HSE Sounds Alarm on Rising COSHH Breaches in UK Food Sector

The Health and Safety Executive (HSE) has issued a stark reminder to businesses within the UK's expansive food and drink manufacturing sector regarding the critical importance of complying with the Control of Substances Hazardous to Health (COSHH) Regulations 2002. This comes amidst concerns over a reported increase in incidents and enforcement actions related to inadequate control of hazardous substances.

Food and drink manufacturing remains one of the largest manufacturing sectors in the UK, employing over 470,000 people. While contributing significantly to the economy, it also presents a unique array of health and safety challenges, particularly concerning exposure to substances that can cause occupational asthma, dermatitis, and other respiratory and skin conditions. The HSE's renewed focus underscores the agency's commitment to reducing preventable harm in workplaces.

Key Hazardous Substances and Associated Risks

Within the food sector, hazardous substances are not limited to industrial chemicals. They encompass a broad spectrum, including:

  • Cleaning and Disinfection Agents: Caustic sodas, acids, hypochlorites, and quaternary ammonium compounds (QUATS) are commonly used for hygiene, posing risks of chemical burns, respiratory irritation, and sensitisation.
  • Flour Dust: A well-known cause of occupational asthma, particularly in bakeries and flour mills. The HSE estimates that around 2,000 new cases of occupational asthma are reported each year, with flour dust being a significant contributor.
  • Enzymes: Used in baking, brewing, and other processes, enzymes can be potent respiratory sensitizers.
  • Allergens: While not traditionally classified under COSHH in the same way as chemical hazards, the cross-contamination and airborne presence of food allergens (e.g., nuts, soy, dairy) can pose severe risks to sensitised employees, requiring similar control measures to prevent exposure.
  • Gases: Carbon dioxide in breweries or nitrogen in food freezing processes can pose asphyxiation risks if not properly managed.

The HSE emphasizes that employers have a legal duty under COSHH to protect their employees from these risks. This involves a hierarchical approach to control, starting with elimination or substitution of hazardous substances, followed by engineering controls (e.g., local exhaust ventilation), administrative controls (e.g., safe work procedures), and finally, personal protective equipment (PPE).

Recent Enforcement Actions and Industry Implications

Although specific recent statistics for COSHH breaches solely within the food sector are not independently published, the HSE's broader enforcement statistics highlight ongoing challenges. For the period 2022/23, the HSE issued 7,725 enforcement notices across all industries in Great Britain, with a significant proportion related to general health and safety failings that often include inadequate control of hazardous substances. Prosecutions also resulted in £14.3 million in fines. These figures serve as a stark reminder of the financial and reputational consequences of non-compliance.

A recent HSE prosecution in the North West saw a food manufacturer fined £200,000 after an employee suffered severe chemical burns due to inadequate training and faulty equipment during a cleaning process involving caustic chemicals. This case exemplifies the direct consequences of failing to implement robust COSHH management systems.

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The HSE's guidance, 'COSHH essentials for the food and drink industries' (HSG253), provides practical advice tailored to the sector. It outlines the steps required for a suitable and sufficient risk assessment, including identifying hazards, deciding who might be harmed and how, evaluating risks, and recording findings. Crucially, it also stresses the importance of regular review and update of these assessments.

Proactive Steps for Businesses to Ensure Compliance

To mitigate risks and ensure compliance, businesses in the food sector should:

  • Conduct Thorough COSHH Assessments: Systematically identify all hazardous substances, assess exposure risks, and determine appropriate control measures.
  • Implement Control Measures: Prioritise elimination, substitution, engineering controls (e.g., enclosed systems, ventilation), and administrative controls (e.g., safe work procedures, reduced exposure times).
  • Provide Comprehensive Training: Ensure all employees who work with or near hazardous substances receive adequate information, instruction, and training on the risks involved and the control measures in place. This includes emergency procedures.
  • Regularly Monitor and Review: Periodically check the effectiveness of control measures and review COSHH assessments, especially after any changes in processes, substances, or incidents.
  • Ensure Health Surveillance: Where appropriate, implement health surveillance programs for employees exposed to substances known to cause occupational diseases, such as respiratory sensitizers.

The HSE reiterates that prevention is always better than cure. By taking a proactive approach to COSHH compliance, food sector businesses can protect their workforce, avoid costly enforcement actions, and maintain operational efficiency.

For businesses seeking to enhance their understanding and compliance with COSHH regulations, comprehensive training is essential. Abertay Training at https://www.abertaytraining.co.uk offers a range of health and safety courses, including COSHH awareness and risk assessment training, designed to equip employers and employees with the knowledge and skills necessary to manage hazardous substances effectively and ensure a safer working environment.