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HSE to inspect all Food Manufacturers starting April 2015

View profile for Phil Cookson
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This information has kindly been provided by the British Frozen Food Federation

ALL food manufacturers will be inspected by HSE between April '15 and April '16. Their inspections will start with food producers within the categories of Bakeries/ Cakes/ Dairy/ Cheese/ Meat and Poultry Processing. They will then look at other food manufacturing sites.

The focus of their inspections will revolve around the management of Musculoskeletal disorders in food and drink manufacturing and also the management of occupational asthmagens and carcinogens in manufacturing industries.

Their pro-active inspection programme will involve the following:

Focus Area 1- Controlling significant health risks from Musculoskeletal disorders caused by manual handling (MH) and repetitive tasks

Inspectors will be:

  • Assessing the management arrangements for control of MSD risks in accordance with the requirements of the Manual Handling Operations Regulations hierarchy and the Management of Health, Safety at Work Regulations and Workplace, Health, Safety and Welfare Regulations.
  • Checking whether suitable and sufficient risk assessments have been carried out for tasks involving MH and repetitive movements. MAC, ART (and VMAC when available) tools should be used to help determine the level of risk.
  • Checking that suitable control measures have been provided for MH tasks where MSD risks are significant and task cannot be avoided e.g. by provision of mechanical handling aids/ devices and job/ workplace design.
  • Checking that suitable control measures have been provided for repetitive tasks where the risk of ULDs is significant and cannot be avoided (mechanised) by reducing task risk factors (repetition, duration, force) and changing work organisation (position, environment, rotation).
  • Checking that relevant employees have been provided with adequate task specific information, instruction and training on MSD risks from MH or repetitive tasks and the correct use of all control measures (equipment and systems) have been provided.
  • Investigating what health surveillance programmes are in place.
  • When inspecting bakeries, cake and biscuit manufacturing sites the risks from flour dust and enzyme exposure should also be assessed

The benchmark they have set for these inspections is nil or negligible risk of a serious injury or health effect. They have stated that non-compliance with the benchmark standards (set by the MAC or ART tool) will produce at least a ‘substantial risk gap’ with standards established or defined. This would result in an initial enforcement expectation of an Improvement Notice.

Focus Area 2- Occupational asthmagens and carcinogens in manufacturing industries

Flour dust and enzymes are the main asthmagens and/or carcinogens relating to our industry that they are focusing on and they are targeting manufactures of bread, fresh pastry goods, cakes, rusks, biscuits and bakeries for this campaign.

Inspectors will be:

  • Assessing the management arrangements for control of the risks from exposure to asthmagens and carcinogens;
  • Checking whether a suitable and sufficient risk assessment has identified asthmagens and/ or carcinogens present in the workplace;
  • Checking whether the assessment identified control measures to reduce exposures as low as reasonably practicable;
  • Checking whether the appropriate control measures, including extraction and/ or respiratory protective equipment (RPE), to protect employees from exposure to astmagens and/ or carcinogens are in place and being used;
  • Checking if employees potentially exposed to asthmagens and/ or carcinogens have received adequate training in the health risks associated with exposure and the correct use of equipment provided to control the risk;
  • Checking if the LEV systems are:
    • Suitable for the purpose for which they are being used;
    • Visually effective in extracting contaminant;
    • Used properly by the worker;
    • Supplied with a user manual and maintenance log book;
    • Damaged or have weak points, including damaged ducting or use gaffer tape to repair damage;
    • Maintained and inspected by a competent person (at least every 14 months);
  • Checking RPE is
    • Appropriately selected;
    • Provided with face fit testing (if appropriate)
    • Used;
    • Maintained
  • Checking RPE is being examined at suitable intervals; there is no specific time limit but taking into account:
    • The environment the respirator is being used in;
    • The manufacturer’s instructions;
    • The amount of use when setting an appropriate maintenance schedule;
  • Checking cleaning methods for RPE are used;
  • Checking if health surveillance is provided where appropriate;
  • Checking if air monitoring has been carried out, and if not confirm that the decision can be justified

The benchmark they have set for these inspections is a nil or negligible risk of a serious health effect. They state that this benchmark can be achieved by applying the COSHH principles of good control practice and using a variety of engineering control measures, provision and use of suitable RPE, plus the provision of suitable instruction, information, training and health surveillance.