Health and Safety
Executive / Commission
Local authority circulars
To: Directors of Environmental Health/ Chief Environmental Health Officers of London, Metropolitan, District and Unitary Authorities and Chief Executives of County Councils.
For the attention of: Environmental Services /Trading Standards /Fire Authorities /Other
This circular gives advice to local authority enforcement officers
| LA health and safety enforcement officers are asked to proactively engage with duty holders in flour dust management issues. This work will contribute directly to the Disease Reduction Programme (DRP). |
1. This LAC introduces an inspection intervention to improve good practice amongst those exposed to flour dust and dust from enzyme-containing flour additives in bakeries and other food preparation premises where flour is used .
2. The Disease Reduction Programme aims to contribute to ill‑health reduction targets by achieving a 2.4% reduction in the incidence of chemically induced ill health. The Respiratory Disease and Skin Disease Projects aim to achieve a 10% reduction in the incidence of occupational asthma and dermatitis by 2007/8 compared with 2003/4.
3. Flour dust is a hazardous substance as defined under the Control of Substances Hazardous to Health (COSHH) Regulations 2002. It is a respiratory sensitiser and is known to cause allergic rhinitis and occupational asthma. Flour dust is also an irritant and may give rise to short term respiratory, nasal and eye symptoms. It may provoke an asthmatic attack in individuals with pre-existing disease and lead to chronic bronchitis. The Workplace Exposure Limit (WEL) is 10mg/m 3 (8-hr TWA) with a Short Term Exposure Limit (STEL) of 30mg/m 3 (15 minute reference period).
4. Flour, flour additives and spices may also act as skin irritants but perhaps more commonly the handling of moist doughs, frequent hand washing, and exposure to detergents are the predominant cause of irritant contact dermatitis within the bakery industry. Flour is also a skin sensitiser.
5. There are about 4,500 small craft bakeries in the UK, each employing typically between 5 and 25 people, 350 medium sized bakeries (employing between 25 and 100 people) and 150 large plant bakeries (employing more than 100 people). About 27 000 workers are exposed to flour dust in the baking and associated trades.
6. In support of the review of the flour dust limit, HSE and the Health and Safety Laboratory, Buxton, carried out a national project to ascertain the impact the then Maximum Exposure Limit (MEL) had made on bakers in terms of their understanding of the issue, control of flour dust and health surveillance. Generally it was found that there had been little change since a similar project 10 years ago in Scotland, which showed that bakery workers suffered widespread occupational ill health related to significant levels of flour dust exposure. The recent survey confirmed that this picture was repeated nationally.
7. To support this intervention, health and safety officers are asked to carry out inspections in bakeries and other food preparation premises where flour is used, concentrating on controlling exposure to flour dust. There are two strands to this intervention, one targeting small bakeries, the other targeting medium sized and plant bakeries.
8. Small bakeries and other food preparation premises where flour is used – LA Health and Safety Officers and HSE Health & Safety Awareness Officers (HSAOs) are asked to visit small bakeries and other food preparation and manufacturing premises where flour is used , which fall within their field of responsibility. Many of these visits will be outside normal hours (ie night shift) and may need to be planned in advance in order to inspect premises when ‘floury’ products are being produced.
9. There is a national initiative (the Large Organisation Pilot Project) ongoing with large companies and officers may therefore wish to choose companies other than those participating in the LOPP for inspection under this project this year.
10. Plant and Medium Sized Bakeries –a proportion of these will be visitedby HSEinspectors to evaluate flour dust control systems and the provision of health surveillance in plant bakeries.
11. While advice and information from inspectors/officers is a key part of the project, it should be remembered that many bakers have been made aware of the flour dust/asthma issue in the past, not only by enforcing authorities but also through their trade associations and the trade press. Poor compliance should normally result in enforcement action being taken.
12. Any enforcement action taken should reflect the new emphasis in Regulation 7 of COSHH 2002 (as amended) to apply the principles of good control practice when controlling exposure to substances hazardous to health – Schedule 2A provides details on what is required.
13. Reporting activity and impact - Whilst planning and doing Fit3 work is obviously important, it is no less important to feedback on your activities and outcomes. This is to allow the progress all enforcing authorities are making towards the Disease Reduction Programme (DRP) objectives to be monitored (and where necessary, refocussed and /or be better supported). It is also invaluable information for HSC/HELA/LAU to have when responding to interest from Ministers and keeping them and the Local Better Regulation Office (LBRO) updated on the achievements of the LA/HSE partnership in delivering [DRP and] the Fit3 programme in general.
There are a number of ways in which you can record your activities and achievements both quantitatively and qualitatively:
You may wish to use more than one of these ways of recording your activity.
14. The primary objective where a WEL is in force is to prevent the material becoming airborne in the first place. In larger bakeries good engineering control should control dust to acceptable limits. There is normally scope for using local exhaust ventilation (LEV) at the dustier processes and this should be encouraged. Such control should also be considered in smaller bakeries where practicable. Other simple controls can be effective such as lids on mixing vessels and vacuuming spills rather than brushing.
15. In bakeries without automation some tasks produce greater exposure than others, including bag slitting and tipping, sieving, weighing and mixing. Simple changes in work practices can greatly reduce exposure at these and other tasks.
16. Information on controls and good working practices can be found in HSE publication HSG233 A Baker’s Dozen which includes the ‘Ten top tips for bakers’. Also relevant are the COSHH Essentials flour control guidance sheets (www.coshh-essentials.org.uk), the Federation of Bakers (FoB) booklet Guidance on Dust Control and Health Surveillance in Bakeries (also known as the Blue Book) available from the FoB.
17. A ‘control’ topic pack is being prepared by HSE advising on areas/activities where specific controls can be applied. In addition, HSE is providing training for LA Health & Safety Officers at ten venues around the country during May/June 2006.
18. Health surveillance must be carried out, as flour dust and improvers including amylase are respiratory sensitisers. The level of surveillance required is described in HSG233, Chapter 2. One of the most common responses from smaller bakers is that Occupational Health help and advice is difficult to obtain, if so, the HSE Employment Medical Advisory Service should be contacted for help via the HSE Enforcement Liaison Officer
19. Guidance on dermatitis can be found in HSE’s free Food Information Sheet 17 Occupational dermatitis in the catering and food industries.
20. For further information please HSE, Agriculture and Food Sector Section, Pegasus House, 375 West George Street, Glasgow G2 4LW Tel no. 0141 275 3111