Tolley's Practical Risk Assessment Handbook, 5th Edition

The author has encountered many situations where employers have not met the objectives of the COSHH Regulations, sometimes despite the expenditure of considerable time and effort. Amongst the more common pitfalls are the following.
Employers have collected a vast library of manufacturers and suppliers data sheets (many of which relate to substances they do not use) in the belief that this constitutes a COSHH assessment. Whilst acquiring relevant data sheets is an important preparatory step and their availability can assist in respect of emergency medical treatment, simply acquiring data sheets is a long way short of what is required.
Some employers have been known to simply arrange for information from data sheets to be transcribed onto their own COSHH assessment form without anyone actually visiting the workplace to review the circumstances of use. Observations and discussions in the workplace are an essential part of assessing what control measures are necessary for individual processes or activities.
Manufacturers and suppliers often identify precautions which may be appropriate for the use of their products. The unquestioning adoption of these precautions can often result in precautions (particularly PPE requirements) which are unnecessary, impractical for employees and extremely expensive. Whilst advice in data sheets is undoubtedly relevant, it is ultimately for the assessor(s) to determine what is appropriate in their workplace for their working methods and the quantity of substances they use.