HSE Intensifies Focus on Chemical Safety in UK Food Industry

The Health and Safety Executive (HSE) has issued a renewed warning to businesses within the UK's vast food and drink manufacturing sector, highlighting an uptick in enforcement actions related to the Control of Substances Hazardous to Health (COSHH) Regulations 2002. This comes as recent prosecution data indicates a growing emphasis on ensuring robust chemical safety management across the industry, following several high-profile incidents.

Food and drink manufacturing remains one of the largest manufacturing sectors in the UK, employing over 400,000 people. While contributing significantly to the economy, it also presents unique challenges regarding chemical safety, from cleaning agents and disinfectants to flavourings and processing aids. The HSE's proactive stance underscores the critical need for employers to diligently assess, control, and monitor exposure to hazardous substances.

Understanding COSHH in the Food Sector Context

The COSHH Regulations 2002 require employers to control substances hazardous to health. For the food and drink industry, this encompasses a wide array of materials, including:

  • Cleaning and disinfection chemicals: Caustic sodas, acids, hypochlorites, and quaternary ammonium compounds, often used in large volumes.
  • Flavourings and additives: Certain concentrated flavourings can cause respiratory sensitisation or skin irritation.
  • Processing aids: Enzymes, lubricants, and refrigerants.
  • Naturally occurring substances: Flour dust, grain dust, and spices, which can cause respiratory diseases like asthma.
  • By-products of processes: Fumes from cooking or welding, and even carbon dioxide from fermentation.

A recent HSE report highlighted that occupational asthma remains a significant concern, with flour dust being a leading cause in bakeries. The report noted that between 2017/18 and 2019/20, an estimated 13,000 new cases of occupational asthma were reported in the UK, with food-related exposures contributing substantially to this figure.

“Employers in the food sector must recognise that COSHH extends far beyond just the obvious corrosive cleaning agents,” stated an HSE spokesperson. “The risks posed by dusts from flour, spices, or even certain food allergens, require equally rigorous assessment and control. Failure to do so not only endangers employee health but also risks significant legal and financial penalties.”

Recent Enforcement Actions and Their Implications

The HSE's renewed focus is evidenced by several recent successful prosecutions. In one notable case in late 2022, a major food manufacturer was fined over £500,000 and ordered to pay costs after an employee suffered severe chemical burns due to inadequate control measures for a cleaning chemical. The investigation found a lack of proper risk assessment, insufficient training, and inadequate personal protective equipment (PPE).

Another case in early 2023 saw a bakery company fined £120,000 for failing to control exposure to flour dust, leading to multiple employees developing occupational asthma. The court heard that despite repeated warnings, the company had not implemented effective local exhaust ventilation (LEV) or provided adequate respiratory protective equipment (RPE).

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These cases serve as stark reminders of the HSE's commitment to enforcing COSHH regulations. Penalties for breaches can include:

  • Significant fines, potentially running into hundreds of thousands or even millions of pounds.
  • Imprisonment for individuals found to be grossly negligent.
  • Reputational damage and loss of consumer trust.
  • Increased insurance premiums.

The HSE guidance HSG258 'Controlling airborne contaminants at work: A guide to local exhaust ventilation (LEV)' and HSG193 'Respiratory protective equipment at work: A practical guide' are frequently cited in enforcement actions, underscoring the importance of adherence to these practical guidelines.

Key Steps for Food Businesses to Ensure COSHH Compliance

To mitigate risks and ensure compliance, food businesses should implement a comprehensive COSHH management strategy. The HSE recommends following the '8 Steps to Control COSHH' framework:

  1. Assess the risks: Identify hazardous substances and evaluate the risks they pose. This includes reviewing Safety Data Sheets (SDS) for all chemicals.
  2. Decide on precautions: Apply the hierarchy of controls (elimination, substitution, engineering controls, administrative controls, PPE).
  3. Prevent or adequately control exposure: Implement effective control measures such as LEV, process enclosure, or automation.
  4. Maintain control measures: Regularly inspect and test control equipment (e.g., LEV systems every 14 months, as per Regulation 9 of COSHH).
  5. Monitor exposure: Where necessary, conduct air monitoring to ensure control measures are effective.
  6. Carry out health surveillance: For employees exposed to certain substances (e.g., sensitizers like flour dust or isocyanates), regular health checks are crucial.
  7. Prepare plans and procedures for accidents, incidents and emergencies: Ensure spill kits are available and employees know how to respond.
  8. Inform, instruct and train employees: Provide comprehensive training on the risks, control measures, and emergency procedures.

The HSE’s 'COSHH essentials for the catering industry' and 'COSHH essentials for food and drink manufacturers' provide sector-specific guidance and control sheets to assist businesses in developing appropriate measures.

In conclusion, the heightened scrutiny from the HSE serves as a critical reminder for all UK food and drink manufacturers to review and reinforce their COSHH compliance strategies. Proactive risk management, thorough training, and consistent monitoring are not just regulatory requirements but fundamental pillars for ensuring a safe and healthy working environment. For businesses seeking to enhance their understanding and implementation of COSHH regulations, professional training and consultancy services are invaluable. Abertay Training offers comprehensive health and safety courses, including COSHH awareness and management, to help organisations meet their legal obligations and foster a culture of safety. More information can be found at https://www.abertaytraining.co.uk.