approval into a tick-box.

Does the employer remain responsible if a consultant is used?

Yes. External advice can support the duty, but it does not remove the employer's responsibility for the workplace. The employer controls the process, people, equipment and resources and must ensure that the assessment is suitable and controls are applied.

When appointing a consultant, define scope, competence, access to the workplace, deliverables and how recommendations will be closed. Check whether specialist claims are supported by measurements, design information or recognised guidance.

Can software or AI complete the assessment?

Software can organise source data and produce a draft, but a competent person must validate the workplace facts and controls. Automated output cannot observe the task, confirm a hood is effective, know a container was substituted or decide whether workers can follow the method.

Use AI or templates to reduce transcription, then review every hazard, quantity, exposure route, control, PPE choice and source citation. The assessment features should preserve source fidelity and human sign-off rather than imply that generation equals approval.

How should competence be documented?

Document why each role is suitable for the assessments assigned. Useful evidence includes relevant training, task knowledge, experience, supervised practice, qualifications where applicable and access to specialist support.

Use boundaries such as:

• trained supervisors may assess defined low-complexity tasks;
• safety advisers review moderate-risk assessments;
• occupational hygiene input is required where exposure cannot be confidently evaluated;
• engineering specialists verify LEV or process controls;
• senior approval is required before high-risk work begins.

Review competence when duties, processes or regulations change. A certificate gained years ago is not evidence of current familiarity with a new process.

What happens when the assessor is unsure?

Uncertainty should trigger evidence gathering or escalation, not a confident guess. Pause approval when product identity is uncertain, source data conflicts, exposure cannot be estimated, controls are unverified or specialist health effects are involved.

Record the question, interim safeguards, owner and required expertise. The help centre can support record structure, while technical uncertainty may still require HSE guidance, supplier information or a competent specialist.

Good governance separates preparation, technical challenge and authority while keeping responsibility clear. The employer owns the outcome; competent people supply the evidence and judgement needed to reach it.

How should competence match assessment complexity?

Use a scope matrix so people know which work they may assess and when to escalate. Consider hazard severity, exposure uncertainty, process variability, engineering controls, monitoring and health-surveillance implications.

The matrix should guide allocation, not replace judgement. A normally simple task can become complex when controls fail or information conflicts.

What is the difference between review and approval?

Review tests technical quality; approval authorises the organisation to rely on the assessment and actions. One person may perform both roles for simple work, while higher-risk assessments benefit from separation.

The reviewer checks sources, task context, exposure and controls. The approver confirms that actions, resources, training and restrictions are in place. A signature before action completion should clearly state whether work is authorised and under what interim conditions.

How should contractors be handled?

The host and contractor must exchange enough information to control combined risks. The contractor may assess its own product and method, but the host knows local ventilation, nearby workers, emergency arrangements and simultaneous activities.

Check competence, product identity, SDS, method, controls and change notification before work. Do not accept a generic contractor COSHH sheet that names no site, task or quantity. HSE says employers need to know what hazardous substances contractors bring and how harm to workers will be prevented (HSE assessment guidance).

When should competence be reassessed?

Review competence after new processes, significant errors, role changes or long gaps in practice. Use observed assessments, feedback and continuing development, not certificate dates alone.

If audits find copied controls, wrong SDS matches or missed exposure routes, address both the individual record and the competence system. Provide supervised practice and restrict scope until improvement is demonstrated.