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8 Point checklist: How food manufacturers can prepare for inspection

20/03/2018

8 Point checklist: How food manufacturers can prepare for inspection

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8 Point checklist: How food manufacturers can prepare for inspection

The Health and Safety Executive (HSE) has stated that it will be launching  a series of unannounced inspections focusing on the Food and Beverage industry.  We take a look at how you can best prepare for them.

The dangers of flour

When you think about occupational respiratory illnesses, what sort of hazards do you think of?  Coal dust in mines? Silica dust in quarries?  Asbestos in any building built pre-2000?  What might not come to mind is flour.  Flour makes you think of delicious pastries, tempting cakes, crispy biscuits and fresh-baked bread. Not occupational illness.  And yet, exposure to flour dust is the second most common cause of occupational asthma in the UK.  Workers in bakeries, grain mills, and other places using flour are all at risk unless appropriate precautions are taken.

Occupational lung diseases are estimated to cause around 12,000 deaths each year in the UK – dwarfing the number of deaths from workplace accidents in 2016/17 of 137.  The percentage of cases attributable to isocyanates, although higher than that for flour, has gone down over the past 10 years, whilst the percentage due to flour has stayed at the same level.  If nothing is done, flour could become a greater killer than isocyanates.  Flour is also linked to other debilitating conditions from dermatitis, rhinitis and irritable eyes, to Chronic Obstructive Pulmonary Diseases (COPD) such as emphysema.

HSE Inspections

The HSE has decided it is time to do more about this problem, and in January it announced that it was starting a programme of unannounced inspections of food manufacturing businesses across the UK. Its top priority for inspections will be a focus on occupational lung disease, including asthma, as well as on musculoskeletal disorders caused by manual handling.

The HSE are not coming in for a chat.  They are coming to enforce.  Their press release makes clear “The inspections will ensure measures are being taken by those responsible to protect workers against health risks and HSE will not hesitate to use enforcement to bring about improvements.”  Enforcement could mean a fee for intervention (FFI), an improvement or prohibition notice – or even a full scale, expensive prosecution. As previous cases have shown, the HSE do not need evidence of ill-health to make a prosecution – just evidence that a hazard is not adequately controlled.

Checklist

So what should you do about it?  The following checklist suggests some of the evidence the HSE will be looking for if they come calling:

  1. Do you have a suitable and sufficient risk assessment? If you use flour (or any other respirable hazard) your risk assessments must identify where it is used, and which people might be exposed (for example, listed by role). A risk assessment that just lists “flour” as the hazard and “be careful” and “wear PPE” as the controls will not be regarded as sufficient. Manufacturers should also be aware of what else the flour contains – additives in flour, particularly those containing enzymes, can increase the problem. Flour is not the only food product to be aware of – in 2001 the HSE concluded that coffee bean and soybean dust, egg and fish proteins as well as other additives used in food processing can also cause asthma.
  2. Your risk assessment will identify controls, and these should focus on measures at the top of the hierarchy. Have you done everything practical to eliminate and isolate dust before you start offering dust masks?  For example, are ingredients available in a liquid form rather than a powder?
  3. Your controls are likely to include extraction equipment (such as local exhaust ventilation) to take the dust out of the air. Can you present clear records of regular servicing and inspection for the equipment?
  4. Where controls rely on people, have these been documented, for example in method statements or procedures? HSE inspectors are likely to look more closely where flour is added to a process by hand (rather than mechanised and enclosed) or used for dusting, and at what happens during maintenance and breakdowns.  The HSE has a colourful summary of some of the poor behaviours inspectors will be looking out for.
  5. Is there evidence that people who need to apply the controls have been trained appropriately? The HSE might want to see records of training, referring to the procedures, and to any additional refresher training provided.
  6. Where there is still a residual risk that needs to be controlled with respiratory protective equipment (RPE), you need to be able to show how you went about choosing the right sort of RPE, that people have been shown how to put it on and take it off correctly, how to check that it is fitted correctly and what to do with it in between use.
  7. What monitoring records can you show the HSE? Do you have any evidence to show that you make sure the RPE is used?  Do you have stationary or personal monitors (or both) to check the dust content in the air?  Flour is defined as a hazardous substance under COSHH regulations, so you need to be able to show you are complying with workplace exposure limits (WEL) for long-term and short-term exposure.
  8. It is important to tackle the problem early – once someone has become sensitised to flour dust, even a small quantity can bring on an asthma attack. Do staff know what symptoms to look for and how to report them? The HSE might ask to see your health surveillance programme, so make sure you’ve something to show them.

Our risk assessment software can help you to be prepared for any inspection.  If you are interested in finding out more, contact us today.

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