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There is no absolute correlation between the need of a risk assessment and what type of product you are using. CLP and Reach dictates the demands for chemical products, while cosmetic products are covered by another legislation, that much is true. Reach and CLP controls which products must come with an SDS, how you should get it and how the products should be labelled for example.

But the demand for a risk assessment in the workplace is often covered by national occupational regulations. In sweden for example, the Swedich Work Environment Authority is the controlling agency for occupational risk assessments, and the provision Chemical Hazards in the Work Environment (AFS 2011:19 om Kemiska arbetsmiljörisker) dictates the demands for chemical risk assessments. There is nowhere stated that those risk assessments only cover chemical products and that for example cosmetic products in general are excluded from that demand. They are excluded from the demand of SDS because they are not covered by Reach, yes, but they may still pose a risk in the work place.

Tip: If using the old risk assessment, use the shorter template Risk mapping, if you know straight away that this product poses no risk to your employees. If using the new risk assessment, group several simlar products togehter in one risk assessment to document their low risk. Could be for example all mild soaps from all different brands you use.