Dental practices use numerous products and substances that can harm health if they are stored, handled, mixed or disposed of incorrectly. These include cleaning chemicals, instrument disinfectants, dental materials, waterline products, laboratory dusts and biological agents.

The Control of Substances Hazardous to Health Regulations, commonly known as COSHH, require employers to assess these risks and prevent or adequately control exposure.

However, effective COSHH management involves more than collecting safety data sheets or keeping a large folder in the practice. A compliant system must reflect the substances used, the activities performed and the people who could be exposed within that particular dental workplace.

The Care Quality Commission has reinforced this through Dental Mythbuster 41, which explains how dental providers should approach hazardous substances and COSHH risk assessments.

This guidance does not introduce new legislation. It clarifies how existing COSHH duties apply in dental practices and the evidence providers may need to demonstrate that risks are being managed effectively.

COSHH compliance in a dental practice requires the employer to identify hazardous substances, assess how people may be exposed, prevent or control that exposure, inform and train staff, and regularly review whether the controls remain effective. Safety data sheets support this process but do not replace a COSHH risk assessment.

What Is COSHH in a Dental Practice?

COSHH stands for the Control of Substances Hazardous to Health. It refers both to the relevant legal regulations and to the system an employer uses to manage exposure to hazardous substances at work.

Under COSHH, a hazardous substance is not limited to a chemical displaying a hazard symbol. Hazardous substances can include:

• Chemicals and products containing chemicals
• Fumes
• Dusts
• Vapours
• Mists
• Gases
• Biological agents
• Substances produced during work activities

In a dental practice, exposure may occur through inhalation, skin or eye contact, accidental ingestion, inoculation or contact with damaged skin.

A product may also present different levels of risk depending on how it is used. A chemical stored in a sealed container presents a different exposure risk from the same chemical being diluted, sprayed, poured or used repeatedly in a poorly ventilated room.

A suitable COSHH assessment must therefore consider the actual task, environment, quantity, frequency of use and people who may be exposed.

Why COSHH Matters in Dental Practices

COSHH is sometimes treated as a paperwork requirement, but its primary purpose is to prevent ill health.

Poor control of hazardous substances can contribute to:

• Skin irritation or dermatitis
• Eye injuries
• Allergic reactions
• Respiratory irritation or occupational asthma
• Chemical burns
• Headaches, nausea or dizziness following vapour exposure
• Injury caused by spills or incompatible chemicals
• Long-term health effects following repeated exposure
• Infection following exposure to harmful biological agents

Dental nurses may be particularly exposed because they frequently handle cleaning products, decontamination chemicals, dental materials and clinical waste. They may also be responsible for stock rotation, dilution, spill management and maintaining the practice’s COSHH records.

Good COSHH management supports the CQC key question of whether a service is safe. It also contributes to effective governance because the practice must be able to show that risks have been identified, controls have been implemented and staff understand the procedures they are expected to follow.

What Has CQC Clarified Through Dental Mythbuster 41?

Dental Mythbuster 41 brings existing COSHH requirements into a dental setting. It reinforces that providers must identify hazardous substances, assess the risks associated with their use and take appropriate action to prevent or control exposure.

A suitable process should include:

1. Identifying hazardous substances used or generated in the practice.
2. Determining who could be exposed and how exposure could occur.
3. Evaluating the level of risk.
4. Preventing exposure where reasonably practicable.
5. Introducing suitable controls where exposure cannot be prevented.
6. Recording significant findings where required.
7. Providing staff with information, instruction and training.
8. Monitoring whether control measures are being used and remain effective.
9. Reviewing assessments when products, working methods or other relevant circumstances change.

The guidance should not be interpreted as a demand for a particular type of COSHH folder or a fixed number of assessment forms.

The central question is whether the practice has a suitable and sufficient system for controlling exposure to substances that could harm health.

Common Hazardous Substances and Exposures in Dentistry

The substances requiring assessment will depend on the services, products and procedures used by the individual practice.

Examples may include:

This is not a standard list that every practice should copy into its COSHH folder. Each practice must develop an inventory based on what it actually purchases, stores, uses or generates.

Products that are no longer used should be removed from the inventory and disposed of appropriately. Newly introduced substances should be assessed before, or as part of, their introduction into the workplace.

Safety Data Sheets Are Not COSHH Risk Assessments

One of the most common COSHH mistakes in dental practices is collecting safety data sheets and treating them as completed risk assessments.

A safety data sheet provides important information about a chemical product, including:

• Its hazardous properties
• Possible health effects
• Safe handling and storage
• Recommended exposure controls
• Appropriate personal protective equipment
• First-aid measures
• Firefighting measures
• Spill-management information
• Disposal considerations

This information is essential, but it does not describe precisely how the product is used in a particular dental practice.

For example, a safety data sheet will not necessarily identify:

• Who dilutes or handles the product in the practice
• How frequently it is used
• The quantity used during each task
• Whether it is sprayed, poured or applied with a wipe
• The ventilation available in the room
• Where it is stored
• Whether patients, contractors or other staff could be exposed
• Whether the manufacturer’s recommended controls are followed
• What local spill arrangements are available

The Health and Safety Executive states clearly that a safety data sheet is not a risk assessment. It should be used as a source of information when completing the practice’s own assessment.

A folder containing current safety data sheets is valuable. A folder containing only safety data sheets is not a complete COSHH system.

What Should a Dental COSHH Risk Assessment Include?

There is no single legally prescribed COSHH assessment form. The format can vary, provided the assessment is suitable and sufficient for the substance, task and level of risk.

A dental practice COSHH assessment should normally identify:

• The product, substance or biological agent
• The task or activity in which it is used or generated
• Its hazardous properties
• Who may be exposed
• Possible routes of exposure
• How frequently the task is carried out
• The likely duration and level of exposure
• Existing control measures
• Whether exposure can be eliminated or reduced further
• Required personal protective equipment
• Safe handling and dilution instructions
• Storage requirements
• Spill and emergency procedures
• First-aid arrangements
• Waste-disposal requirements
• Any monitoring or health-surveillance requirements
• Additional actions required
• The person responsible for completing those actions
• The assessment date
• The planned review arrangements

Practices with five or more employees must record the significant findings of their assessments. The HSE recommends documenting the steps taken even where an employer has fewer than five employees, as a written record provides clarity and helps demonstrate that risks have been considered.

Generic templates can provide a useful starting point, but they must be adapted. An assessment copied from another practice may be unsuitable if the products, equipment, procedures or working environment are different.

Applying the Hierarchy of Control

Providing gloves and eye protection does not automatically mean the risk has been adequately controlled.

COSHH requires employers to prevent exposure where reasonably practicable. Where exposure cannot be prevented, it must be adequately controlled.

The practice should consider controls in a logical order.

Eliminate the substance or activity

First consider whether the hazardous substance is necessary. A discontinued product should not remain stored indefinitely, and an unnecessary process should not continue simply because it has always been used.

Substitute it with a safer alternative

Where possible, replace the substance or method with one presenting a lower risk. Any replacement must still be assessed because “safer” does not mean risk-free.

Change or contain the process

Exposure may be reduced through measures such as using closed containers, pre-dosed products, suitable extraction, effective ventilation or equipment that reduces direct handling.

Introduce safe systems of work

Clear procedures should cover receiving, storing, preparing, using, transporting and disposing of the substance.

The procedure should reflect how the task is performed in the practice. It should also address accidental exposure, spillages and equipment failure.

Provide information, training and supervision

Staff must understand the hazards and the controls they are expected to use. New employees, trainees and temporary staff should receive appropriate instruction before carrying out relevant tasks.

Supervision may be necessary until the individual can demonstrate that they can complete the task safely.

Use suitable PPE

Personal protective equipment may still be necessary, but it should normally support other control measures rather than replace them.

The PPE must be appropriate for the specific substance and exposure route. A standard pair of clinical gloves may not provide suitable chemical protection for every product.

The HSE advises employers not to select PPE automatically as the first control measure, because it is generally less reliable than preventing or controlling exposure at source.

What Dental Staff Need to Know

Having completed assessments is not enough if staff do not understand them or cannot apply the required controls.

Dental team members should know:

• Which substances and activities present a risk
• How they could be exposed
• The possible effects of exposure
• How to use the products safely
• Whether products require dilution
• Which substances must never be mixed
• What PPE is required
• Where products must be stored
• Where safety data sheets and assessments are kept
• What to do following a spill, splash or accidental exposure
• How to dispose of the substance safely
• Who to report a concern, incident or defective control measure to

Training should be relevant to the employee’s role. Asking staff to sign a generic COSHH policy without checking their understanding is weak evidence of competence.

Practices can strengthen their evidence through:

• Induction training
• Product-specific instruction
• Practical demonstrations
• Staff-meeting discussions
• Competency checks
• Training records
• Spill-response exercises
• Periodic knowledge reviews

Where manufacturers update their instructions or a new product is introduced, staff affected by the change should receive updated information.

How Often Should COSHH Assessments Be Reviewed?

COSHH does not impose a universal annual review date for every risk assessment.

The appropriate review frequency depends on the nature of the risk, the work performed and the likelihood of change. A practice may choose an annual review cycle as part of its governance system, but it should not wait for the scheduled date if circumstances change earlier.

An assessment should be reviewed when:

• A new product or substance is introduced
• A product formulation changes
• Updated safety information becomes available
• The practice changes supplier
• The way the product is used changes
• New equipment or working procedures are introduced
• Staff report problems with the controls
• An exposure incident, accident or near miss occurs
• Monitoring suggests that controls are ineffective
• The substance is moved to a different storage or working area
• The assessment may no longer be valid or sufficient

The review does not necessarily require the entire assessment to be rewritten. If the assessment remains suitable and the controls continue to work, the practice can record that it has been reviewed and remains current.

The HSE’s COSHH guidance explains that review intervals should reflect the type of risk and likelihood of changes. This is more defensible than applying an arbitrary date without considering the actual circumstances.

What Might CQC Look for?

CQC does not prescribe one compulsory COSHH folder layout. Inspectors may consider different sources of evidence when assessing whether hazardous substances are being managed safely.

Relevant evidence may include:

• A current inventory of hazardous substances
• Suitable substance-specific or activity-based assessments
• Current safety data sheets
• Evidence that the assessments reflect actual working practices
• Appropriate storage and labelling
• Clear dilution or preparation instructions
• Effective measures to prevent or control exposure
• Suitable PPE where required
• Spill kits and emergency arrangements
• Staff training and competency records
• Defined review arrangements
• Records of incidents, near misses and follow-up actions
• Evidence that staff understand the relevant procedures
• Evidence that control measures are followed consistently

Inspectors may also compare written procedures with what happens in practice.

An assessment stating that a product is stored securely has limited value if the product is found unlabelled or accessible in an unsuitable area. Similarly, a procedure requiring eye protection is undermined if staff routinely complete the task without it.

The strongest evidence is alignment between the assessment, staff knowledge, available equipment and day-to-day practice.

Common COSHH Compliance Mistakes

Treating safety data sheets as completed assessments

Safety data sheets provide product information, but they do not assess the practice’s specific task or environment.

Using generic assessments without adapting them

Templates that contain incorrect products, rooms, job roles or controls do not demonstrate that the practice has assessed its own risks.

Assessing the product but not the activity

Risk depends on how a substance is used. Spraying, pouring, mixing, grinding and wiping can produce different routes and levels of exposure.

Relying only on PPE

Gloves, masks and eye protection may be necessary, but the practice should first consider whether exposure can be eliminated or controlled more effectively.

Forgetting process-generated substances

Hazards can arise from dusts, vapours, aerosols and biological material produced during work, even when there is no packaged product with a safety data sheet.

Failing to update the substance inventory

Assessments for products no longer used can remain in the folder while newer products have not been assessed.

Ignoring manufacturer changes

A familiar product may change formulation, classification or safety instructions. Current documentation should therefore be obtained from the supplier or manufacturer.

Using assessments that do not match practice

The written controls must be realistic and consistently followed. An impressive document does not compensate for unsafe working practices.

Obtaining staff signatures without checking understanding

A signature confirms that a document was signed. It does not, by itself, demonstrate that the employee understood the risks or can follow the required procedure.

Dental Practice COSHH Checklist

Use the following questions to review your current system:

• Have all hazardous substances used, stored or generated in the practice been identified?
• Is there a current substance inventory?
• Are current safety data sheets available where required?
• Has each relevant substance or activity been assessed?
• Do the assessments reflect how the work is actually performed?
• Have all possible routes of exposure been considered?
• Have employees, patients, contractors and other people who could be exposed been considered?
• Has the practice considered eliminating or substituting hazardous products?
• Are control measures suitable for the level of risk?
• Is the specified PPE appropriate for the substance?
• Are products stored securely, correctly labelled and separated where necessary?
• Are spill, exposure and first-aid procedures clear?
• Do staff know how to access the assessments and safety information?
• Have staff received appropriate information, instruction and training?
• Is staff understanding or competence checked?
• Are control measures monitored to confirm that they work?
• Are assessments reviewed when products or procedures change?
• Are review dates and resulting actions recorded?
• Do written procedures match what happens in practice?

Any “no” answer should prompt further investigation and, where necessary, a documented action.

Final Takeaway

COSHH compliance in a dental practice is not measured by how big the COSHH folder is.

It is demonstrated through suitable assessments, effective controls, informed staff and working practices that consistently protect people from exposure.

Safety data sheets remain an important source of information, but they are only one part of the system. Every assessment must connect the product or hazardous substance to the task, the people who may be exposed and the controls used in that particular practice.

CQC Dental Mythbuster 41 provides a timely reminder that a compliant COSHH system must work beyond the paperwork. Practices should be able to show not only that risks have been documented, but that the controls are understood, implemented, monitored and reviewed.