Is a COSHH register a legal requirement?

Not by that name. The regulations require a suitable and sufficient assessment before work liable to expose people, and its review when it may no longer be valid. A register is the practical way firms keep on top of that across many substances.

What should a COSHH register contain?

Each substance as people actually name it, where and by whom it is used, its hazard classification and exposure limit, the safety data sheet with its version, the assessment covering it, and a named person responsible for reviewing it.

What is the difference between a COSHH register and a COSHH assessment?

The assessment is the decision about one substance in one piece of work. The register is the list of everything the firm uses, with the assessments and data sheets held against it, so nothing gets missed and nothing goes stale.

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What is a COSHH register, and what goes in one?

A COSHH register is the list of every hazardous substance the firm actually uses, with the assessment and the safety data sheet held against each one. The regulations do not name it or require it by that name — it is the practical answer to a duty that is otherwise impossible to keep on top of.

This page covers what a register is, what belongs in one, and why firms keep them.

Health and exposure records are a separate legal duty with their own retention periods — forty years for health records — and are not part of a substance register.
A stock or ordering system is a different list with a different purpose, even where it names the same products.

On this page

What it is, and why it exists
What goes in one
Why a folder of PDFs stops working
Keeping it current

What it is, and why it exists

Nothing in the regulations says "keep a register". What they say is that an employer must not do work liable to expose people without a suitable and sufficient assessment, and must review it when it may no longer be valid.

Try to satisfy that across forty products, six vans and a store, using a folder of PDFs, and the problem becomes obvious. Nobody knows which assessments exist, which sheets are current, or that the firm started using something in March that nothing covers.

A register is simply the list that makes those questions answerable. It is a management tool, not a legal document — but it is what stands behind the legal documents when somebody asks for them.

What goes in one

The substance, as people call it: The trade name on the tin *and* what it actually is. "Gap filler foam" and "polyurethane foam" want to find the same row.
Where it is used, and by whom: Which trades, which jobs, which vehicles. This is what tells you who a change affects.
The hazard picture: Classification, pictograms, and the workplace exposure limit where the substance has one.
The safety data sheet: With its version and revision date, so "is this current?" has an answer. See reading a data sheet.
The assessment: The one that covers this substance for this work, and when it was last reviewed.
Who is responsible: A named person for the review. A register with no owner is a list that ages.

Why a folder of PDFs stops working

Three failures, and every firm that has kept one recognises all three.

Drift
What the firm holds moves away from what it assessed. New products arrive with a job and nobody adds them; old ones stay in the folder long after the last tin went.
Staleness
Safety data sheets are revised and the folder is not. A sheet from 2016 may not describe what is in the tin, and nothing in a folder tells you which ones are behind.
Retrieval
The moment it matters — a prequalification form, a client's onboarding, an incident — somebody has to find the right assessment for the right substance for the right job, at speed. That is precisely when a folder is worst.

Keeping it current

A register earns its keep only if adding to it is easier than not. In practice that means one rule: a substance new to the firm gets a row before it gets used, not afterwards.

Then two habits. Check the sheets against their revision dates periodically, and review a row whenever the work it belongs to changes — the same triggers that make an assessment stop being valid.

That is the whole discipline, and it is also the honest reason software helps: not because a spreadsheet cannot hold a list, but because a spreadsheet cannot notice that a sheet is three versions behind or that the job it belonged to finished last year.

Questions people ask

Is a COSHH register a legal requirement?: Not by that name. The regulations require a suitable and sufficient assessment before work liable to expose people, and its review when it may no longer be valid. A register is the practical way firms keep on top of that across many substances.
What should a COSHH register contain?: Each substance as people actually name it, where and by whom it is used, its hazard classification and exposure limit, the safety data sheet with its version, the assessment covering it, and a named person responsible for reviewing it.
What is the difference between a COSHH register and a COSHH assessment?: The assessment is the decision about one substance in one piece of work. The register is the list of everything the firm uses, with the assessments and data sheets held against it, so nothing gets missed and nothing goes stale.