Hazardous Chemicals

COSHH training

From superficial compliance to safe behavior

10 minutes01/31/2024

writen by Stefan Ganzke

Recently, within a mid-sized company in the chemical industry, About 50 employees are seated in a large training room, being instructed on how to handle hazardous chemicals. As with each of these quarterly meetings, this session is scheduled for four hours. The instructions are conducted by the production management using operating instructions. These are partly read out loud and partly supplemented by PowerPoint slides projected onto the wall. After 60 minutes, the participants' thoughts begin to drift.

The Control of Substances Hazardous to Health Regulations (COSHH) represents a statutory instrument in the United Kingdom. It underscores the obligations employers have to safeguard their workforce, as well as others, from the dangers associated with substances utilized in the workplace. According to Regulation 12, it is mandatory for all workers who may come into contact with hazardous chemicals to receive adequate and appropriate information, guidance, and training.

This article will explain whether this obligation is sufficiently met in the above example, and what more suitable alternative methods exist to ensure the safety of employees in handling substances hazardous to health.

Scientific exploration of the potential effectiveness of COSHH training

As diverse as companies themselves, so too are their approaches to the manner and method of COSHH training. In some businesses, it is standard practice for managers to simply hand out operating instructions to the employees for reading. In others, lengthy, monologue-like instructions are conducted in crowded meeting rooms. What do these two methods have in common? Firstly, they are not legally compliant. Additionally, they are also not effective. The learning matter is often inadequately absorbed, and safe working in practice is not ensured. The reasons for this will be explained below based on a scientific basis.

Retention curve by Hermann Ebbinghaus

According to the retention curve by Hermann Ebbinghaus, different probabilities of retention arise depending on the methodological approach:

If managers simply read the operating instructions to the employees, the retention probability is 20 percent. If the employees read the operating instructions themselves, the probability rises to 30 percent. COSHH training combined with PowerPoint presentations integrate visual and auditory impressions and increase the retention rate to up to 45 percent. However, this result is still far below a desirable knowledge base. By adding repetitions to the visual and auditory presentation, the probability of retention can be increased to 70 percent. With the interactive participation of employees, the retention rate can even be increased to 92 percent.

Forgetting curve by Hermann Ebbinghaus

Another reason that points towards the ineffectiveness of annual, lengthy meetings for providing instruction is the limitation posed by our limbic system. It has the capability to sustain one's attention for only a specific duration. In general, most people can focus effectively for a span of up to 55 minutes, which explains why attendees often tend to mentally drift off during lengthy training sessions. This phenomenon was described by Hermann Ebbinghaus in his forgetting curve:

By considering both the forgetting and retention curves, it becomes evident that lengthier instructions facilitated via PowerPoint typically result in a retention probability of less than 45% for the material taught. This level of retention is far from satisfactory when acknowledging the vital importance of this knowledge in ensuring the safe handling of hazardous chemicals.

Finding fresh approaches that ensure the long-term recall of COSHH training

Multi-hour, PowerPoint-supported COSHH trainings essentially meet legal requirements in instruction practice if they contain comprehensive and understandable information, are adapted to reflect the nature of the work and potential exposure as identified through risk assessment, are delivered in a suitable form considering the unique features of the workplace, and importantly, are conducted prior to the commencement of work involving hazardous chemicals.

However, the effectiveness of these training methods comes into question when we consider scientific research on the probability of retention (the retention curve). Traditional, lengthy PowerPoint-supported sessions may not be the most conducive to learning retention or efficient information absorption, particularly over extended periods (the forgetting curve). When the goal is to sensitize individuals to the potential dangers of hazardous chemicals and inspire safer practices, we may need to review our approach. As is often the case, there isn't a one-size-fits-all solution. A variety of instructional methods should be considered to find the optimal fit for both the content and the audience, aligning with the unique requirements of the parties involved.

Safety briefings

Consider conducting regular safety briefings as a possibility, with focus on discussions about the risks and protective measures for specific hazardous chemicals, such as oxygen, or categories of hazardous chemicals, like corrosive materials. It's important to keep these sessions brief to avoid overwhelming attendees with information, which could accelerate the forgetting process. Following the principles of the retention curve, it becomes evident that simply reinstating discussions about handling hazardous chemicals can likely bolster information retention to approximately 70 percent.

Further enhancing the effectiveness of these briefings, the retention rate can skyrocket to almost 95 percent when interactive elements, such as engaging the employees with questions, are incorporated. This method fosters critical thinking, ensuring the highest likelihood of key information being processed effectively and retained longer.

While the COSHH regulations do not explicitly mandate documentation of such training sessions, keeping thorough records of these safety briefings is highly advisable. Regarded as a best practice in health and safety regulation compliance, documentation serves to demonstrate that businesses have fulfilled their obligations by educating their employees about potential hazards and the corresponding measures to reduce risk.

You can organize safety briefings following this template:

Template for safety briefings on substances hazardous to health

  • What is the subject of the conversation

    Example: Specific identification of the hazardous chemical or the group of hazardous chemicals

  • What should be achieved when working with the hazardous chemical or the group of hazardous chemicals?

    Example: Specify health hazards, environmental hazards, etc.

  • What are the dangers associated with the substance?

    Example: Concrete dangers based on the COSHH risk assessment, safety data sheet and operation instruction.

  • How can the hazards in the workplace be avoided?

    Example: Discussing protection measures according to own practice, cross-check with the protective measures from risk assessment, safety data sheet, operation instruction.

  • Determinations

    Example: Derivation of to-dos (e.g., necessary labelling of substances, containers, requirements, changes in personal protective equipment, etc.), possibly to be added in the annual plan or topic storage.

Hold sessions in small groups, preferably between 6-10 participants.

  • Center discussions around a topic relevant to all group members. Ideally, allow the group to choose this focus themselves.
  • Entrust the moderation of the conversation to someone qualified in the area, such as a safety specialist, safety manager, or a supervisor.
  • Ensure regularity in conducting these sessions, whether monthly, quarterly, or semi-annually.
  • Restrict safety briefings to a manageable timeframe, ideally no more than 30 minutes.
  • Make sure the briefings are relevant to the participants' workplace scenario.
  • Maintain a record of each session, whether through the use of purpose-built forms or a specialized EHSQ software solution.

Small group work

Small group work sessions offer a valuable approach to communicating and reinforcing knowledge about substances hazardous to health. Like safety briefings, these focused sessions should be regularly held while only requiring a manageable 10 to 15 minutes of employees' time.

Managers can assemble one or more small groups based on the number of team members. A thought-provoking question, such as identifying the risks of certain hazardous chemicals and outlining the proper precautions for handling them, could serve as the discussion's catalyst. The primary objective here is to encourage employees to think independently, prompting them to become active participants in conversations about safety. Upon completion of these sessions, it's crucial that the participants present and document their key points on a flipchart or whiteboard.


Photographing the contents of the flipchart or whiteboard can ensure compliance with legal documentation requirements. It's essential to receive confirmation from each participating employee, indicating both their attendance and comprehension of the content discussed.

Change management: Redefining your COSHH training culture

Any changes or restructuring of your approach to COSHH training should always involve cross-functional collaboration. This includes management, operational leaders, and representatives responsible for safety and hazardous chemical management. Inclusion of the works council, where available, can also add value to the process. As a key measure, establishing a dedicated committee tasked solely with the reform of COSHH training is advisable.

This committee's initial responsibility is to evaluate the current training framework. Once the committee has gained a comprehensive understanding of the current situation, the process of restructuring can commence. This stage involves determining which elements of the COSHH training could be best addressed using safety briefings, small group work sessions or other methodological variations. Simultaneously, constructing an appropriate organizational structure is necessary. This might include adjustments to shift times, further qualification of moderators, or standardizing certain processes.

As the committee proceeds with these initiatives, it's vital to remember that final decisions on the future of COSHH training cannot solely rest upon them. Therefore, sharing developments and proposed changes with the occupational safety and health committee or a relevant steering group, if available, is a must.


As per Control of Substances Hazardous to Health (COSHH) regulations, companies are legally required to equip their employees with the necessary knowledge for the safe handling of hazardous chemicals they encounter in their work. However, traditional methods such as long, multi-hour meetings often result in scant information absorption and minimal advancement in knowledge.

Informed by Ebbinghaus's retention and forgetting curves, it becomes evident that conventional training methodologies fall short in adequately sensitizing employees to the safe handling of hazardous chemicals, and in fostering sufficient risk competency. These insights underscore the urgent need to deviate from tradition, embracing new strategies such as safety briefings or small group work, which are designed to enhance retention and combat forgetting.

Companies aiming to implement these more effective training methods should establish a specialized committee focusing on systematic change management. Incorporating representatives from a diverse array of operational functions is key when introducing these novel methodologies. This holistic approach ensures the initiative receives the necessary authority and acceptance and is thoroughly thought-out and planned from the outset. Before implementation can begin, management, leaders, and moderators need to undergo adequate training to ensure focused and successful deployment.

Stefan Ganzke is an expert in safety culture and communication on the topic of occupational safety. As Managing Partner of WandelWerker Consulting GmbH, he primarily helps safety engineers and occupational safety professionals to achieve lasting reductions in workplace accidents.

About the author


1  Will M, Brauweiler J (2020) Business Continuity Planning. In: Leal Filho W, Marisa Azul A, Brandli L, et al. (eds) Sustainable Cities and Communities. Springer International Publishing, Cham, pp 33–44
2  Will M, Brauweiler J (2020) Business Continuity Planning. In: Leal Filho W, Marisa Azul A, Brandli L, et al. (eds) Sustainable Cities and Communities. Springer International Publishing, Cham, pp 33–44