Which regulations are actually in play
Storage sits across two sets, and confusing them is what makes people buy the wrong thing.
COSHH is about health. Storage matters to it because a container that leaks, a decanted product in an unlabelled bottle, or a solvent evaporating in a warm cupboard are all exposures — and because regulation 13 wants the arrangements for a spill in place before there is one.
DSEAR is about fire and explosion. Where a substance is flammable, DSEAR drives the quantity kept, the separation, the ignition sources and the ventilation. A flammable solvent that is also harmful to health falls under both, for different reasons.
What good storage has to achieve
- Containment
- It stays in its container, and if the container fails what comes out is caught. Liquids that could reach a drain need catching by design rather than by mop.
- Separation
- Things that react are kept apart — acids from bases, oxidisers from fuels and solvents. Section 7 and section 10 of the safety data sheet name the incompatibilities.
- Labelling that survives
- Every container says what is in it, including the one somebody decanted into. An unlabelled bottle in a store is the single most common storage failure, and the most dangerous.
- Ventilation
- Vapour does not build up in the space, and opening the door is not the ventilation strategy.
- Access
- The people who need it can get it; the people who should not — including children and the public where a store is accessible — cannot.
- Quantity
- Only what the work needs is held. The cheapest way to reduce a storage risk is to store less.
Does the law require a COSHH cabinet?
No. There is no regulation that says "a COSHH cabinet", and no legal specification for one. The phrase is a trade name for a metal cupboard, usually with a sill or a bunded base and often yellow or red.
They are frequently a sensible way to meet the requirements — containment, separation, restricted access and a place for a spill to go, in one object. But the duty is the outcome, and a firm meeting it with a bunded, ventilated, lockable store meets it just as well.
The honest test is not "do we have a cabinet?". It is: if the worst container in there failed tonight, what would be on the floor in the morning, where would it have gone, and who would find it?
Site storage, which is the harder problem
A workshop store is a solved problem. A site is not: things live in a van, a container, a lock-up or the back of a unit, they move weekly, and the people using them are not the people who put them there.
Three things go wrong reliably. Decanting — product moved into an unlabelled bottle and left. Van heat — solvents and aerosols in a metal van in July, well above what the label assumed. And accumulation — part-used tins that nobody throws away, until the store holds twenty products and the assessment covers six.
The accumulation one is why a COSHH register is worth keeping: it is the only way to notice that what the firm actually holds has drifted away from what it assessed.
Questions people ask
- What are the COSHH storage requirements?
- COSHH does not prescribe a container or a cabinet. It requires exposure to be prevented or adequately controlled and arrangements to be in place for spills and leaks — which in practice means containment, separation of incompatible substances, labelling that survives, ventilation, controlled access and holding no more than the work needs.
- Is a COSHH cabinet a legal requirement?
- No. There is no legal specification for a COSHH cabinet. Cabinets are a common way of meeting the requirements, but a bunded, ventilated, lockable store meets them equally well.
- Can I keep chemicals in an unlabelled container?
- No. Every container needs to say what is in it, including one that a product has been decanted into. An unlabelled container is the most common storage failure and the most dangerous, because nobody knows what they are dealing with in a spill or a first-aid situation.
- What should not be stored together?
- Substances that react — acids with bases, oxidisers with fuels and solvents, and anything the safety data sheet names as incompatible in sections 7 and 10. Bleach and acidic cleaners together are the everyday example, because the reaction releases chlorine gas.