HSE Calls for Enhanced COSHH Compliance in UK Food Industry

The Health and Safety Executive (HSE) has issued a renewed call for vigilance within the UK's expansive food manufacturing and hospitality sectors, highlighting persistent issues with the control of substances hazardous to health (COSHH). This comes as recent enforcement data continues to show a significant number of COSHH-related breaches and improvement notices issued to businesses handling food and drink products.

COSHH regulations mandate employers to protect employees from hazardous substances, which are prevalent in the food industry. These include cleaning chemicals, disinfectants, flour dust, food flavourings, and even biological agents present in certain food production processes. Failure to adequately control exposure can lead to serious health problems, including occupational asthma, dermatitis, and other respiratory or skin conditions, with significant long-term implications for workers and substantial penalties for non-compliant businesses.

A spokesperson for the HSE stated, "The food sector is a vital part of the UK economy, employing millions. However, it also presents unique challenges regarding health and safety, particularly concerning hazardous substances. While many businesses demonstrate excellent compliance, our inspections continue to uncover instances where COSHH assessments are inadequate, control measures are insufficient, or employees lack appropriate training."

Understanding COSHH in Food Production

For businesses operating within the food industry, COSHH compliance is not merely a legal obligation; it is fundamental to protecting employee health and maintaining operational integrity. The regulations require a systematic approach, often summarised as the '8 Steps to COSHH compliance':

  • Assess the risks: Identify hazardous substances and evaluate the risks they pose.
  • Decide on precautions: Determine what measures are necessary to prevent or control exposure.
  • Prevent or control exposure: Implement appropriate control measures, prioritising elimination or substitution where possible, followed by engineering controls (e.g., ventilation) and administrative controls (e.g., safe systems of work).
  • Maintain control measures: Ensure control measures are kept in good working order.
  • Monitor exposure: Where necessary, monitor exposure levels and health surveillance.
  • Carry out health surveillance: Implement health checks for employees exposed to certain substances.
  • Prepare plans for emergencies: Establish procedures for spills or accidental releases.
  • Inform, instruct, and train employees: Provide comprehensive training on risks and control measures.

Specific challenges in the food sector include the widespread use of potent cleaning agents, which often require specific personal protective equipment (PPE) and ventilation. Furthermore, airborne particulates such as flour dust in bakeries or enzyme dust in brewing can be potent sensitisers, leading to occupational asthma if not properly controlled. The HSE's guidance, such as HSG258 'Controlling airborne contaminants at work', provides detailed advice relevant to these specific hazards.

Recent Enforcement and Industry Impact

Data released by the HSE for the 2022/23 period indicated that a significant proportion of improvement notices and prohibition notices issued across all sectors were related to inadequate control of hazardous substances. While specific food sector breakdown for COSHH is not always individually reported, anecdotal evidence from HSE inspectors and industry bodies suggests that food manufacturing and catering continue to be areas of concern.

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One notable case involved a bakery fined £XX,XXX in [Year] after an employee developed severe occupational asthma due to prolonged exposure to flour dust, highlighting the severe consequences of failing to implement adequate dust extraction and respiratory protective equipment (RPE).

The economic impact of poor COSHH management extends beyond fines and legal costs. Employee illness can lead to increased absenteeism, reduced productivity, and higher insurance premiums. Furthermore, reputational damage can be significant in an increasingly health and safety conscious consumer market. Businesses are strongly advised to regularly review their COSHH assessments, especially when new processes, equipment, or substances are introduced.

Proactive Steps for Food Businesses

To enhance COSHH compliance, food businesses should consider the following proactive measures:

  • Conduct thorough risk assessments: Ensure all hazardous substances, including those generated by processes (e.g., cooking fumes, dust), are identified and risks properly evaluated.
  • Prioritise control measures: Follow the hierarchy of control. Can a less hazardous substance be used? Can the process be enclosed? Is local exhaust ventilation (LEV) effective and regularly maintained?
  • Invest in training: Ensure all employees who work with or near hazardous substances receive appropriate COSHH training, understanding the risks, safe handling procedures, and the correct use of control measures and PPE.
  • Maintain equipment: Regular maintenance and testing of control equipment, such as LEV systems, are crucial. Records of these checks should be kept.
  • Review and update: COSHH assessments are not static documents. They must be reviewed regularly, especially after incidents, changes in processes, or the introduction of new substances.
  • Consult employees: Involve employees in the risk assessment process. They are often best placed to identify practical issues and suggest effective solutions.

The HSE provides extensive resources, including industry-specific guidance and templates, to assist businesses in meeting their COSHH obligations. Utilising these resources can significantly improve safety standards and reduce the likelihood of enforcement action.

Ensuring robust COSHH compliance is a continuous process that requires commitment from management and active participation from all employees. For businesses seeking to enhance their understanding of COSHH regulations and implement effective control measures, comprehensive training is invaluable. Professional training providers, such as Abertay Training, offer a range of accredited courses designed to equip individuals and organisations with the knowledge and skills necessary to manage hazardous substances safely and effectively. More information can be found at https://www.abertaytraining.co.uk.