HSE Reinforces COSHH Compliance in Food Industry Following Allergy Concerns

The Health and Safety Executive (HSE) has issued a renewed call for vigilance and robust compliance with the Control of Substances Hazardous to Health (COSHH) Regulations 2002 within the UK food manufacturing, catering, and retail sectors. This comes amidst ongoing concerns regarding food allergy incidents and the potential for severe health consequences stemming from inadequate control measures.

While COSHH is often associated with industrial chemicals, its scope extends significantly to include any substance that could pose a risk to health, including food allergens when they are present in a manner that could cause harm to susceptible individuals. The HSE emphasises that food businesses have a legal duty to protect their employees and, indirectly, their customers from exposure to hazardous substances, which critically includes managing allergens effectively.

The Interplay of COSHH, Allergens, and Consumer Safety

The Food Standards Agency (FSA) consistently highlights the critical importance of accurate allergen information. However, COSHH addresses the workplace aspect of managing these substances. For example, in a bakery, flour dust is a known respiratory sensitiser and falls under COSHH. Similarly, managing cross-contamination of allergens like nuts or sesame seeds during food preparation or manufacturing processes can create a hazardous environment for employees with allergies, and potentially for consumers if those allergens are not declared.

A recent FSA report indicated that food allergy and intolerance incidents remain a significant public health issue. Although specific COSHH enforcement statistics for allergen-related incidents are not typically segregated, the HSE's broader enforcement activities often uncover deficiencies in general workplace hygiene and substance control that could contribute to allergen cross-contamination. The HSE's 'Hidden Killer' campaign, for instance, often touches upon respiratory sensitisers, many of which are common food ingredients.

Key COSHH Requirements for Food Businesses

Under COSHH, employers are legally required to:

  • Assess the risks: Identify all hazardous substances, including specific food allergens that could be present, and evaluate the risks they pose to employees. This includes assessing the potential for airborne particles (e.g., flour dust, spice dust) and skin contact with sensitising ingredients.
  • Control the risks: Implement effective control measures to prevent or adequately control exposure. This hierarchy of control should be followed: elimination, substitution, engineering controls (e.g., ventilation, enclosed systems), administrative controls (e.g., safe work procedures, cleaning protocols), and finally, personal protective equipment (PPE) as a last resort.
  • Maintain control measures: Ensure that all control measures are regularly checked and maintained to ensure their continued effectiveness.
  • Monitor exposure: In some cases, monitoring the level of exposure may be necessary to ensure controls are working.
  • Health surveillance: Provide health surveillance for employees where there is a reasonable likelihood of an adverse health effect linked to exposure, such as occupational asthma from flour dust.
  • Provide information, instruction, and training: Employees must be fully aware of the risks and the control measures in place, including specific training on allergen handling and cross-contamination prevention.

The HSE's guidance on COSHH emphasises that 'adequate control' means reducing exposure to as low as reasonably practicable and, in any case, below any Workplace Exposure Limits (WELs). While WELs don't exist for all food allergens, the principle of minimising exposure remains paramount.

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Preventative Measures and Best Practices

For food businesses, proactive measures are essential. This includes:

  • Detailed Risk Assessments: Conducting thorough COSHH risk assessments that specifically consider all allergens present in the workplace, their form (e.g., powder, liquid), and potential for exposure.
  • Segregation and Labelling: Implementing strict segregation of allergen-containing ingredients and products, along with clear and accurate labelling throughout the production process.
  • Dedicated Equipment and Zones: Where possible, using dedicated equipment and production zones for allergen-free or specific allergen-containing products to minimise cross-contamination.
  • Robust Cleaning Regimes: Establishing and strictly adhering to comprehensive cleaning and sanitation protocols, including validating cleaning effectiveness for allergen removal.
  • Employee Training: Providing ongoing and comprehensive training for all staff on allergen awareness, COSHH procedures, safe handling practices, and emergency protocols. This should cover new employees and regular refreshers for existing staff.
  • Ventilation Systems: Ensuring adequate local exhaust ventilation (LEV) systems are in place and properly maintained to control airborne dusts from ingredients like flour, spices, or powdered milk, which can be both respiratory sensitizers and allergens.

Failure to comply with COSHH regulations can lead to enforcement action from the HSE, including improvement notices, prohibition notices, prosecution, and significant fines. More importantly, it can result in serious health impacts for employees and consumers, reputational damage, and financial losses for the business.

Businesses are encouraged to review their existing COSHH assessments and control measures, especially in light of any changes to ingredients, processes, or personnel. Staying informed about the latest guidance from the HSE and FSA is crucial for maintaining a safe working environment and ensuring product safety.

For comprehensive training on COSHH and food safety, businesses can explore resources offered by expert providers such as Abertay Training, who offer a range of accredited courses to help organisations meet their regulatory obligations and foster a culture of safety. Visit https://www.abertaytraining.co.uk for more information.