19th September, 2023

Construction COSHH Failures And How To Avoid Them

COSHH applies to every industry, including construction, however many workplaces fail to adequately assess the risks of exposure to hazardous substances. Health risks are the biggest killer in construction, so what causes COSHH failures in construction and how can we avoid them?

Construction COSHH Failures And How To Avoid Them header image

The Control of Substances Hazardous to Health (COSHH) Regulations are a well-known set of regulations. Whatever industry to work in, including construction, COSHH applies.

And construction uses and creates its fair share of hazardous substances. Cement, paints, plaster, lead, concrete, mortar, fuels. And you can find hazardous substances in many forms on the construction site. Sprays, fumes, liquids, dust.

However many workplaces fail to adequately assess the risks from exposure to hazardous substances.

Why is this?

Often because the hazardous substances you use are not what we would classify as dangerous chemicals - they don't kill you the moment you are exposed - a sniff or a splash won't lead to instant death.

And the substances are part of everyday use, so we don't see them as scary.

If you fall off a roof or get electrocuted, you could die. No one wants a death on their construction site, so those hazards get a lot of attention.

And so they should.

But did you know that it is estimated over 600 people die each year from past exposure to silica dust? Health risks (especially hazardous substances) are the biggest killer in construction. These deaths just take longer to happen.

It is estimated that past exposures in the construction sector annually cause over 5,000 occupational cancer cases and approximately 3,700 deaths.

Compare those statistics to the 135 workers killed in fatal accidents this year, and you start to realise what a massive issue the exposure to hazardous substances is.

You might use some substances for weeks or even years without any health concerns at all. Or, you might start to notice warning signs or problems. Like trouble breathing, a cough you can't shake off, a rash or skin problems that gradually get worse.

But, you don't really know the cause or put it down to something else. Maybe you've got a bit out of shape? Maybe you have a bug? Or perhaps you just put it down to getting older.

In short, the risks are overlooked.

COSHH failures in construction include:

But what could be the consequences of overlooking the risks of hazardous substances? And how can we avoid these construction COSHH failures?

Failing to identify hazardous substances

The first and most obvious COSHH failure is not knowing when you are using a hazardous substance. You should always start by identifying the hazardous substances used within your workplace.

Construction is a high-risk industry. A lot of focus is put on the serious safety hazards (like working at height), and health hazards (like asbestos). While asbestos is a hazardous substance, it has its own specific regulations, so asbestos is not covered under COSHH.

But asbestos isn't the only hazardous substance you will come across in construction.

Common hazardous substances on construction sites can include fuels, cement, paints and cleaning substances. These substances are in use regularly and without much alarm.

Cutting bricks? That's a hazardous substance.
Drilling concrete? That's a hazardous substance.
Applying varnish? That's a hazardous substance.
Mixing cement? That's a hazardous substance.


Avoiding this COSHH failure sounds simple. You need to identify the hazardous substances you use at work.

There are a wide range of hazardous substances used in construction work. Here's an example of some common hazardous substances in construction work:

We've covered some common examples here, but of course, each construction project and activity is different. Look at what hazardous substances you use and produce in your work.

Find out more about how to identify COSHH substances in your workplace in what substances does COSHH cover?

You can often spot if a substance you buy is hazardous, from the hazard symbol on its packaging.

That's a good start, but under COSHH, you shouldn't just think about the substances you use, you also need to consider those you produce. And this is especially important in construction where you regularly create dust, fumes and vapours.

Overlooking the risks

You'll often use hazardous substances without feeling any sense of danger. Because they are used so often we become almost blind to them.

But thousands of people die each year from past exposure to hazardous substances. And hundreds of thousands of workers live with painful and debilitating illnesses from contact with hazardous substances.

For example, cement is a common building material used by trades across the construction industry. Workers use it daily, often without worry. But it is also a hazardous substance.

concrete pour

Short-term exposure to cement can lead to irritant dermatitis. The cement particles, often mixed with aggregates, abrade the skin causing irritation.

Long-term skin exposure to cement can result in dermatitis, which over time can become extremely painful. Once the skin has become sensitised any further exposure can result in severe outbreaks and worsening of the condition.

Do bricks or concrete make you worried?

Silica dust is one of our top 5 health risks, and construction workers are one of the most at-risk groups from this naturally occurring substance. Drilling or cutting concrete, stone and other building materials? You are probably producing silica dust.

And what about wood? It's natural, and trees are good, right?!

Wood dust is another substance that is regularly created during construction activities, particularly carpentry and joinery work. Exposure to wood dust can lead to health issues including asthma and sometimes cancer.

working with wood dust

Failing to control hazardous substances

Ok, so once you have spotted hazardous materials, and know the risk, the next COSHH failure is to not do anything about it.

Once you know what substances you are dealing with, you can start planning how to control the risks.

As an employer (or self-employed), you have health and safety responsibilities. Just knowing there is a risk isn't enough, you need to reduce risk as low as is reasonably practicable (ALARP).

The hazardous substances you use or create at work should all be COSHH assessed and exposure controlled to minimise the risk to employees that use them.

That's the law.

Firstly, and most obviously, failing to assess the risks from hazardous substances in the workplace is a breach of the regulations that could lead to enforcement action.

Secondly, the regulations are in force to protect workers from the effects of exposure to hazardous substances. So if you fail to assess and control the risks, the health of your workforce could suffer as a consequence.

COSHH failures are bad for you, bad for your business, and bad for your team. Time off sick, fines, breaches, compensation and loss of productivity and reputation can all result from failing to manage hazardous substances at work.

To avoid this COSHH failure, you need to control the risks and reduce exposure to safe levels.

As with all hazardous substances, a COSHH assessment should be undertaken, and this should be based on the activity and the people at risk. COSHH assessments are a legal requirement, and they will also help you to assess the risk and reduce harm.

Keep a COSHH register for any substances hazardous to health and make sure data sheets and COSHH assessments are carried out for these substances and adequate control measures are in place.

Use appropriate controls should to minimise exposure and control the risks.

And speaking of controls, that doesn't just mean PPE.

Relying only on PPE

Your first thought for controlling COSHH risks might be PPE.

Hazardous dust? Wear a mask.
Hazardous liquid? Wear gloves.

Don't just rely on personal protective equipment (PPE). PPE is important, but it is also the last line of defence and only protects one user at a time.

PPE gloves

Instead of thinking of PPE first, you should be thinking of it last. It's down at number 6 on our 7 types of COSHH control measures.

PPE has its place, but there are more effective control measures.

Often, you will need to control the risks using a combination of safety measures.

Control measures are always a mixture of equipment and ways of working to reduce exposure. The right combination is crucial.

For example, instead of just relying on gloves to protect the skin from exposure to cement particles, you can:

For inhalation exposure to hazardous dust, you can consider:

You still use PPE, but it's not the only control measure.

Now we know that COSHH applies to construction work and some of the substances that it covers. But how do you comply with COSHH, and avoid COSHH failures?

  1. Identify hazardous substances
  2. Assess hazardous substances
  3. Control exposure to hazardous substances
  4. Make suitable arrangements
  5. Plan for emergencies
  6. Create a COSHH register
  7. Monitor controls
  8. Provide information
  9. Provide training

Get more details on the 9 ways to comply with COSHH.

Need help with COSHH? Start your COSHH register today by downloading our free template to help you identify the hazardous substances in use, and download COSHH assessment templates for your work activities.

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This article was written by Emma at HASpod. Emma has over 10 years experience in health and safety and BSc (Hons) Construction Management. She is NEBOSH qualified and Tech IOSH.

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