What regulation 12 actually requires
The duty is on the employer, and it has a shape. Anyone who may be exposed to a substance hazardous to health must be given information, instruction and training that is suitable and sufficient for them to know:
- The risks
- What the substances they work with can do to them, and by which route — breathing, skin, eyes, swallowing.
- The precautions
- The controls decided in the assessment, and how to use them properly.
- The results
- Any exposure monitoring — and, where health surveillance is done, the collective results in a form that identifies nobody individually.
- What to do when it goes wrong
- The emergency arrangements under regulation 13: spills, splashes, losses of containment.
Notice what is not in that list: a syllabus, a duration, an awarding body, or a card. The regulations describe an outcome — the person knows — rather than a product.
Who needs it
Anyone who may be exposed. That is wider than the person handling the product: the labourer sweeping up after the cutting, the apprentice in the same room, the cleaner working where a substance is used.
It also reaches the people who make the decisions. Whoever writes the assessments needs to understand the work and the substances well enough for the assessment to be suitable and sufficient — and whoever supervises needs to know what the controls are, or regulation 8's "reasonable steps to ensure controls are used" has nobody taking them.
How often, and whether it expires
There is no statutory refresh interval for COSHH training, and no expiry date in the regulations. Certificates carry expiry dates because awarding bodies set them, not because the law does — which is worth knowing when a prequalification form asks for in-date certificates.
What the regulations do require is that the training stays suitable and sufficient. In practice that means it is repeated or updated when:
The work changes
A new substance, a new process, a new place. Training for the old method is training for a job nobody is doing.
The assessment is revised
If the controls changed, the people using them need to be told — an updated assessment nobody has read has changed nothing on site.
Someone new arrives
Including short-term labour and subcontractors' people, where they are exposed by your work.
Something suggests it did not stick
A near miss, a control found switched off, monitoring that came back higher than expected.
Proving it happened
This is where firms get caught, and it is rarely because the training did not happen. It is because two years later nobody can show it did.
A record needs to answer four questions: who was trained, on what, when, and how you know — a signature, a toolbox talk register, a certificate. Anything less is a memory rather than evidence.
That is the part HubTrack is for. Keeping a workforce's competence current — who holds what, what has lapsed, what is about to — is a register problem rather than a training problem, and it is the same evidence a prequalification form asks for.
Questions people ask
- Is COSHH training a legal requirement?
- Information, instruction and training are required by regulation 12 of the COSHH Regulations 2002 for anyone who may be exposed to a substance hazardous to health. A formal course or certificate is not required — the requirement is that the training is suitable and sufficient.
- How long does COSHH training last?
- The regulations set no expiry. Certificates carry dates because awarding bodies set them. What the law requires is that the training remains suitable and sufficient, which means updating it when the work, the substances or the assessment change.
- Who needs COSHH training?
- Anyone who may be exposed — not only the person handling the product, but people working nearby, and cleaners and labourers working where substances are used. Those who write assessments and supervise controls need to understand them too.
- What should COSHH training cover?
- The risks from the substances involved, the precautions and controls and how to use them, the results of any exposure monitoring and the collective results of health surveillance, and the emergency arrangements.
- How do I prove COSHH training took place?
- A record showing who was trained, on what, when, and the evidence — a signed register, a toolbox talk record, or a certificate. The training happening is the duty; being able to show it is what a prequalification form or an inspector asks for.