Purpose
Bubble Fresh (Bubblefresh Limited, company number 12691029) is committed to protecting the health and safety of our employees, clients, and anyone who may be affected by our work with hazardous substances. This policy sets out how we manage the risks from hazardous substances during our cleaning and clearance operations. We comply with the Control of Substances Hazardous to Health Regulations 2002 (as amended) (COSHH), the Classification, Labelling and Packaging of Substances and Mixtures Regulation (CLP Regulation, retained EU Regulation (EC) No 1272/2008), and the Health and Safety at Work etc. Act 1974. We follow the Health and Safety Executive (HSE) Approved Code of Practice L5 (Control of substances hazardous to health) and associated guidance, including HSE guidance note EH40 on Workplace Exposure Limits.
Scope
This policy covers two categories of hazardous substance. First, substances we bring to site: all cleaning chemicals, disinfectants, germ-killing products (biocidal products), odour-removing agents (deodorising agents), sealants, and any other products classified as hazardous under the CLP Regulation that we use during our operations. Second, substances found at client properties: unknown chemicals, unlabelled containers, pesticides, solvents, aerosols, medications, and any other potentially hazardous materials that our teams may encounter during cleaning and clearance work in vulnerable adults' homes. These properties may contain substances in unmarked or damaged containers, chemicals stored inappropriately, or residues from substances used by the occupant. This policy also covers biological hazards encountered during biohazard cleaning work, including bodily fluids, animal waste, mould, and other organic matter. Exposure to asbestos or lead is managed under their specific regulations and is outside the scope of this policy. This policy should be read alongside our Risk Assessment Policy, Infection Control Policy, Health and Safety Policy (which includes our personal protective equipment provisions), Waste Management Policy, and Training and Development Policy.
Responsibilities
The Director, Lance James, has overall responsibility for COSHH compliance across the business. This includes approving the COSHH register, making sure assessments are carried out and reviewed, providing the resources needed to control exposure, and acting on the findings of exposure monitoring and health surveillance. Team leaders are responsible for making sure COSHH assessments are followed on every job, checking that the correct products and PPE are used, carrying out dynamic assessments when unknown substances are found on site, and reporting any incidents or concerns. All employees are responsible for following the control measures set out in COSHH assessments, using PPE correctly, never mixing chemicals, reporting any substances found on site that are not in the COSHH register, reporting any symptoms of ill health that may be linked to substance exposure, and raising concerns if they believe control measures are not working or are not being followed. No employee will face any penalty for raising a genuine concern about hazardous substance risks.
Substances found at client properties
The homes of vulnerable adults may contain unknown or hazardous substances that we did not bring to site. These may include unlabelled bottles or containers, household chemicals stored in food or drink containers, prescription or over-the-counter medications, pesticides, herbicides, or rodent poisons, solvents, paint, or adhesives, illicit substances or drug paraphernalia (which our team does not attempt to identify or handle beyond making the area safe), and aerosol cans that may be pressurised or damaged. If the team discovers what appears to be a significant quantity of illicit substances, we contact the police and the referring council before proceeding. Our teams treat all unknown substances as potentially hazardous. If a team member finds an unlabelled or suspicious substance, they must not open, sniff, taste, or pour it. They must isolate the area, inform the team leader, and put on appropriate PPE before handling the container. Where a substance cannot be identified, we bag and seal it for safe disposal through our hazardous waste routes, in line with our Waste Management Policy. Medications found on site are never disposed of by our team. We set them aside and notify the client, their carer, or the referring council officer so they can be returned to a pharmacy for safe disposal. Where we find a significant quantity of hazardous or unknown substances at a property, we inform the referring council so they can take any further action needed. If a team member is accidentally exposed to an unknown substance, they follow the emergency procedures in this policy and seek medical attention immediately, taking the container or a photograph of it to the hospital where possible.
CLP Regulation and hazard classification
All hazardous substances we use are classified and labelled in accordance with the CLP Regulation (retained EU Regulation (EC) No 1272/2008). We make sure all containers carry the correct CLP hazard pictograms, signal words (Danger or Warning), hazard statements (H-statements), and precautionary statements (P-statements). Our COSHH assessments take into account the CLP classification of each substance. We train employees to recognise CLP hazard pictograms and to understand what they mean in practice, including the health hazards (such as acute toxicity, skin corrosion, respiratory sensitisation, and specific target organ toxicity) and the physical hazards (such as flammable, oxidising, or corrosive properties). When we encounter substances at client properties that still carry older orange and black warning symbols rather than CLP pictograms, our teams are trained to recognise both labelling systems.
COSHH assessments
We carry out a suitable and sufficient COSHH assessment for every hazardous substance we use, as required by Regulation 6 of the COSHH Regulations 2002. We maintain a COSHH register listing all hazardous substances in use, with corresponding COSHH assessments and safety data sheets (SDS). The register is held at the office and in digital form, and is available for inspection by employees, council partners, and regulatory bodies. Each assessment identifies the substance and its CLP classification, the tasks and situations where exposure may occur, the people at risk (including employees, clients present during work, and any other people on site), the route of exposure (inhalation, skin contact, ingestion, or eye contact), the control measures in place, and the emergency procedures. We review assessments at least annually, when we introduce a new substance, when we change how a substance is used, or following any incident involving a hazardous substance. We hold safety data sheets for all products. All employees can access them in vehicles and on site. Where employees may be exposed to more than one hazardous substance at the same time, we consider the combined effect in the COSHH assessment, as substances used together may increase the overall risk even if each one is within safe limits on its own. For substances found at client properties where no SDS is available, we carry out a dynamic COSHH assessment based on any available information (labels, pictograms, appearance, smell at a safe distance) and apply the precautionary principle, treating the substance as high risk until identified.
Hierarchy of controls
When a COSHH assessment identifies a risk from a hazardous substance, we apply controls in the following order of priority, as set out in Schedule 2A of the COSHH Regulations 2002 and HSE guidance. First, we eliminate the hazard where possible, for example by removing the need to use a particular chemical or by removing an unknown substance from the work area before cleaning begins. Second, we substitute a less hazardous product, for example by choosing a cleaning product with a lower hazard classification under the CLP Regulation. Third, we put engineering controls in place, for example by using local exhaust ventilation, opening windows and doors to increase natural ventilation, or using enclosed application systems. Fourth, we use administrative controls, for example by limiting the time employees spend working with a substance, rotating tasks, restricting the area where the substance is used, and displaying warning signs. Fifth, we provide personal protective equipment (PPE) as a last line of defence, selected on the basis of the COSHH assessment and the safety data sheet. We always follow manufacturer instructions for dilution and application, and we never mix chemicals. Mixing products can create toxic gases or reactions that are not covered by the individual safety data sheets. We never rely on PPE alone where a higher-level control is reasonably practicable. We record the controls applied in the COSHH assessment for each substance.
Client exposure and ventilation
Many of our clients are vulnerable adults who may be present in the property while we work. We take steps to protect clients from exposure to the substances we use. Before starting any work involving chemicals, we assess ventilation in the property. We open windows and doors where possible to provide natural ventilation. If the property has poor ventilation, is sealed, or has windows that cannot be opened, we use portable ventilation fans to increase airflow. We ask clients to move to a well-ventilated room away from the area being cleaned, or to leave the property temporarily if the COSHH assessment identifies a risk to anyone nearby. We ask the client or referring council whether the client has any respiratory conditions (such as asthma or chronic obstructive pulmonary disease) or chemical sensitivities, and we adjust our product selection and ventilation measures accordingly. We choose low-odour and low-toxicity products where a suitable alternative exists. We do not use products that release high levels of fumes or vapour in occupied areas unless the client has been moved to a safe location and adequate ventilation is in place. After completing work with chemicals, we ventilate the area thoroughly before the client returns. We explain to the client, or to the referring council officer or care worker, what products we have used and any ventilation steps they should follow after we leave.
Respiratory protective equipment and face-fit testing
Where a COSHH assessment identifies a risk of harmful inhalation exposure that cannot be adequately controlled by other means, we provide respiratory protective equipment (RPE). We select RPE on the basis of the substance, the concentration, the duration of exposure, and the task being carried out. RPE may include disposable filtering facepieces (such as FFP2 or FFP3 masks), half-face respirators with appropriate filters, or full-face respirators for high-risk tasks such as biohazard cleaning or work involving volatile organic compounds. All employees who may need to wear tight-fitting RPE undergo face-fit testing in accordance with HSE guidance document INDG479 (Guidance on respiratory protective equipment fit testing) and the requirements of Regulation 7(3) of the COSHH Regulations 2002 and Regulation 7 of the Personal Protective Equipment at Work Regulations 2022. Face-fit tests are carried out by a competent person using a qualitative or quantitative method appropriate to the RPE type. We repeat face-fit testing when an employee changes the type or model of RPE, when there is a significant change to the employee's facial features (such as significant weight change, dental work, or facial scarring), and at least every two years as good practice. Employees must be clean-shaven in the area where the RPE seals against the face. We record all face-fit test results and keep them for at least the duration of employment.
Pregnant workers and new mothers
Some hazardous substances pose particular risks to pregnant workers, workers who have recently given birth, or workers who are breastfeeding. Under Regulation 16 of the Management of Health and Safety at Work Regulations 1999 and Regulation 12 of the COSHH Regulations 2002, we carry out a specific risk assessment when we are notified that an employee is pregnant, has given birth within the past six months, or is breastfeeding. This assessment considers the substances the employee may be exposed to (including those classified as toxic to reproduction, mutagenic, or with specific target organ toxicity under the CLP Regulation), the route and level of exposure, and whether the existing control measures are sufficient to protect the mother and the unborn or breastfeeding child. Where the assessment identifies a risk that cannot be adequately controlled, we will adjust the employee's duties to avoid exposure, move the employee to alternative work at the same pay and conditions, or, if no suitable alternative work is available, suspend the employee on full pay in accordance with Section 67 of the Employment Rights Act 1996. We do not wait for an employee to tell us they are pregnant before considering reproductive risks. Our standard COSHH assessments flag any substance that carries reproductive toxicity hazard statements (H360, H361, H362) so that we can act quickly when notified.
Storage and handling
We store all hazardous substances securely in their original containers with labels intact. We keep an up-to-date inventory of all substances stored at our premises. We transport substances in vehicles in accordance with relevant regulations, stored upright and secured to prevent spillage. We only decant substances where necessary and clearly label all secondary containers with the product name, hazard pictograms, and key safety information. We store incompatible substances separately, in line with the compatibility information on the safety data sheet. Flammable substances are stored away from heat sources and ignition points, in line with the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR).
Emergency procedures
We train all employees in emergency procedures for chemical spills, splashes, and accidental exposure. For spills: contain the spill using appropriate absorbent materials, ventilate the area, wear the PPE specified in the safety data sheet, and dispose of contaminated materials through hazardous waste routes. For skin or eye contact: remove contaminated clothing, flush the affected area with clean water for at least 15 minutes (20 minutes for eyes), and seek medical attention. For inhalation: move the affected person to fresh air immediately. For ingestion: do not induce vomiting unless the safety data sheet specifically instructs it, rinse the mouth with water, and seek medical attention immediately. Call 999 if the person is unconscious, has difficulty breathing, or if the safety data sheet indicates the substance requires emergency medical treatment. If a client is present when a chemical emergency occurs, we move them to safety first, away from the affected area, and arrange for a carer, family member, or council officer to attend if needed. We carry first aid equipment appropriate to the substances in use on every job, including eye wash stations. Safety data sheets are available in vehicles and on site. After any emergency involving a hazardous substance, the team leader completes an incident report and we investigate the cause, in line with our Incident Reporting Policy. Where an incident is reportable under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) 2013, for example a chemical burn requiring hospital treatment or a dangerous occurrence involving a hazardous substance, we notify the Health and Safety Executive within the required timescale.
Waste disposal of contaminated materials
We dispose of all waste contaminated with hazardous substances in accordance with the Environmental Protection Act 1990, the Hazardous Waste Regulations 2005 (as amended), and our Waste Management Policy. Contaminated waste includes used absorbent materials from spills, empty chemical containers, used PPE that has been in contact with hazardous substances, cleaning cloths or rags contaminated with chemicals, and any unknown substances removed from client properties. We segregate contaminated waste from general waste on site. We bag and label contaminated waste clearly, noting the substance involved where known. We never pour chemicals down drains, toilets, or into general waste. We transport contaminated waste in sealed containers in our vehicles and dispose of it through licensed hazardous waste carriers. We keep waste transfer notes and consignment notes as required by law and retain them for the minimum periods set out in the relevant regulations (3 years for waste transfer notes, 3 years for hazardous waste consignment notes). See our Waste Management Policy for full details.
Training
All employees receive COSHH awareness training during induction, as part of their minimum 20 hours of annual training (see our Training and Development Policy). Training covers the hazards of the substances we use and those commonly found at client properties, how to read and understand safety data sheets and CLP labels, the hierarchy of controls and why it matters, correct use of PPE including RPE, face-fit testing requirements, what to do if they find unknown or unlabelled substances on site, emergency procedures for spills, splashes, and exposure, how to protect clients from exposure during work, waste disposal requirements for contaminated materials, and the additional risks that certain substances pose to pregnant workers and new mothers. We provide refresher training at least annually, when we introduce a new substance, and following any incident involving a hazardous substance. Team leaders receive additional training on carrying out and reviewing COSHH assessments, including dynamic assessments for unknown substances. We assess competence after training through observed practice and keep records in line with our Training and Development Policy.
Exposure monitoring
Where a COSHH assessment identifies a risk of significant exposure, we carry out exposure monitoring in accordance with Regulation 10 of the COSHH Regulations 2002. Monitoring may include personal air sampling to measure an employee's exposure to airborne substances against Workplace Exposure Limits (WELs) published in HSE guidance note EH40. We use the results of exposure monitoring to check that our control measures are working and to update COSHH assessments where needed. We share the results with the employees concerned and explain what they mean. We keep exposure monitoring records for at least 5 years, or for 40 years where the records relate to identifiable individuals, in accordance with Regulation 10(5) of the COSHH Regulations 2002.
Health surveillance
Where our COSHH assessments identify that health surveillance is appropriate under Regulation 11 of the COSHH Regulations 2002, we arrange health surveillance for exposed employees. This may include skin checks for employees regularly using substances that can cause dermatitis, lung function tests for employees exposed to respiratory sensitisers, and any other surveillance appropriate to the substances and exposure involved. Health surveillance is carried out by a qualified occupational health professional. If health surveillance identifies an adverse health effect linked to substance exposure, we review and strengthen the control measures for that substance, consider whether other employees may be similarly affected, and make sure the affected employee receives appropriate medical follow-up. Health surveillance records are kept for at least 40 years from the date of the last entry, in accordance with Regulation 11(3). Health surveillance and exposure monitoring records contain special category health data under Article 9 of the UK General Data Protection Regulation (UK GDPR), processed on the basis of Article 9(2)(b) (obligations under employment law, specifically the COSHH Regulations 2002). Employees can exercise their data subject rights in relation to these records as set out in our Privacy Policy.
Record keeping
We keep clear and accurate records to demonstrate COSHH compliance and to support continuous improvement. Our records include the COSHH register and all COSHH assessments, safety data sheets for every substance we use, exposure monitoring results, health surveillance records, face-fit test results for RPE, training records (including COSHH induction, refresher training, and competence assessments), incident reports involving hazardous substances, waste transfer notes and hazardous waste consignment notes, and records of any substances found at client properties that required dynamic assessment. We store records securely with access limited to authorised personnel, in line with our Information Security Policy. We retain records for the minimum periods required by law (40 years for health surveillance and identifiable exposure monitoring records, 5 years for non-identifiable exposure monitoring records, 3 years for waste consignment notes). Management and council partners can review relevant records on request.
Changes to this policy
We may update this policy from time to time to reflect changes in legislation, HSE guidance, or our working practices. Any changes will be posted on this page with an updated date. Where we make material changes that affect how we manage hazardous substances or the responsibilities of our team, we will notify all affected parties, including employees and council partners, and brief them on the changes before they take effect.
Review
The Director, Lance James, reviews this policy at least annually, when we introduce new substances, when relevant legislation or HSE guidance changes, or following any incident involving a hazardous substance. Last reviewed: February 2026. Next review due: February 2027.
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