42 HEALTH AND SAFETY ISSUES – Food and Drink – Good Manufacturing Practice, 7th Edition



In the Introduction, the intention was made clear to limit this Guide to matters having a direct bearing on the scientific, technological and organisational aspects affecting the quality and safety of products. For this reason, detailed consideration has not been given to the safety and welfare of operatives (except insofar as their health and personal hygiene bears directly on the quality and safety of products). It is, however, acknowledged here that the management of any food manufacturing operation has general responsibility and, in most countries, legal obligations (with which it must be familiar) for the health and safety of its employees.


42.1 In the UK, the Health and Safety at Work Act 1974 is the primary piece of legislation covering occupational health and safety. The Act applies not only to employees but also to members of the public, including customers, visitors and contractors. A duty is placed on employers with more than five employees to develop and implement a written health and safety policy. Statutory instruments are secondary pieces of legislation made under specific Acts of Parliament that address specific health and safety issues. The range of health and safety legislation that food manufacturers must comply with is too complex to outline in this chapter. However, food manufacturers must have a formal, appropriate and effective health and safety management system that ensures health and safety issues are minimised. For comprehensive support with regard to the requirements for health and safety management within a manufacturing unit see the Health and Safety Executive (HSE) website (www.hse.gov.uk).

42.2 The main causes of injury in a food manufacturing environment include manual handling injuries, slips on wet or food‐contaminated floors, falls from heights, workplace injuries including those involving fork‐lift trucks, injuries associated with food processing machinery, packaging machinery and being hit by a falling object, for example from racking, contact with harmful substances, or being injured by tools used, such as knives. The risks associated with a given food manufacturing environment are specific to the foods being processed and the tasks being undertaken, for example the use of ovens and heat‐related injuries or risk of dust explosions is very specific to one type of food manufacture and not another. The food manufacturer therefore needs to consider all potential health and safety hazards and undertake a formal risk assessment to ensure that these risks are managed effectively and the risk of minor and major injury is reduced.

42.3 The main occupational health issues in a food manufacturing environment are musculoskeletal injuries, including back injuries, dermatitis from repeated handwashing or contact with certain foodstuffs, excessive noise that affects hearing, i.e. where noise levels exceed 85 dB(A), occupational asthma, for example from dust, occupational dermatitis and rhinitis, for example from dust, spices or seasonings, and work‐related stress. The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) 2013 require employers, the self‐employed and people in control of work premises (identified as the ‘responsible person’) to report certain serious occupational diseases, specified dangerous occurrences (near misses) and serious workplace accidents, for example a fatality to the Health and Safety Executive within a prescribed timescale from the date of the incident. Specified incidents that must be reported, known as RIDDOR, include burns, fractures, amputations, and any injury leading to blindness, loss of consciousness or admittance to hospital. For a full list of injuries and occupational diseases that are subject to RIDDOR see http://www.hse.gov.uk/riddor/reportable‐incidents.htm.

42.4 In the UK, the Control of Substances Hazardous to Health (COSHH) Regulations 1999, amended in 2002, introduced a requirement for employers to carry out a formal assessment of all work that is liable to expose employees to hazardous substances, including chemicals, liquids, solids, vapours, fumes, mists, dusts, nanotechnology and biological agents, including microorganisms. The formal COSHH assessment must evaluate the risks to health and the actions that are required to minimise that risk. More information is available from the HSE website.

42.5 A responsible person must be appointed by the manufacturer to have overall responsibility for the health and safety management system. They are responsible for the operation of an effective health and safety management system and for implementing the health and safety strategy drawn together by senior management. Senior management are responsible for providing adequate resources to ensure that the health and safety management system can be effectively implemented and that the safety of workers is assured. The responsible person and other key individuals identified in the health and safety management system must be competent and have had appropriate training and support to ensure that they have the knowledge and skills required so that they can fulfil their responsibilities. The training and qualifications must be of sufficient quality and at a sufficient level that is commensurate with the individual’s responsibilities, for example the Institute of Occupational Safety and Health suite of qualifications. Documentation should be developed in line with the general guidance given in Chapter 13. When electronic or magnetic recording methods are used, see also Chapter 39.