Purpose and scope
“COSHH” is a United Kingdom term. In the UAE, use a standalone Hazardous Substances Control and Hazard Communication Programme that meets applicable federal, emirate, municipality, Civil Defence, free-zone and project requirements. It is an injury-and-illness prevention control programme, not an administrative SDS collection exercise.
The programme covers hazardous materials brought to, stored, decanted, used, generated or removed from a construction site, including any other material classified as presenting physical, health or environmental hazards:
- Paints, coatings, adhesives and sealants
- Solvents, fuels and compressed gases
- Curing compounds and concrete additives
- Cleaning agents and laboratory chemicals
- Welding consumables and grout
- Dust-generating materials and hazardous waste
Scope exclusion: this standalone programme does not cover fitness to work, occupational health screening or medical surveillance. Those are controlled separately under the project occupational-health procedure — see the injury and illness prevention briefing.
UAE and Abu Dhabi requirements
At federal level, MoHRE's OSH procedures require the employer's safety programme to identify activity risks and implement preventive and control measures. For hazardous substances, the procedures require competent-authority approval before storage or handling where applicable, accurate use, storage and trading records, safe storage in labelled containers, warning labels in Arabic and other languages understood by workers where necessary, and suitable measurement or monitoring with recorded results. [1]
In Abu Dhabi, ADOSH-SF (formerly OSHAD) CoP 1.0 applies to entities that import, store, transport, sell or use hazardous materials. It requires risk assessment, relevant permits and approvals, competent oversight, controls at source, routine inspection, approved disposal, emergency planning and worker training before work. The CoP also specifies current SDS access, compatible storage, inventories, labels and emergency arrangements. [2]
Authority check: comply with the stricter applicable requirement. Project permit conditions, developer standards, Civil Defence requirements and free-zone rules may add requirements for quantities, storage, transport, fire protection, notifications or waste disposal.
Standalone programme structure
1Leadership, roles and approval
Nominate a competent hazardous-substances coordinator; define responsibilities for procurement, site HSE, storekeeper, supervisors, subcontractors and waste contractors; prohibit unauthorised chemicals entering site.
2Pre-procurement review and substitution
Review the intended material before purchase. Eliminate or substitute higher-hazard products where reasonably practicable; verify the latest SDS, label, supplier and required authority approvals.
3Chemical inventory and SDS register
Keep an up-to-date inventory by product, manufacturer, quantity, store or work location, expiry date and SDS revision. Ensure current SDSs are accessible to workers and emergency responders in languages understood by the workforce. [2]
4Task and storage risk assessment
Assess use, handling, decanting, incompatibility, fire and explosion, exposure routes, spill pathways, waste and emergency scenarios. Link the approved assessment and controls to the MSRA and permit-to-work where relevant.
5Hazard communication
Maintain original supplier labels and label all secondary or decanted containers immediately. Show product identity, key hazard information, precautions and date/expiry where relevant. No unknown or unlabelled containers. Use signage suited to workforce literacy and language.
6Storage and segregation
Use approved stores, compatible containers, segregation controls, quantity limits, ventilation, secondary containment, security, access control, fire protection and clearly marked emergency equipment and escape routes.
7Safe use and exposure control
Apply the hierarchy of controls: eliminate, substitute, isolate or engineer, administer, then PPE. Control high-risk work such as flammable-liquid transfer, spraying, hot work near flammables, gas-cylinder use, welding fumes and silica-generating work.
8Training and supervision
Provide general awareness before work and task-specific instruction before handling. Cover SDS use, labels, hazards, PPE, storage, decanting, incompatibilities, waste, spill response and emergency actions in a language workers understand. [2]
9Spill, fire and release readiness
Establish chemical-specific emergency arrangements, spill kits, containment, waste containers, alarms and communications, and drills. Prevent releases to drainage, ground or storm-water systems.
10Waste, inspection and assurance
Identify and segregate hazardous waste, use approved disposal routes, inspect stores and work areas, replace damaged labels and expired or damaged products, investigate releases and track corrective actions to closure.
Key operational controls
| Control area | Site requirement | Evidence to retain |
|---|---|---|
| Entry to site | Approval before procurement or delivery; current SDS; product risk review; verify any authority approval, permit or quantity restriction. | Approved chemical request, SDS, delivery check, permit/approval copies. |
| Labelling and communication | Original labels retained; secondary containers labelled; workforce understands signs, labels, SDS precautions and emergency instructions. | Label inspection records, induction/training record, toolbox talk attendance. |
| Storage | Compatibility assessment; segregation; bunding or secondary containment; ventilation; controlled access; stock and expiry rotation; no food or drink in use or store areas. | Store layout, compatibility matrix, store inspection, inventory and expiry register. |
| Use and decanting | Approved MSRA, suitable tools and containers, ventilation and controls, required PPE, housekeeping and supervision. | MSRA, pre-task briefing, permit where applicable, supervisor inspection. |
| Transport and delivery | Approved vehicle and driver, and secure compatible packages where hazardous-material transport requirements apply; emergency information available. | Delivery records, transport documents or manifest, journey controls where required. |
| Spills and waste | Spill kit, response procedure, containment, appropriate waste containers, approved waste contractor and incident reporting. | Spill-kit inspection, drill record, waste consignment record, incident/CAPA record. |
Minimum registers and controlled records
| Register or document | Minimum fields / content |
|---|---|
| Hazardous substances inventory | Product name, manufacturer, intended use, hazard classification, work or store location, maximum and current quantity, expiry date, SDS revision date and approval status. |
| SDS register | Product, latest SDS issue or revision date, file link or location, languages available, verification date and responsible person. |
| Chemical approval register | Product, risk review, substitution considered, authority or permit requirement, approval reference, restrictions and authorised user or location. |
| Storage compatibility matrix | Hazard class, incompatibilities, segregation method, permitted storage location and emergency controls. |
| Hazardous-store inspection | Labels, SDS access, segregation, quantities, expiry, container integrity, fire and spill equipment, bunding, housekeeping, access and corrective actions. |
| Training matrix | General awareness, task-specific handling, storekeeper, decanting, spill response, transport and delivery, supervisor and refresher requirements. |
| Hazardous-waste register | Waste description, source, hazard status, container, accumulation area, quantity, collection or disposal contractor, consignment reference and date. |
Pre-mobilisation checklist
- 1Confirm exact jurisdiction, permit conditions, client or developer requirements and Civil Defence controls.
- 2Appoint the competent programme owner and establish chemical entry and approval controls.
- 3Create the hazardous-substances inventory, SDS register and chemical approval register before delivery.
- 4Complete storage and task risk assessments, including compatibility, segregation and spill pathways.
- 5Approve stores, secondary containment, fire and spill equipment, signage and emergency access and egress.
- 6Ensure all product and secondary containers are identified and current SDSs are accessible in understandable languages.
- 7Deliver hazard-communication and task-specific training before work starts.
- 8Link work controls to MSRAs, permits, inspection schedules, emergency drills and approved waste disposal arrangements.
Frequently asked questions
Does COSHH apply in the UAE?
No. COSHH is a United Kingdom term and UK regulation. In the UAE you run a standalone Hazardous Substances Control and Hazard Communication Programme that meets applicable federal, emirate, municipality, Civil Defence, free-zone and project requirements. The content is equivalent in intent: assess, control, communicate, store, train and dispose.
What does MoHRE require for hazardous substances on site?
MoHRE's OSH procedures require competent-authority approval before storage or handling where applicable, accurate use, storage and trading records, safe storage in labelled containers, warning labels in Arabic and other languages understood by workers where necessary, and suitable measurement or monitoring with recorded results.
What does ADOSH-SF CoP 1.0 add in Abu Dhabi?
CoP 1.0 applies to entities that import, store, transport, sell or use hazardous materials. It requires risk assessment, relevant permits and approvals, competent oversight, controls at source, routine inspection, approved disposal, emergency planning, and worker training before work, plus current SDS access, compatible storage, inventories, labels and emergency arrangements.
Does the programme cover fitness to work or medical surveillance?
No. This programme deliberately excludes fitness to work, occupational health screening and medical surveillance. Those are controlled separately under the project occupational-health procedure.
Which registers should a UAE construction site keep?
As a minimum: the hazardous substances inventory, SDS register, chemical approval register, storage compatibility matrix, hazardous-store inspection record, training matrix and hazardous-waste register.
Official source references
- [1]MoHRE Administrative Decision No. 19 of 2023 — Occupational Safety and Health and Labour Accommodation
- [2]ADPHC ADOSH-SF (formerly OSHAD) CoP 1.0 — Hazardous Materials, Version 4.0 (July 2024)
- [3]Dubai Administrative Resolution No. 7 of 2022 — Manual for Providing First Aid Services at Workplaces
The Dubai First Aid Manual requires current chemical safety data sheets to be prominently available at locations using chemical substances that may pose health hazards, supporting the site SDS-access requirement. [3]
This is a general implementation briefing, not legal or medical advice. Verify the site-specific legal and authority requirements before adoption. The Arabic version of any applicable UAE legislation governs in the event of a discrepancy.