HSE Calls for Renewed Focus on COSHH in UK Food Industry

The Health and Safety Executive (HSE) has issued a fresh reminder to businesses within the UK's expansive food and drink manufacturing sector regarding their obligations under the Control of Substances Hazardous to Health (COSHH) Regulations 2002. This comes amidst ongoing concerns about persistent breaches related to the safe handling and storage of hazardous substances, which pose significant risks to worker health.

The food and drink industry, a cornerstone of the UK economy, employs over 440,000 people. However, it also presents a unique array of COSHH challenges, from potent cleaning agents used in hygiene protocols to process-generated contaminants like flour dust and flavourings, and even allergenic ingredients. The HSE's latest guidance underscores the critical need for robust risk assessments, effective control measures, and comprehensive employee training to mitigate these hazards.

Key Hazardous Substances in Food & Drink Manufacturing

Workers in the food and drink sector are routinely exposed to a variety of substances that, if not properly controlled, can lead to serious health issues. The HSE highlights several common culprits:

  • Cleaning and Disinfection Chemicals: Caustic sodas, acids, hypochlorite solutions, and quaternary ammonium compounds (QUATS) are widely used for sanitation. These can cause skin irritation, chemical burns, respiratory problems, and eye damage if mishandled or if ventilation is inadequate.
  • Flour Dust: Particularly in bakeries and flour mills, exposure to flour dust can lead to occupational asthma, a leading cause of work-related respiratory disease in the UK. The HSE estimates that around 1,500 new cases of occupational asthma are reported each year, with a significant proportion linked to flour.
  • Allergenic Ingredients: While primarily a food safety concern for consumers, airborne dust from allergenic ingredients (e.g., nuts, soy, dairy, gluten) can also pose a COSHH risk to employees who may develop sensitisation or suffer allergic reactions upon inhalation or skin contact.
  • Enzymes: Used in various food processes (e.g., baking, brewing), enzymes can be potent respiratory sensitizers, leading to asthma.
  • Carbon Dioxide: Used in packaging, chilling, and carbonation, CO2 can displace oxygen and lead to asphyxiation in confined spaces if not properly managed.
  • Fumes and Vapours: From cooking oils, solvents used in flavourings, or even welding in maintenance, these can irritate respiratory systems or cause other adverse health effects.

The HSE's latest statistics reveal that occupational lung diseases, often linked to COSHH breaches, account for approximately 12,000 deaths annually in the UK. This stark figure reinforces the imperative for employers to take their COSHH responsibilities seriously.

Employer Responsibilities Under COSHH Regulations 2002

The COSHH Regulations 2002 place clear duties on employers to protect their employees from hazardous substances. The HSE advises businesses to follow a systematic approach, often summarised as the '8-step COSHH assessment':

  1. Assess the Risks: Identify hazardous substances, who might be harmed, and how. Review Safety Data Sheets (SDS) for all chemicals.
  2. Decide on Precautions: Determine what control measures are necessary.
  3. Prevent Exposure: Prioritise eliminating the hazardous substance or substituting it with a safer alternative.
  4. Control Exposure: If prevention isn't possible, implement adequate control measures. This includes engineering controls (e.g., local exhaust ventilation – LEV), administrative controls (e.g., safe work procedures, segregation), and personal protective equipment (PPE) as a last resort.
  5. Maintain, Examine and Test Controls: Ensure control measures, especially LEV systems, are regularly checked, maintained, and tested (e.g., LEV systems require statutory examination and testing at least every 14 months, as per HSG258).
  6. Monitor Exposure: Where necessary, carry out workplace air monitoring or health surveillance to check the effectiveness of controls.
  7. Health Surveillance: Provide appropriate health surveillance for employees exposed to certain substances (e.g., sensitizers like flour dust).
  8. Information, Instruction and Training: Ensure all employees who work with or near hazardous substances receive adequate information, instruction, and training on the risks and control measures.

Failure to comply with COSHH regulations can result in significant penalties, including fines and imprisonment, as well as the devastating human cost of occupational ill-health. The HSE conducted 7,126 prosecutions in 2022/23, with fines totalling over £24.7 million, underscoring their commitment to enforcement.

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

Proactive Measures and Future Outlook

The HSE continues to advocate for a proactive approach to COSHH management within the food and drink sector. This includes encouraging businesses to engage with industry-specific guidance, participate in HSE-led initiatives, and foster a strong safety culture where employees feel empowered to report concerns without fear of reprisal.

Technological advancements, such as improved LEV systems, automated cleaning processes, and real-time air monitoring, are also playing an increasing role in enhancing COSHH compliance. However, the human element – informed decision-making, diligent supervision, and ongoing training – remains paramount.

The message from the HSE is clear: COSHH is not a 'tick-box' exercise but a continuous process of risk management essential for protecting the health of the workforce and ensuring the sustainability of the UK's vital food and drink industry. Employers are urged to review their current practices, update risk assessments, and invest in appropriate control measures and training to meet their legal and moral obligations.

For organisations seeking to enhance their COSHH compliance and ensure their workforce is adequately trained, Abertay Training offers a comprehensive range of health and safety courses. Learn more about their offerings at https://www.abertaytraining.co.uk.