HSE Reinforces COSHH Compliance for UK Food Sector

The Health and Safety Executive (HSE) has issued a fresh reminder to businesses within the UK food sector regarding their obligations under the Control of Substances Hazardous to Health (COSHH) Regulations 2002. This comes amidst ongoing efforts to ensure worker safety and prevent occupational ill-health, particularly in environments where cleaning agents, disinfectants, and other chemicals are routinely used.

Food production and catering environments, by their very nature, rely heavily on a range of substances that, if not properly controlled, can pose significant risks to employee health. From potent cleaning chemicals used for sanitisation to ingredients that may be allergenic or irritant, the potential for exposure is ever-present. The HSE's renewed focus aims to highlight the importance of thorough risk assessments, appropriate control measures, and comprehensive training.

Understanding COSHH in a Food Environment

COSHH regulations require employers to control exposure to hazardous substances to prevent ill-health. In the food sector, this includes, but is not limited to, substances such as:

  • Cleaning Chemicals: Detergents, sanitisers, degreasers, and disinfectants, many of which can cause skin irritation, respiratory issues, or chemical burns.
  • Flavourings and Additives: Certain natural and artificial flavourings can be respiratory sensitizers or skin irritants.
  • Dusts: Flour dust in bakeries is a well-known respiratory sensitizer, leading to occupational asthma. Grain dust and spice dusts also pose risks.
  • Gases: Carbon dioxide used in packaging or refrigeration, and ammonia in older refrigeration systems, can be hazardous if leaked.
  • Biological Agents: While less common under COSHH in this context, certain moulds or bacteria in food production could be considered if they pose a direct health risk to workers beyond food spoilage.

The HSE emphasises that a 'hazardous substance' isn't just a chemical with a hazard symbol. It can also include naturally occurring substances or process-generated substances like dusts. Employers must identify all such substances, assess the risks they pose, and implement effective controls.

Key COSHH Requirements for Food Businesses

Compliance with COSHH involves a systematic approach. The HSE outlines several critical steps that food businesses must undertake:

  1. Risk Assessment: Identify hazardous substances, assess who might be harmed and how, and evaluate the risks. This assessment should be specific to the tasks and substances used.
  2. Control Measures: Implement appropriate controls to prevent or adequately control exposure. The hierarchy of controls should always be followed:
    • Elimination: Can the hazardous substance be removed entirely?
    • Substitution: Can a less hazardous substance be used instead?
    • Engineering Controls: Local Exhaust Ventilation (LEV) to remove airborne contaminants, enclosed systems, or automated processes.
    • Administrative Controls: Safe working procedures, reduced exposure times, good housekeeping, and supervision.
    • Personal Protective Equipment (PPE): Gloves, eye protection, respiratory protective equipment (RPE). This should be the last resort after all other controls have been considered.
  3. Monitoring and Surveillance: Where appropriate, monitor exposure levels and conduct health surveillance for employees exposed to specific hazards, such as flour dust or sensitising chemicals.
  4. Information, Instruction, and Training: Provide employees with clear information about the hazards, risks, and control measures. Ensure they are properly trained in safe working procedures and the correct use of control equipment and PPE.
  5. Maintenance: Ensure all control measures, especially engineering controls like LEV, are properly maintained and regularly checked to ensure their effectiveness.

According to HSE statistics, occupational asthma, often linked to exposure to flour dust and other sensitizers, remains a significant concern in the food and drink manufacturing sector. In 2022/23, an estimated 13,000 new cases of breathing or lung problems were reported, with a substantial portion attributed to workplace exposures. This highlights the ongoing need for rigorous COSHH management.

Related training: If you are looking to qualify as a trainer in this area, see COSHH assessor training or explore working at heights trainer courses for nationally recognised UK and Ireland qualifications.

Recent Enforcement and Industry Best Practice

The HSE continues to conduct inspections and investigations across the food sector. Recent enforcement actions have included improvement notices and prosecutions for failures in COSHH management, particularly where inadequate ventilation or insufficient PPE has led to worker exposure. For example, a bakery was recently fined for failing to control exposure to flour dust, resulting in employees developing occupational asthma. This serves as a stark reminder of the legal and moral responsibilities employers hold.

Industry best practice goes beyond mere compliance. It involves fostering a proactive safety culture where employees are encouraged to report concerns and contribute to risk management. Regular reviews of COSHH assessments, especially after changes in processes, substances, or equipment, are also crucial. The British Retail Consortium (BRCGS) Global Standards for Food Safety also incorporate elements of COSHH, requiring sites to demonstrate effective management of chemicals and other hazardous substances.

Food businesses are encouraged to consult the HSE's extensive guidance on COSHH, including specific advice for sectors such as bakeries, catering, and food manufacturing. Utilising resources like safety data sheets (SDS) provided by chemical suppliers is fundamental for understanding the hazards and recommended control measures for each substance.

For businesses seeking to enhance their understanding and implementation of COSHH regulations, comprehensive training is invaluable. Abertay Training offers a range of health and safety courses, including specialised COSHH training, designed to equip individuals and organisations with the knowledge and skills necessary to manage hazardous substances effectively and ensure a safe working environment. More information can be found at https://www.abertaytraining.co.uk.