Mould Check

COMPLIANCE GUIDE

COSHH for Housing Providers

Complete guide to Control of Substances Hazardous to Health regulations for social housing, mould remediation, and Awaab's Law compliance.
AWAAB'S LAW
10 Working days
To investigate a damp and mould hazard
EMERGENCY
24 Hours
To make an emergency hazard safe
IN FORCE
Oct 2025
Awaab's Law live

Understanding COSHH

COSHH (Control of Substances Hazardous to Health Regulations 2002) is the UK framework that requires employers to assess the risk from hazardous substances and prevent or adequately control exposure.

In housing associations and local authority housing, it's especially relevant because so much frontline work happens inside occupied homes, with vulnerable residents nearby and a high volume of "everyday" chemicals and dusty tasks.

Key Point People Miss

COSHH is not just "chemicals with hazard symbols." It also covers dusts, fumes, mists, vapours and biological agents (germs), which is directly relevant to damp/mould environments and some repair tasks.

The Social Housing Context

From 27 October 2025, Awaab's Law (phase 1) applies in England's social rented sector, requiring fixed timeframes for damp and mould hazards that present a significant risk of harm, alongside emergency hazards.

This tends to drive a higher volume of "make safe" actions (often including mould washes) at pace, which increases the importance of having standardised COSHH assessments and method statements ready to deploy.

Government Damp and Mould Guidance Stresses:

  • Treat damp/mould as a serious health risk
  • Don't wait for medical evidence
  • Address underlying causes, not only visible mould

Source: Understanding and addressing the health risks of damp and mould in the home

What Counts as COSHH-Relevant?

In housing association operations

Chemicals & Products

(Obvious COSHH)

  • Mould washes / biocides / bleach-based cleaners
  • Descalers, disinfectants, detergents
  • Paints, varnishes, sealants, adhesives, foams
  • Solvents, degreasers, fuels
  • Pesticides / herbicides for grounds and pest control

Generated Substances

(Often Forgotten)

  • Silica dust from drilling/cutting masonry/tiles
  • Wood dust from joinery repairs
  • Spray mists from atomised cleaning products
  • Fumes from hot works or some solvent products

HSE explicitly flags that harmful substances can be produced by processes.

Biological Agents

(Relevant to Damp/Mould)

COSHH includes biological agents, and HSE guidance on harmful micro-organisms highlights exposure to fungi among other risks.

Controls include:

  • Hygiene/washing protocols
  • Appropriate work clothing
  • Training
  • Task-based risk assessment

Core COSHH Duties

Legal requirements that matter most in housing operations
  1. 01

    Risk Assessment

    Regulation 6

    You must assess the risk to health from work involving hazardous substances before the work (and keep it under review).

    HSE's Practical Approach:

    • Identify hazards (labels + Safety Data Sheets, and anything generated by the task)
    • Assess risks (who's exposed, route of exposure, duration, frequency, others nearby)
    • Control the risks (eliminate/substitute first; then engineering/administrative controls; then PPE)
    • Inform/train, and review regularly
  2. 02

    Prevention or Control

    Regulation 7

    Exposure must be prevented, or if not reasonably practicable, adequately controlled.

    HSE's Practical Approach:

    • Substitution is a core idea in practice
    • Follow the control hierarchy
    • Document your control measures
    • Ensure adequate control, not just "below limits"
  3. 03

    Use & Maintain Controls

    Regulation 8 & 9

    If you specify controls (equipment, ventilation, PPE, safe systems), you must ensure they're actually used, maintained, and examined as required.

    HSE's Practical Approach:

    • Engineering controls must be maintained
    • RPE must be inspected and tested
    • Keep maintenance records
    • Ensure supervision of control use
  4. 04

    Monitor Exposure

    Regulation 10

    Ensure exposure is monitored using a suitable procedure where appropriate.

    HSE's Practical Approach:

    • Consider when conditions vary (tiny bathrooms, poor ventilation)
    • Monitor when controls are hard to verify
    • Use for significant airborne exposure tasks
    • Act on symptoms/complaints/near misses
  5. 05

    Health Surveillance

    Regulation 11

    Not general health screening. Required when there's a known disease associated with the substance, it's possible to detect early change, and workplace conditions make it likely the disease could occur.

    HSE's Practical Approach:

    • Focus on asthma, dermatitis, specific diseases
    • Results must be interpreted and acted upon
    • May require worker redeployment
    • Keep records (up to 40 years for some cases)
  6. 06

    Information & Training

    Regulation 12

    Provide appropriate information, instruction and training for people who may be exposed.

    HSE's Practical Approach:

    • Link training to approved products and tasks
    • Short, repeatable "what good looks like" steps
    • Ensure contractors and agency staff are included
    • Document all training delivery
  7. 07

    Emergency Plans

    Regulation 13

    Arrangements to deal with accidents, incidents and emergencies involving hazardous substances.

    HSE's Practical Approach:

    • Plan for splashes to eyes/skin
    • Prepare for accidental mixing reactions
    • Know how to handle spills in vans/communal areas
    • Have protocols for resident exposure complaints

The "Occupied Home" Issue

COSHH plus residents in the work area

COSHH is mainly framed around workers, but housing associations also have a legal duty under Section 3 of the Health and Safety at Work etc. Act 1974 to conduct their undertaking so as to ensure people not in their employment (tenants, visitors) aren't exposed to risks.

That's especially relevant when you're using chemicals or creating dust/mists in a resident's kitchen/bathroom/bedroom.

Your COSHH Thinking Must Include:

  • Bystander exposure (resident/children)
  • Vulnerability (pregnancy, infants, older people, asthma/COPD, immunocompromised)
  • Re-occupation and ventilation (how you ensure the space is safe after the task)

Consider in Your Assessments:

  • Who is present during work
  • Where residents go during application
  • How long they must stay away
  • How you communicate safety measures

COSHH for Mould Remediation

What a good approach looks like

Biological Exposure

Spores/allergens/irritants when disturbing mould

  • Who is exposed (operative + resident)
  • Route of exposure (inhalation, contact)
  • Controls to minimize disturbance

Chemical Exposure

Whatever wash/biocide/disinfectant you apply

  • Review Safety Data Sheets
  • Identify hazards from product and application method
  • Control vapours, mists, and resident exposure

Control Hierarchy in Practice

What assessors expect to see in your COSHH approach:

  1. 1

    Eliminate / Substitute

    "Can you avoid high-hazard chemistry or spraying? Can you use a less hazardous process/product?"

    Use COSHH-free products where possibleWipe instead of sprayChoose pH-neutral over corrosive
  2. 2

    Engineering Controls

    "Can you control the hazard at source?"

    Local ventilationKeep area well ventilatedMechanical extractionEnclosed systems
  3. 3

    Administrative / Safe System

    "How do you organize the work safely?"

    Isolate the areaMinimize time in roomAvoid creating aerosolsKeep residents awayClear instructionsCleaning sequence
  4. 4

    Personal Protective Equipment

    "What PPE is needed based on SDS and task?"

    Gloves/eye protection/apronsRPE based on vapours/gases vs particulatesTask-appropriate selectionFit testing where required

Bleach / Hypochlorite Warning

If bleach-type products are in scope, a known practical risk is dangerous gas release if mixed with acidic products. This is exactly the kind of "real world" hazard COSHH assessments in housing need to anticipate (e.g, residents may already have other cleaners in the room).

Source: Sodium hypochlorite: general information (Gov.UK)

Common Failure Points

In social housing mould jobs (and how to avoid them)
FAILURE POINTHOW TO AVOID
Treating COSHH as "file the SDS"
Create task-based assessments (spraying vs wiping, occupancy, ventilation, bystanders)
Too many products in vans/depots
Maintain approved products register with consistent controls
No explicit resident controls
Document who is present, where they go, how long, and communication protocols
Over-reliance on PPE
Prioritize substitution/process changes that reduce risk more reliably
"Clean only" responses
Address underlying damp causes (flagged heavily in government damp/mould guidance)

What "Good" Documentation Looks Like

Housing-association-ready COSHH pack

COSHH Register

Approved products only with current SDS

Task-Based Assessments

E.g, "bathroom spot mould wash", "void deep clean", "post-leak decontamination"

Method Statements

Standard procedures tied to assessments

Resident Safety Addendum

How you control bystander exposure, ventilation, re-entry

Training Records

Including dermatitis/hand care and chemical handling

Incident Plan

Splashes/spills/resident exposure events

The COSHH-Free Alternative

Product Selection

Traditional products with bleach or quaternary ammonium compounds require full COSHH assessments. COSHH-free alternatives eliminate documentation burden and speed up response times.

Occupied Properties

Social housing work happens with residents present. Products requiring evacuation delay Awaab's Law compliance and significantly increase costs.

Faster Response

Meet Awaab's Law timeframes without waiting for COSHH assessments, method statements, or evacuation arrangements.

SOLUTION

Mould Check

  • No risk assessments needed
  • No tenant evacuation required
  • Faster Awaab's Law compliance
  • Reduced operational costs
  • 80× more effective than bleach
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Official Resources

HSE and Government guidance for full compliance

Need a COSHH-Free Solution?

Mould Check is the UK's only COSHH-free mould remover. Eliminate compliance barriers, speed up response times, and meet Awaab's Law requirements without documentation delays.

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