HSE Intensifies Focus on COSHH Compliance in UK Food Sector

The Health and Safety Executive (HSE) has issued a renewed call for vigilance and strict adherence to Control of Substances Hazardous to Health (COSHH) regulations within the UK's expansive food and drink manufacturing and service sectors. This comes amidst a backdrop of increased enforcement action and substantial fines levied against businesses failing to manage hazardous substances effectively.

COSHH, enshrined in law by the Control of Substances Hazardous to Health Regulations 2002, places a legal duty on employers to protect their employees from ill-health caused by exposure to hazardous substances. In the food sector, these substances can range from cleaning chemicals, disinfectants, and flavourings to flour dust, enzymes, and even naturally occurring toxins.

Recent data from the HSE indicates a persistent challenge in controlling exposure to workplace hazards. While specific figures for COSHH breaches in the food sector for the latest reporting period are still being compiled, historical data highlights the scale of the problem. For instance, respiratory diseases, often linked to exposure to hazardous substances like flour dust in bakeries or cleaning agents, continue to be a significant concern. The HSE's 'Health and safety statistics for Great Britain, 2022' report highlighted that an estimated 1.8 million working people suffered from work-related ill health in 2021/22, with new cases of breathing or lung problems estimated at 19,000.

Key Hazardous Substances and Risks in Food Environments

The food industry presents a unique array of COSHH risks. Businesses, from large-scale manufacturers to small independent cafes, routinely utilise a variety of substances that, if not properly controlled, can lead to serious health issues. These include:

  • Cleaning and Disinfecting Agents: Strong acids, alkalis, and sanitisers used for hygiene purposes can cause skin burns, respiratory irritation, and eye damage.
  • Flour Dust: A well-documented respiratory sensitiser, prolonged exposure to flour dust can lead to occupational asthma, a chronic and debilitating lung condition. The HSE has previously launched targeted campaigns to address this, emphasising the importance of dust control measures.
  • Enzymes: Used in baking and brewing, enzymes can cause allergic reactions and occupational asthma.
  • Food Additives and Flavourings: Some can be respiratory or skin sensitizers.
  • Refrigerants: Leaks from refrigeration systems can pose asphyxiation risks in enclosed spaces.
  • Fumes and Vapours: From cooking oils, frying, or certain processing techniques can irritate the respiratory system.

The HSE emphasises that employers must conduct thorough COSHH assessments to identify all hazardous substances, evaluate the risks they pose, and implement effective control measures. This is not merely a bureaucratic exercise but a fundamental pillar of workplace safety, directly impacting employee health and business continuity.

Enforcement and Penalties for Non-Compliance

The HSE has demonstrated a robust approach to enforcement, with significant penalties for non-compliance. In the financial year 2022/23, the total amount of fines resulting from HSE prosecutions was £23.6 million, with an average fine per case of £145,000. While these figures encompass all health and safety breaches, a substantial portion relates to failures in managing workplace hazards, including those covered by COSHH.

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

Recent cases illustrate the severity of repercussions. For example, a food manufacturing company in the North East was fined £80,000 in late 2023 for failing to adequately control exposure to cleaning chemicals, which resulted in an employee suffering severe chemical burns. Another bakery business faced a £50,000 fine earlier this year for failing to implement sufficient controls for flour dust, leading to multiple employees developing occupational asthma.

These cases underscore the HSE's commitment to holding businesses accountable. Fines can be substantial, but the reputational damage, loss of productivity, and human cost of preventable ill-health are often far greater.

Steps for Effective COSHH Management

To ensure compliance and protect employees, businesses in the food sector should:

  1. Conduct Comprehensive Risk Assessments: Identify all hazardous substances present, assess the risks, and determine who might be harmed and how.
  2. Implement Control Measures: Follow the hierarchy of controls: eliminate, substitute, engineer controls (e.g., local exhaust ventilation), administrative controls (e.g., safe work procedures), and finally, personal protective equipment (PPE).
  3. Provide Information, Instruction, and Training: Employees must be fully aware of the risks and how to work safely with hazardous substances. This includes proper use of PPE and emergency procedures.
  4. Monitor Exposure and Health Surveillance: Where appropriate, monitor air quality and conduct health surveillance for employees exposed to certain substances (e.g., respiratory health checks for those exposed to flour dust).
  5. Maintain and Review: Regularly review COSHH assessments and control measures, especially after any incidents, changes in processes, or introduction of new substances.
  6. Emergency Procedures: Establish clear procedures for spills, leaks, and other emergencies involving hazardous substances.

The HSE provides extensive guidance and resources on its website (www.hse.gov.uk) to assist businesses in meeting their COSHH obligations. Employers are strongly advised to familiarise themselves with these resources and seek expert advice where necessary.

Ensuring robust COSHH compliance is not just a legal requirement but a moral imperative. Protecting the health of employees from hazardous substances in the food sector safeguards individuals and contributes to a more productive and sustainable industry. For businesses seeking to enhance their understanding and implementation of COSHH regulations, professional training can be invaluable. Abertay Training offers comprehensive health and safety courses, including those focused on COSHH, to help organisations meet their legal obligations and foster a safer working environment. More information can be found at https://www.abertaytraining.co.uk.