HSE Intensifies Focus on COSHH Compliance in UK Food Sector

The Health and Safety Executive (HSE) has issued a renewed call for food businesses across the United Kingdom to rigorously review and update their compliance with the Control of Substances Hazardous to Health (COSHH) Regulations 2002. This comes as the regulator signals an increased focus on chemical safety within the food manufacturing, catering, and retail sectors, prompted by ongoing enforcement activities and a commitment to reducing work-related ill health.

Chemicals, ranging from cleaning agents and disinfectants to flavourings and processing aids, are ubiquitous in the food industry. While essential for hygiene and production, they pose significant risks if not managed correctly. Exposure can lead to various health issues, including dermatitis, asthma, and other respiratory diseases, which continue to be a leading cause of occupational ill health in the UK.

Understanding COSHH in the Food Industry Context

COSHH regulations mandate employers to protect their employees from the risks associated with hazardous substances. For food businesses, this extends beyond obvious industrial chemicals to include substances like flour dust, enzymes, and even some natural allergens that can become hazardous when airborne or handled improperly. The HSE emphasises that a robust COSHH assessment is not merely a tick-box exercise but a dynamic process requiring continuous review.

  • Identification: Businesses must identify all hazardous substances used or produced in their operations. This includes reviewing Safety Data Sheets (SDS) for all products.
  • Assessment: A thorough risk assessment must be conducted to determine who might be harmed, how, and what precautions are needed.
  • Control Measures: Implement effective control measures to eliminate or reduce exposure. This hierarchy of controls prioritises elimination, substitution, engineering controls (e.g., ventilation), administrative controls (e.g., safe work procedures), and finally, Personal Protective Equipment (PPE).
  • Monitoring and Review: Control measures must be regularly monitored to ensure their effectiveness, and assessments should be reviewed periodically or when processes change.
  • Information, Instruction, and Training: Employees must receive adequate information, instruction, and training on the risks and control measures.

Key Areas of Concern and Recent Enforcement Trends

The HSE's latest enforcement data indicates a consistent pattern of non-compliance in specific areas within the food sector. Common failings include inadequate risk assessments, poor ventilation systems, insufficient provision or use of appropriate PPE, and a lack of proper training for staff handling hazardous substances.

For instance, recent enforcement actions have highlighted issues with bakeries failing to control flour dust exposure, leading to occupational asthma. Similarly, catering establishments have faced scrutiny over the safe handling and storage of strong cleaning chemicals, where inadequate ventilation or incorrect dilution practices have presented risks of respiratory irritation and skin burns.

According to the latest HSE statistics for 2022/23, there were 1.8 million working people suffering from work-related ill health, of which 13,000 deaths each year are estimated to be linked to past exposure to chemicals or dust at work. While not solely attributable to the food sector, these figures underscore the pervasive nature of chemical hazards and the critical importance of COSHH compliance across all industries, including food.

Related training: If you are looking to qualify as a trainer in this area, see DSE assessor training or explore food hygiene trainer qualifications for nationally recognised UK and Ireland qualifications.

The HSE has been clear that it will not hesitate to take enforcement action, including issuing Improvement Notices, Prohibition Notices, and prosecutions, where serious breaches are found. Fines can be substantial, and convictions can also lead to significant reputational damage for businesses.

Practical Steps for Food Businesses to Enhance COSHH Compliance

To proactively address the HSE's concerns and ensure a safe working environment, food businesses should consider the following practical steps:

  1. Conduct a Comprehensive Audit: Systematically review all chemicals and hazardous substances used or generated on-site. This includes cleaning products, pest control agents, ingredients (e.g., flour, spices), and by-products.
  2. Update Risk Assessments: Ensure all COSHH risk assessments are up-to-date, specific to the tasks performed, and reflect current working practices. Pay particular attention to substances that can become airborne, such as dusts and mists.
  3. Review Control Measures: Verify that engineering controls (e.g., Local Exhaust Ventilation - LEV systems for flour dust or steam) are effective and regularly maintained. Check that administrative controls (e.g., safe operating procedures, restricted access) are being followed.
  4. PPE Assessment: Re-evaluate the suitability and effectiveness of PPE. Ensure it is correctly selected, properly maintained, and that employees are trained in its correct use, storage, and disposal.
  5. Training and Communication: Provide regular, comprehensive training to all employees who work with or near hazardous substances. This training should cover the risks, control measures, emergency procedures, and the correct use of PPE. Ensure Safety Data Sheets (SDS) are readily accessible and understood.
  6. Emergency Procedures: Review and practice emergency response procedures for chemical spills or exposures. Ensure first-aid provisions are adequate and personnel are trained.
  7. Consultation: Engage with employees and their representatives on COSHH matters. Their input can provide valuable insights into practical risks and control effectiveness.

By taking these proactive measures, food businesses can not only safeguard the health of their employees but also ensure compliance with legal obligations and avoid potential enforcement actions.

Staying informed about the latest health and safety regulations and best practices is crucial for all businesses. For comprehensive training and consultancy services in COSHH and other critical health and safety areas, including bespoke solutions for the food sector, consider visiting Abertay Training at https://www.abertaytraining.co.uk.