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APP_26 — COSHH Assessment Audit Register

Document Information

Field Value
Document Reference APP_26
Issue Number 1
Issue Date 15 September 2026
Next Review 15 September 2027
Controlled By Sean Ashton (HSQE Consultant)
Approved By Aaron Mason, Director

Download the register

Download APPL_26 (.xlsx)

Related: APP_09 COSHH Register · APP_10 Legal Register L7 · SOP 8.5 COSHH

1. Why this register exists

APP_09 indexes thirty-one COSHH assessments. Every one is on the same template, carries the H and P codes, names the PPE, and records frequency and duration of exposure against Regulation 6.

None of that tells anyone whether the controls are actually being used.

COSHH Regulation 9 requires control measures to be maintained in efficient working order and good repair, and Regulation 12 requires that people using the substance have been informed, instructed and trained. Those are ongoing duties about what happens in the yard and on site, not about what the assessment says. An assessment can be word-perfect while the eye-wash by the chlorine store is out of date, the gloves specified are not the gloves stocked, and nobody has read it.

This register is the check. APP_09 says what the assessment requires; APP_26 records what was found when someone went and looked.

Why indexing the assessments is not the same as checking them

They pick one, walk to where the substance is kept, and compare. That takes four minutes. This register records AMWS making the same check first.

2. How the audit works

A COSHH assessment audit is a physical check against the assessment, not a desk review. It takes about ten minutes per substance.

# Check What "pass" looks like
1 The substance is where the assessment says it is Found at the stated location, in the stated container
2 Quantity is roughly as assessed A COSHH assessment for a 5-litre container does not cover a 200-litre drum
3 Labelling is intact and legible Original supplier label, GHS pictograms readable, no decanting into unlabelled containers
4 The safety data sheet is accessible On the portal, and reachable by whoever uses the substance
5 PPE specified is present and serviceable The gloves, goggles or RPE the assessment names — the actual ones, not a substitute
6 Engineering and emergency controls work Ventilation, bunding, spill kit, eye wash — present, in date, unobstructed
7 Storage matches the assessment Segregation, fire separation, bunding, locked where required
8 Users can describe the main hazard and the main control Asked, not assumed. If they cannot, Regulation 12 is not met regardless of what the training record says
9 Disposal route is as assessed Waste stream correct, hazardous consignment where required
10 Assessment is current and matches the product actually held Same product, same supplier, same concentration. Products get substituted quietly

Any check that fails is recorded with a finding and an action.

Scoring

Meaning Action
🟢 Compliant All applicable checks pass Record and move on
🟡 Minor finding Controls in place, something needs correcting — a label, a date, a missing SDS copy Fix within 30 days, recorded here
🔴 Major finding A control the assessment relies on is absent or not working Stop using the substance until corrected. Raise in APP_21
⬛ Not audited Not yet checked this cycle —

3. Audit frequency

Auditing all thirty every year would not be achievable, so the frequency is set by hazard group.

Group Frequency Why
High hazard — H314, H304, H350, H340 carriers, and anything van-carried Every 6 months Severe consequence, in daily use, carried to site
Medium hazard — Warning signal word, or stored in bulk Annually
Low hazard — welfare and office products, non-classified Every 2 years, or on change Proportionate. Air freshener does not need a six-monthly audit
Any substance On trigger New product, changed supplier, spill, near miss, or a change in how it is used

4. The audit register

Empty at issue. The register is created before the first audit rather than written up afterwards.

# COSHH ref Substance Hazard group Audited by Date Result Findings Actions raised Next due
⬛

First cycle — the priority order

The first audits go to the substances where a control failure would matter most.

Priority COSHH refs Substance Why first
1 COSHH_04, COSHH_10 Chlorinated spray · Traffic film remover Both H314 — cause severe skin burns and eye damage. Check the eye wash is in date and reachable
2 COSHH_07 Chlorine disinfection tablets Used on live commissioning work; releases chlorine gas in contact with water
3 COSHH_23, COSHH_24 Petrol · Diesel Petrol carries benzene, a Category 1A carcinogen, and both are held at the yard. Check the storage against the Oil Storage Regulations question open at APP_06 Ref 10
4 COSHH_25–30 The six cabinet substances Assessments issued and each carries its safety data sheet. Four reach the sheet by supplier link rather than a copy held locally — owner Leanne Mason, target 31/10/2026. Auditing them will also confirm what is actually in the cabinet and in what quantity
5 Remainder Van-carried products The thirteen synchronised to the Van Packs portal — audited against an actual van, not the register

Owner: Sean Ashton with Jason May. First cycle: the five priority-1 and 2 substances by 31/10/2026, then the remainder through the 2027 programme.

This register will be empty at the October audit

APP_26 is issued on 15/09/2026 and the first audits are scheduled for after the surveillance visit, so the register currently holds no completed audits.

The response is: "We index thirty assessments in APP_09. In September we recognised that indexing them is not the same as verifying the controls are in place, so we created the audit register and scheduled the first cycle against the highest-hazard substances. It is empty because we have not done the first one yet."

Creating the mechanism and dating the first cycle is a Clause 9.1.1 answer. Claiming audits that have not happened is a major non-conformity. If there is time before 6 October, auditing the two priority-1 substances would put entries in the register. It is about two hours' work.

5. What findings feed

Finding type Where it goes
Minor finding Recorded here, closed within 30 days
Major finding APP_21 as an NCR, substance withdrawn until corrected
Assessment out of date or wrong product APP_09 — assessment reissued
PPE not available or not as specified RA_HO_15 and the PPE issue register action
User could not describe hazard or control APP_12 — Regulation 12 training gap
Storage or spill control inadequate APP_06 Ref 3 and Ref 10

6. Responsibilities

Who What
Sean Ashton (HSQE Consultant) Maintains this register, runs the audits, reports results to the Management Review
Jason May (Site Supervisor) Attends the audits, corrects minor findings on the spot, withdraws substances on a major finding
Leanne Mason (Director) Procurement — ensures the product held matches the product assessed, and that specified PPE is stocked
Aaron Mason (Director) Resources for corrections; reviews major findings

Supporting standard

Supporting standard

Audits follow the approach in ISO 19011 for auditing management systems, scaled to a substance-level physical verification. Referenced undated so a new edition does not force a re-issue. The editions held are listed in APP_02 Section 3.

Audit trail

Issue Date Approved By Summary
1 15/09/2026 Aaron Mason, Director Initial issue. APP_09 indexed thirty COSHH assessments at the time of this issue but held no record of the controls being verified in use, which is what COSHH Regulations 9 and 12 actually require. This register is the verification layer: a ten-point physical check against the assessment, a three-level result, a risk-based frequency, and a routing table for findings. Issued empty with the first cycle scheduled — the two H314 substances by 31/10/2026 — rather than written up retrospectively.

This document forms part of A M Water Services Limited's Integrated Management System. Paper copies are uncontrolled when printed.