HSE Intensifies Focus on COSHH Compliance in UK Food Sector

The Health and Safety Executive (HSE) has issued a renewed call for UK food businesses to rigorously review and enhance their compliance with the Control of Substances Hazardous to Health (COSHH) Regulations 2002. This comes amidst ongoing concerns about work-related respiratory and dermatological illnesses attributed to exposure to hazardous substances commonly found within the food production and hospitality sectors.

Recent data from the HSE indicates that the food industry, encompassing everything from manufacturing and processing to catering and retail, remains a significant contributor to occupational ill-health. Specifically, flour dust, cleaning chemicals, and certain food additives are frequently cited as causes of occupational asthma, dermatitis, and other respiratory sensitisation conditions.

“The food sector relies heavily on a range of substances that, if not properly controlled, can pose serious health risks to workers,” stated a spokesperson for the HSE. “From the everyday use of cleaning agents to the inhalation of flour dust in bakeries, employers have a clear legal duty under COSHH to protect their employees. We are seeing a persistent number of cases of preventable ill-health, and it’s imperative that businesses take proactive steps to mitigate these risks.”

Key Hazardous Substances and Associated Risks

Within the diverse landscape of the food industry, several categories of hazardous substances present distinct challenges for COSHH compliance:

  • Flour Dust: A well-known respiratory sensitiser, flour dust can cause occupational asthma. The HSE estimates that bakers and other workers exposed to flour dust are at a significantly higher risk of developing this debilitating condition. Exposure limits and control measures, such as local exhaust ventilation (LEV) and good housekeeping, are crucial.
  • Cleaning Chemicals: Detergents, sanitisers, disinfectants, and descalers, often used in concentrated forms, can cause skin irritation, burns, and respiratory problems from fumes. Proper storage, dilution, personal protective equipment (PPE), and adequate ventilation are essential controls.
  • Food Additives and Flavourings: Certain additives, particularly those in powdered form, can act as respiratory sensitizers or irritants. Examples include some spices, enzymes, and flavour enhancers.
  • Cooking Fumes and Vapours: High-temperature cooking, especially deep-frying, can produce fumes and vapours containing hazardous compounds that can irritate the respiratory system. Effective kitchen ventilation systems are critical.
  • Refrigerants: While less common in direct exposure, leaks from refrigeration systems can pose asphyxiation risks or exposure to toxic gases.

The HSE emphasises that a robust COSHH assessment must identify all hazardous substances, evaluate the risks they pose, and implement appropriate control measures. This includes considering substitution with less hazardous alternatives, engineering controls (e.g., LEV, enclosed systems), administrative controls (e.g., safe work procedures, reduced exposure times), and finally, suitable PPE where other controls are insufficient.

Legal Obligations and Enforcement

Under the COSHH Regulations 2002, employers are legally required to:

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  • Identify hazardous substances in the workplace.
  • Assess the risks to health arising from these substances.
  • Implement appropriate control measures to prevent or adequately control exposure.
  • Ensure control measures are maintained and regularly reviewed.
  • Provide information, instruction, and training to employees.
  • Carry out health surveillance where appropriate.

Failure to comply with COSHH can lead to enforcement action by the HSE, including improvement notices, prohibition notices, prosecution, and significant fines. In 2022/23, the HSE carried out over 30,000 proactive inspections and investigations, resulting in 182 prosecutions and fines totalling £14.1 million across all sectors. While specific figures for the food sector related to COSHH are not always disaggregated, the industry remains a focus area for regulatory oversight.

The HSE encourages businesses to utilise its comprehensive guidance and resources available on its website, including industry-specific advice for sectors like baking, catering, and food manufacturing. These resources provide practical steps for conducting COSHH assessments and implementing effective control strategies.

Proactive Steps for Food Businesses

To ensure robust COSHH compliance, food businesses should consider the following proactive steps:

  1. Conduct Thorough Risk Assessments: Systematically identify all hazardous substances, assess exposure routes, and evaluate the potential health effects. Review these assessments regularly, especially after changes in processes or substances.
  2. Implement Control Measures: Prioritise the hierarchy of controls – elimination, substitution, engineering controls (e.g., LEV, automation), administrative controls (e.g., job rotation, safe work procedures), and finally, PPE.
  3. Provide Training and Information: Ensure all employees who work with or near hazardous substances receive adequate training on risks, safe handling procedures, emergency protocols, and correct use of control measures and PPE.
  4. Maintain Equipment: Regularly inspect and maintain control equipment, such as LEV systems, to ensure they are functioning effectively. Keep records of all maintenance.
  5. Monitor and Review: Continuously monitor workplace conditions and employee health. Review the effectiveness of control measures and update them as necessary.
  6. Health Surveillance: Where there is a reasonable likelihood of an identifiable disease or adverse health effect occurring, and where valid techniques exist to detect it, arrange for appropriate health surveillance. This is particularly relevant for sensitizers like flour dust.

The HSE's renewed emphasis underscores the ongoing importance of COSHH in protecting workers' health across the UK's vital food sector. Proactive management and a commitment to continuous improvement are key to preventing avoidable illnesses and ensuring a safe working environment.

For businesses seeking to enhance their understanding of COSHH regulations and implement effective safety protocols, professional training and consultancy services can be invaluable. Abertay Training offers comprehensive health and safety courses, including COSHH awareness and risk assessment training, designed to help organisations meet their legal obligations and foster a safer workplace. More information can be found at https://www.abertaytraining.co.uk.