Food Sector Under Scrutiny: HSE Highlights COSHH Failures

The Health and Safety Executive (HSE) has issued a renewed call for heightened awareness and strict compliance with Control of Substances Hazardous to Health (COSHH) regulations within the UK's food manufacturing and catering sectors. This comes in the wake of a discernible increase in enforcement actions and prosecutions related to COSHH breaches during the 2023/2024 reporting period, underscoring persistent challenges in managing chemical risks in food environments.

While the food sector is often associated with biological hazards and food hygiene, the use of cleaning agents, disinfectants, pest control chemicals, and even naturally occurring substances in food processing can pose significant health risks to workers if not properly managed. The HSE's recent emphasis serves as a critical reminder that COSHH compliance is as vital in a kitchen or food production line as it is in a chemical plant.

Key Findings and Regulatory Focus

Analysis of recent HSE prosecution data reveals a concerning trend. Although specific, granular data for COSHH prosecutions solely within the food sector for 2023/2024 is still being compiled and refined, the broader picture indicates that a significant proportion of workplace health prosecutions involve failures in controlling exposure to hazardous substances. For instance, respiratory diseases, often linked to exposure to cleaning chemicals, flour dust, or other airborne contaminants, remain a substantial occupational health issue. The HSE's Health and safety at work: Summary statistics for Great Britain 2023 report highlighted that an estimated 1.8 million working people suffered from work-related ill health in 2022/23, with new or long-standing breathing or lung problems accounting for 13,000 cases, many of which can be attributed to inadequate COSHH controls.

The food industry presents unique COSHH challenges. Substances like caustic soda for cleaning, chlorine-based disinfectants, and even common detergents can cause skin irritation, respiratory issues, and eye damage. Furthermore, allergens, while primarily a food safety concern for consumers, can also pose an inhalation risk to workers if present as airborne dusts, necessitating careful COSHH assessment.

  • Cleaning Chemicals: Many powerful cleaning agents used in food preparation areas are corrosive or irritant.
  • Disinfectants: Chlorine-based and quaternary ammonium compounds (QACs) are common but can cause respiratory sensitisation.
  • Flour Dust: A well-known respiratory sensitiser in bakeries, leading to occupational asthma.
  • Enzymes: Used in some food processing, these can be potent respiratory sensitisers.
  • Pest Control Products: Insecticides and rodenticides, if improperly handled, pose significant risks.

The HSE's renewed focus aims to ensure employers are not just aware of COSHH but are actively implementing robust control measures, including suitable ventilation, appropriate personal protective equipment (PPE), and comprehensive employee training.

Understanding COSHH in Food Environments

COSHH Regulations 2002 (as amended) mandate employers to protect employees from hazardous substances. This involves a hierarchical approach to control, prioritising elimination or substitution of hazardous substances, followed by engineering controls (e.g., ventilation), administrative controls (e.g., safe work procedures), and finally, personal protective equipment (PPE).

Related training: If you are looking to qualify as a trainer in this area, see COSHH assessor training or explore health and safety trainer qualifications for nationally recognised UK and Ireland qualifications.

For food businesses, this translates into several key responsibilities:

  1. Risk Assessment: Identify all hazardous substances used or generated, assess the risks they pose, and determine who might be harmed and how. This should include cleaning products, pest control chemicals, and any substances intrinsic to food processing (e.g., flour dust, enzymes).
  2. Control Measures: Implement effective measures to prevent or adequately control exposure. This might involve using less hazardous alternatives, improving local exhaust ventilation (LEV) systems in areas where dust or fumes are generated, or providing suitable gloves, eye protection, and respirators.
  3. Monitoring and Review: Regularly monitor the effectiveness of control measures and review risk assessments, especially after any incidents, changes in processes, or new substances are introduced.
  4. Information, Instruction, and Training: Provide employees with clear information about the risks and the control measures in place. Training should cover safe handling procedures, emergency protocols, and correct use and maintenance of PPE.
  5. Health Surveillance: Where appropriate, arrange for health surveillance, particularly for employees exposed to sensitising substances like flour dust or certain cleaning chemicals.

Failure to adhere to these regulations can lead to significant penalties, including fines and imprisonment, as well as reputational damage and, most importantly, serious harm to employees' health. The HSE has demonstrated its willingness to prosecute businesses that fail to meet their statutory duties, with recent cases highlighting fines ranging from tens of thousands to hundreds of thousands of pounds for serious breaches.

Proactive Steps for Compliance

To avoid enforcement action and, more importantly, to safeguard employee health, food businesses should take proactive steps to review and enhance their COSHH management systems:

  • Conduct a thorough COSHH inventory: List all chemicals and substances used on-site, obtaining up-to-date Safety Data Sheets (SDS).
  • Review existing risk assessments: Ensure they are comprehensive, specific to the tasks performed, and regularly updated. Pay particular attention to cleaning routines and areas where dust or fumes are generated.
  • Evaluate control measures: Are they effective? Is LEV maintained and tested regularly (e.g., a thorough examination and test every 14 months for LEV systems, as per HSG258)? Is PPE suitable, correctly used, and properly maintained?
  • Enhance training: Ensure all staff, especially new hires and those involved in cleaning or chemical handling, receive adequate COSHH training. This should cover hazard identification, safe handling, emergency procedures, and the correct use of PPE.
  • Promote a strong safety culture: Encourage employees to report concerns about chemical exposure or control measure deficiencies without fear of reprisal.

The HSE's intensified focus on COSHH within the food sector is a timely reminder for all employers. Prioritising chemical safety is not only a legal obligation but a fundamental aspect of responsible business practice, protecting both workers and the business from the potentially severe consequences of non-compliance.

For businesses seeking to ensure full compliance with COSHH regulations and other essential health and safety training, Abertay Training offers comprehensive courses and consultancy services. Visit https://www.abertaytraining.co.uk for more information on how they can assist your organisation in achieving and maintaining high standards of workplace safety.