COSHH in Pest Control: Risk Assessments for Rodenticides, Insecticides and Biocides, PPE and Storage

Summary

COSHH — the Control of Substances Hazardous to Health Regulations 2002 — is the central piece of health and safety legislation governing how pest controllers handle, apply, and store hazardous chemicals. It applies to every substance that could cause harm: rodenticides, insecticides, acaricides (for mites), fumigants, disinfectants, and tracking dusts. In pest control, almost every product used is a hazardous substance within the meaning of the Regulations.

The Regulations do not prohibit the use of these substances — they require that the risk be assessed, controlled, and documented. For pest controllers, this means producing written COSHH risk assessments before any treatment, providing appropriate PPE to operatives, and maintaining records that can be audited by the Health and Safety Executive (HSE) or, in food and healthcare environments, by Environmental Health Officers. A pest controller who cannot produce a COSHH risk assessment for a product they just applied is in breach of the law, regardless of how safe they believe the product to be.

A common misconception is that COSHH assessments are a one-time administrative exercise. In practice, they must be reviewed whenever the product, the method of application, the site conditions, or the workforce changes. The hierarchy of controls — elimination, substitution, engineering controls, administrative controls, PPE — must be applied in order. PPE is the last line of defence, not the first.

Key Facts

• COSHH Regulations 2002 — SI 2002/2677; the primary legislation; applies to all employers and self-employed persons using hazardous substances at work
• Hazardous substance — defined broadly; includes any substance with a workplace exposure limit (WEL), any biological agent, and any substance that creates a comparable hazard; all common pesticides qualify
• Written risk assessment — required under Regulation 6; must be suitable and sufficient; site-specific and product-specific
• Safety Data Sheet (SDS) — formerly MSDS; manufacturers must provide SDS for every hazardous product; the SDS is the starting point for a COSHH assessment, not a substitute for one
• Workplace Exposure Limit (WEL) — set by HSE in EH40; pest control products with inhalation risks have WELs that must be respected; relevant for fumigation and enclosed-space treatments
• Hierarchy of controls — elimination → substitution → engineering controls (e.g. enclosed bait stations) → administrative controls (e.g. restricting access) → PPE; must be applied in this order
• PPE — personal protective equipment; must be suitable for the substance; nitrile gloves for most rodenticides; respirator for dust or spray treatments; eye protection where splash risk exists
• Rodenticides — typically anticoagulant compounds (brodifacoum, bromadiolone, difenacoum, difethialone, chlorophacinone); classified as toxic; require specific PPE and disposal procedures
• Insecticides — include synthetic pyrethroids (permethrin, cypermethrin, deltamethrin), organophosphates (now rarely used in the UK), and neonicotinoids; hazard profile varies
• Biocides — disinfectants and surface treatments used alongside pest control; regulated separately under UK BPR but still subject to COSHH for worker protection
• Storage requirements — pesticides must be stored in a secure, locked, bunded area; temperature limits apply to many formulations; incompatible chemicals must be segregated
• Health surveillance — required where there is a risk of occupational disease; relevant for operatives with prolonged exposure to specific substances
• Emergency procedures — must be documented in the COSHH assessment; includes first aid measures, spill procedures, and notification requirements
• Record retention — COSHH assessments and monitoring records must be retained for at least 5 years; 40 years for substances that cause long-term health effects

Quick Reference Table

Detailed Guidance

Producing a Suitable and Sufficient COSHH Risk Assessment

Regulation 6 of COSHH requires employers to make a "suitable and sufficient" assessment of the risks created by hazardous substances in the workplace. In pest control, this means producing an assessment before starting work on any site where hazardous substances will be used. Generic template assessments are not sufficient on their own — they must be tailored to the specific site, the specific product, the specific application method, and the specific workforce.

A suitable COSHH assessment for a pest control treatment typically includes:

1. Description of the activity — what is being treated, where, how, for how long
2. Substances involved — product name, active ingredient, concentration, form (liquid, bait block, dust, gel)
3. Hazard identification — taken from the Safety Data Sheet; inhalation, skin contact, ingestion, environmental hazards
4. Who could be harmed — the operative, other workers in the area, building occupants, the public
5. Control measures in place — substitution considered and why retained; engineering controls (enclosed bait stations); access restriction; timing (out of hours application)
6. PPE specified — type, standard, when to wear it, how to store and dispose of it
7. Emergency procedures — spill procedure, first aid, poison control contact (National Poisons Information Service: 0344 892 0111)
8. Review date and responsible person

The Safety Data Sheet (SDS) provided by the product manufacturer is the starting point for identifying hazards. Section 8 of the SDS specifies exposure controls and PPE. However, the SDS covers all possible uses of a product; the COSHH assessment must focus on the specific use being made at this site.

PPE Selection for Pest Control

PPE must be appropriate to the specific hazard. In pest control, the most common PPE requirements are:

Gloves: Nitrile disposable gloves (minimum 0.2mm thickness) are suitable for handling most rodenticide bait blocks and insecticide concentrates. For fumigants and products with significant dermal absorption risk, thicker chemical-resistant nitrile or butyl rubber gloves are required. Latex gloves are not recommended due to allergy risks and poor chemical resistance with some solvents.

Respiratory protection: For spray applications in enclosed spaces, a half-face respirator with appropriate filter cartridges (typically P3 for particulates, ABEK for organic vapour and inorganic gas) is required. FFP2 or FFP3 dust masks are suitable for handling tracking dusts. Fumigation with aluminium phosphide requires supplied air or SCBA — this is a specialist activity restricted to trained operatives.

Eye protection: Safety spectacles or chemical splash goggles should be worn when mixing concentrates or when there is any spray splash risk. Side-shields are the minimum; goggles are preferred for mixing operations.

Protective clothing: Coveralls or a separate work garment prevents contamination of personal clothing. For treatment of heavily infested properties with cockroach or bed bug problems, disposable Tyvek suits reduce the risk of transporting live insects between sites.

PPE must be properly maintained, stored, and replaced when damaged or expired. Filter cartridges for respirators have a limited service life once opened; this should be recorded.

Storage of Pesticides and Biocides

UK legislation and the BPCA/British Agrochemicals Standards Inspection Scheme (BASIS) guidance specify requirements for pesticide storage. The key requirements are:

• Security: All pesticides must be stored in a locked store inaccessible to unauthorised persons, children, and non-target animals
• Bunding: The store must be capable of containing 110% of the largest single container in case of spillage
• Segregation: Incompatible chemicals (e.g. oxidising agents and flammables) must not be stored together; follow SDS Section 7
• Labelling: All containers must be clearly labelled; never transfer pesticides to unmarked containers
• Temperature control: Many formulations (especially emulsifiable concentrates and some gel baits) have temperature storage limits; exceeding these can cause degradation or increased vapour pressure
• Ventilation: Pesticide stores should be ventilated to prevent vapour build-up
• Records: A stock register should record what is held, quantities, and batch numbers

Vehicle storage also applies when pest controllers transport products in vans. Products must be secured against spillage in transit, and a spill kit should be carried. ADR (the European Agreement Concerning the International Carriage of Dangerous Goods by Road, as retained in UK law) may apply for larger quantities.

Environmental Controls and Disposal

Pest control products — particularly rodenticides — are classified as dangerous to the environment. Brodifacoum and other second-generation anticoagulants are extremely hazardous to birds of prey, owls, and mustelids (stoats, weasels) through secondary poisoning. COSHH risk assessments must consider the environmental exposure pathway, not just human health.

Empty containers must not be rinsed down the drain or placed in general waste. They should be triple-rinsed (if liquid) and disposed of as hazardous waste through a licensed carrier. Dead rodents recovered from bait stations should similarly be disposed of as hazardous waste — not in general refuse — due to rodenticide residues.

Unused or out-of-date pesticides must be disposed of through a registered waste contractor. Pouring down the drain or burying on site is an offence under the Environmental Protection Act 1990 and Water Resources Act 1991.

Health Surveillance

COSHH Regulation 11 requires health surveillance where operatives are exposed to substances associated with specific occupational diseases. In pest control, the most relevant example is organophosphate exposure — operatives who regularly use organophosphate insecticides should have baseline and periodic cholinesterase monitoring. Given the significant withdrawal of organophosphate products from UK use in recent years, this is less common in routine urban pest control, but it remains relevant for certain agricultural and stored-product pest applications.

More generally, any operative experiencing symptoms — skin irritation, respiratory sensitisation, neurological effects — after repeated pesticide exposure should be referred for occupational health assessment. COSHH assessment reviews should be triggered by any such incident.

Frequently Asked Questions

Does COSHH apply to self-employed pest controllers as well as companies?

Yes. COSHH Regulations 2002 apply to all persons who carry on an undertaking — including sole traders and self-employed operatives. A self-employed pest controller working alone must still produce written COSHH risk assessments for the products they use and maintain records of assessments and any health monitoring.

Is a Safety Data Sheet the same as a COSHH assessment?

No. An SDS is provided by the product manufacturer and describes the general hazards and safe handling of a substance. A COSHH assessment is produced by the employer and applies the information in the SDS to the specific work activity, site, and workforce. The SDS is an input to the COSHH assessment, not a substitute for it.

How long must COSHH assessment records be kept?

The general rule is 5 years. However, for substances known to cause long-latency diseases (cancers, chronic lung disease), records must be kept for 40 years. Given that some pesticide active substances are subject to ongoing review of their carcinogenicity, erring on the side of longer retention is advisable.

What should be included in a spill procedure for rodenticide products?

The spill procedure should specify: evacuate the immediate area; prevent entry of the product into drains or watercourses by bunding with sand or absorbent material; wear full PPE before approaching the spill; collect spillage into a sealable container for disposal as hazardous waste; clean the area with detergent and water; and notify the local Environment Agency if a watercourse is at risk. The National Poisons Information Service (0344 892 0111) should be called if any person has been exposed.

Can pest control COSHH assessments be generic templates?

Generic templates can be a starting point but must be adapted for each specific site and treatment. A suitable and sufficient assessment under Regulation 6 is one that is specific to the activity being carried out. An HSE inspector would expect to see that the assessment reflects the actual conditions — the specific product used, the site layout, the number of people at risk, and the control measures in place at that site.

Regulations & Standards

• Control of Substances Hazardous to Health Regulations 2002 (SI 2002/2677) — primary legislation; requires risk assessment, control measures, PPE, health surveillance, and record-keeping for all hazardous substance use

• EH40/2005 Workplace Exposure Limits — HSE document setting WELs for hazardous substances including some pesticide active ingredients; updated periodically

• UK Biocidal Products Regulation (UK BPR) — governs approval and labelling of biocidal products; SDS requirements flow from this

• Environmental Protection Act 1990 — prohibits unlicensed disposal of controlled waste including pesticide containers and dead rodents with rodenticide residues

• Water Resources Act 1991 — prohibits entry of pollutants including pesticides into controlled waters

• Health and Safety at Work etc. Act 1974 (Section 2 and 3) — overarching duty on employers to protect employees and non-employees from risks arising from work activities

• Personal Protective Equipment at Work Regulations 1992 (as amended 2022) — requires employers to assess PPE needs, provide suitable PPE, and ensure it is used and maintained

• HSE COSHH — A Brief Guide to the Regulations — plain-English HSE guidance on COSHH compliance

• HSE Pesticides — COSHH and Pesticides — specific guidance for pesticide users

• EH40/2005 Workplace Exposure Limits — HSE publication; current WEL values

• BPCA Technical Resources — COSHH guidance, risk assessment templates, and SDS guidance for pest control

• HSE — Storage of Pesticides — storage requirements for pesticide products

• National Poisons Information Service — emergency resource for poisoning incidents; 0344 892 0111

• bpca membership certification — competency and trade body requirements for pest controllers

• rodent control rats and mice — rodenticide application, tamper-resistant boxes, and legal requirements

• insect pest control — insecticide products and application methods

• bird pest control — biocidal gel applications and environmental considerations