The short answer is yes — in most circumstances, UK law requires exterior cleaning contractors to produce both a Risk Assessment and a COSHH Assessment before carrying out work. Here is exactly what the law says and when it applies to you.
The Legal Framework
Several pieces of UK legislation create a legal duty to produce risk assessments and COSHH assessments. These are not optional guidelines — they are enforceable law, and failure to comply can result in prosecution, fines, and in serious cases, imprisonment.
Health and Safety at Work etc. Act 1974
Section 2 & 3Places a general duty on every employer to ensure, so far as is reasonably practicable, the health, safety, and welfare of employees. It also extends this duty to persons not in employment who may be affected by the work — including members of the public and clients.
Management of Health and Safety at Work Regulations 1999
Regulation 3Requires every employer and self-employed person to make a suitable and sufficient assessment of the risks to the health and safety of employees and others arising from their work activities. If you employ five or more people, this assessment must be recorded in writing.
Control of Substances Hazardous to Health Regulations 2002 (COSHH)
Regulation 6Requires employers to assess the risk to health arising from work involving hazardous substances. This applies to any cleaning chemical — including sodium hypochlorite (bleach), degreasers, biocides, and acid-based cleaners — used in exterior cleaning operations.
Work at Height Regulations 2005
Regulation 6Requires a risk assessment for any work carried out at height, and a method statement detailing how the work will be carried out safely. This applies to ladder work, roof cleaning, gutter clearance, and any other exterior cleaning task performed above ground level.
Construction (Design and Management) Regulations 2015 (CDM)
Regulation 4Where exterior cleaning is carried out as part of a construction or refurbishment project, CDM regulations may apply. Principal contractors are required to ensure that all contractors working on site have suitable RAMS in place before work commences.
Does This Apply to Sole Traders?
Yes. The Management of Health and Safety at Work Regulations 1999 apply to self-employed persons as well as employers. If you are a sole trader carrying out exterior cleaning work, you are legally required to carry out a risk assessment before undertaking any work that presents a risk to your health and safety or that of others.
The requirement to record the assessment in writing applies where you employ five or more people. However, even if you work alone, it is strongly advisable to document your risk assessments — both for your own protection and because clients and principal contractors will almost always request written RAMS before allowing you on site.
When Is a COSHH Assessment Required?
A COSHH assessment is required whenever you use, handle, store, or dispose of any substance that is hazardous to health. In exterior cleaning, this includes:
Your COSHH assessment must identify the substance, describe how workers may be exposed, evaluate the risk, and specify the control measures — including PPE, ventilation, and emergency procedures. Safety Data Sheets (SDS) from the manufacturer are the starting point for any COSHH assessment.
What Happens If You Don't Comply?
The consequences of failing to produce adequate RAMS and COSHH assessments can be severe:
HSE improvement notices or prohibition notices, stopping work immediately
Unlimited fines for breaches of the Health and Safety at Work Act
Criminal prosecution and potential imprisonment for serious breaches
Insurance voidance — your public liability insurer may refuse to pay out if you cannot demonstrate a suitable risk assessment was in place
Loss of contracts — commercial clients and principal contractors will not engage contractors who cannot produce RAMS
Making Compliance Straightforward
Understanding the legal requirements is one thing — actually producing compliant documentation consistently for every job is another. RAMS Creator was built to make this process as straightforward as possible for exterior cleaning contractors.
The app includes pre-built COSHH data for common cleaning chemicals, guided risk assessment sections, and automatic PDF generation — so you can produce a legally compliant RAMS and COSHH assessment in minutes, not hours. Whether you are a sole trader or managing a team, having a consistent, documented process protects you, your workers, and your business.
Legal Disclaimer
This article provides general guidance on UK health and safety legislation. It does not constitute legal advice. For specific legal queries, consult a qualified health and safety professional or solicitor.
