Golf Clubs

COSHH Compliance for Golf Club Greenkeepers

๐Ÿ“… February 2025 โœ๏ธ Steuart Fotheringham, ALPS Consultancy โฑ 4 min read

Greenkeepers work with an impressive range of hazardous substances every single day โ€” pesticides, herbicides, fungicides, fertilisers, fuel, lubricants and cleaning chemicals. Yet COSHH (Control of Substances Hazardous to Health) is one of the most consistently under-documented areas of health and safety in UK golf clubs. This article explains what's required, what's commonly missed, and how to fix it.

What is COSHH and Why Does It Apply to Greenkeepers?

The Control of Substances Hazardous to Health Regulations 2002 require employers to assess the health risks posed by any substance that could cause harm โ€” and to take appropriate measures to prevent or adequately control exposure.

For greenkeeping teams, the range of substances involved is broad and includes some genuinely hazardous materials. Pesticides and professional herbicides carry significant health risks if handled incorrectly, including respiratory sensitisation, skin irritation, and in the case of some older compounds, more serious chronic effects.

Legal Obligation

Failure to carry out suitable COSHH assessments is a breach of the COSHH Regulations 2002 and can result in HSE enforcement action, improvement notices, and in serious cases, prosecution. Golf clubs are not exempt because they are membership organisations โ€” COSHH applies to all employers.

What Substances Need COSHH Assessments?

Every substance with the potential to cause harm must be assessed. For a typical golf club greenkeeper's store, this will include:

CategoryExamplesKey Hazards
Pesticides / HerbicidesGlyphosate, Trifloxystrobin, PropiconazoleSkin & eye irritation, inhalation risk
FungicidesChlorothalonil alternatives, TebuconazoleSensitisation, reproductive hazards (some)
FertilisersNitrogen, potassium, iron compoundsDust inhalation, skin irritation
Fuels & LubricantsDiesel, petrol, hydraulic fluid, chain oilDermatitis, fire/explosion risk
Cleaning ChemicalsDegreasers, disinfectants, pressure washer tabletsCorrosive, irritant
Line Marking ProductsSand dyes, paint spraysInhalation risk, skin sensitisation

What Must a COSHH Assessment Include?

A compliant COSHH assessment must document the following for each substance:

  1. Identification of the substance โ€” product name, supplier, active ingredients
  2. Nature and degree of exposure โ€” who is exposed, how often, in what quantities
  3. Health hazards โ€” based on the Safety Data Sheet (SDS) and actual use conditions
  4. Control measures โ€” engineering controls, safe working procedures, PPE
  5. PPE specification โ€” type of gloves, respiratory protection, eye protection required
  6. Emergency procedures โ€” first aid steps if exposure occurs
  7. Review date โ€” assessments must be reviewed when substances or conditions change
Common Gap

Many golf clubs hold COSHH assessments from 5+ years ago that refer to products that are no longer used, or that don't reflect newer substances that have been introduced. An assessment is only valid if it reflects what your greenkeeping team is actually using today.

Pesticide Regulations โ€” An Additional Layer

Professional pesticide use on golf courses is also regulated under the Food and Environment Protection Act 1985 (FEPA) and associated codes of practice. Greenkeepers applying pesticides professionally must hold a BASIS-registered certificate of competence โ€” typically PA1 (foundation) and PA6 (pedestrian-applied) as a minimum, with PA2 added for tractor-mounted applications.

Pesticide application records must be maintained, including the product used, rate, area treated, weather conditions, and operator. These records must be kept for at least 3 years and must be available for inspection by the relevant authority (HSE, Environment Agency, or SEPA in Scotland).

Safe Storage of Substances

Storage of hazardous substances in the greenkeeper's shed is itself a significant compliance area. Requirements include:

Staff Training and Information

Under COSHH Regulation 12, employees must be provided with suitable and sufficient information, instruction and training about the substances they work with. This includes:

Training must be documented with signed records. A verbal briefing given years ago at induction is not sufficient.

โ›ณ Greenkeeper COSHH โ€” Essential Checklist

How ALPS Consultancy Can Help

We carry out full greenkeeper COSHH assessments for golf clubs across Scotland โ€” visiting your premises, reviewing every substance in your store, and producing a complete, legally compliant assessment pack for each one. We also provide the staff training and briefing records you need to demonstrate compliance.

For clubs that have never had a COSHH assessment carried out professionally, or that are working from outdated documents, this is typically a one-visit process that puts everything in order.

SF
Steuart Fotheringham Managing Director, ALPS Consultancy ยท COSHH Assessor ยท NEBOSH ยท Food Safety Level 4

Is Your Greenkeeper COSHH Documentation Up to Date?

Book a initial exploratory discussion with ALPS Consultancy and we'll review your current COSHH position โ€” no obligation, no jargon, no pressure.

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