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Manufacturing Sector Workplan 2016-17: Musculoskeletal Disorders in food manufacturing


This outlines the 2016/17 FOD proactive inspection programme in food  manufacturing focusing on reducing significant health risks from Musculoskeletal disorders (MSDs) caused by manual handling (MH) and repetitive tasks, by ensuring the appropriate controls are in place.


MSDs are the primary cause of ill-health in all manufacturing sectors comprising 48% of all ill health cases, totalling approximately 1 million working days lost in 2014/15 . In food manufacture work-related MSDs are particularly prevalent. Ill health effects are either:

The purpose of the programme is to improve health outcomes by reducing the incidence of ill health from MSDs (lower back pain and upper limb disorders (ULDs)) caused by MH and repetitive tasks. ULDs are particularly problematic in food manufacturing accounting for approximately half of the sector’s MSD ill-health.

Most food manufacturing related musculoskeletal injuries arise from the following activities:



Premises should be selected using the SIC codes and other targeting information in the Organisation section of this OG, with sufficient visits planned for Quarter 3 and carried out before the end of December.

When setting up the COIN service order include keyword #healthcampaign1617 in the notes summary line.

FOD inspectors

The management of occupational health must be assessed in line with this OG when inspecting any premises within scope of the SIC codes targeted (see ‘Organisation’ section). When inspectors prioritise action in relation to Matters of Evident Concern (MEC) or Matters of Potential Major Concern (see OC18/12), further visits should be made to complete the actions below, as necessary. 

The SIC code recorded for the premises must be checked and, if necessary, amended to ensure the visit and findings are correctly analysed for sector insight and future targeting.

Inspectors should give priority to avoiding the risk (for manual handling tasks) and where this is not reasonably practicable, reducing the risk (i.e. control) and focus particularly on those common tasks where lack of avoidance or inadequate controls can result in an extreme or substantial risk gap under the EMM.

Inspectors should:

HSE’s MSD tools or an equivalent can be used by employers to help determine the level of risk.

Obtain Human factors support if required, especially if uncertain about whether avoidance is reasonably practicable, the level of actual risk or the extent of risk reduction required. Specialist advice is more likely to be needed for repetitive tasks where the level of risk and the required control measures can be less straightforward.

Send to Warren Pennington – Food Manufacturing Sector Lead - any information on good or poor practices found.

When inspecting bakeries, cake and biscuit manufacturing and grain milling sites for risks from MSDs, the risks from flour dust and enzyme exposure should also be assessed (see Workplan OG for occupational asthma and carcinogens in manufacturing premises inspection).

See further references section and appendices for guidance material.

Human Factor Specialist (with ergonomics background) inspectors

Provide support to FOD regulatory inspectors on the avoidance and reduction of risks from MH and ULD tasks if needed. Contact sector staff for details of current human factors specialists that can provide support.

Occupational Health Inspectors

Provide support to FOD regulatory inspectors on cases of ill-health and health surveillance issues if needed.

Sector staff

Provide support to FOD inspectors on benchmarking, risk gap and industry standards.


The Manual Handling Operations Regulations 1992 (as amended) is the primary legislation used to secure compliance for MH MSD risks. i.e. the transporting or supporting of a load (includes the lifting, putting down, pushing, pulling, carrying or moving) by hand or by bodily force.

The Management of Health and Safety at Work Regulations 1999 and the Workplace Health, Safety and Welfare Regulations 1992 are also relevant.

The Management of Health and Safety at Work Regulations 1999 and the Health and Safety at Work etc. Act 1974 is the primary legislation used to secure compliance for ULD MSD risks.

The Workplace Health, Safety and Welfare Regulations 1992 are also relevant.

EMM application to MSD risks

Guidance is available on the application of the EMM to health risks including MH and repetitive tasks

OC 313/4  describes the application of the MAC tool to various manual handling tasks to determine the risk gap and IEE.

When using the EMM for decisions on enforcement relating to MSDs you should consider:


Manual handling and repetitive tasks can result in serious  or significant ill health effects from MSDs


Failure to adopt appropriate control measures can result in exposures to MSDs with the possible risk of a serious or significant ill health effect. In most cases (apart from the lifting / carrying of extreme load weights where the ill-health effect can be serious) the ill health effect is significant.

Benchmark standard

The benchmark set is a nil or negligible risk of a serious or significant health effect. This benchmark can be achieved by applying the MHOR/MHSW hierarchy of control approach (Avoid, Assess, Reduce) for MH and ULD tasks with a risk of injury and then applying a variety of control measures including the provision and use of suitable mechanical handling aids/devices, reducing task risk factors (repetition, duration, force) and changing work organisation (position, environment, rotation) as well as the provision of suitable instruction, information, training.

Risk Gap

When the MAC tool is applied to MH tasks that present a risk of injury and the MAC load / weight frequency score is red (i.e. exposes most people to the risk of injury) AND either (i) hand distance from the lower back is red OR (ii) vertical lift is red and hand distance is amber OR (iii) trunk is twisted  -red, the resulting EMM risk gap is substantial and the standard is established. This results in the IEE of an Improvement Notice.

The same IEE is likely when applying the ART tool to highly repetitive, high force, long duration tasks that present a risk of injury. However as the level of risk and control measures required is less clear for ULDs then it is advisable to seek specialist advice.




Visits to be planned for Quarter 3 and carried out before the end of December.


Inspect sites nationally in-line with targeting.

Recording & Reporting

Inspections should be recorded in accordance with current work recording instructions (COIN/DOIT) and should include findings/comments about:

  1. Tasks presenting MSD risks (ULD/MH)
  2. Are the control measures used, checked and maintained
  3.  Specific control failings
  4.  Any management failings such as training, instruction etc.
  5. SG involvement
  6. Any material breach or enforcement action taken

If comment on the matters cannot be provided, please give a brief explanation of the reasons why not.

Health & Safety

HSE health and safety information for visits to food and drink manufacturing premises is available. Inspectors should follow the company’s procedures when visiting.


Be aware that agency and migrant workers form a significant proportion of the workforce in the food and drink manufacture industry and their first language may not be English.

HSE inspectors can access translation services for field visits and investigations.

Further References

Key guidance


MSD Guidance

Website links

Food Specific Industry Guidance

Website links



SD Human Sciences Unit, Human Factors Specialist

ESID Manufacturing, Transportation and Safety Unit (MTSU), food manufacturing

ESID Manufacturing, Transportation and Safety Unit (MTSU), Head of General Manufacturing and Musculoskeletal Disorder Policy


Appendix 1:  Bakeries/Cakes

The bakery/biscuit/cake industry is the largest food industry (approximately 70,000 workers in about 2,200 factories). 

Trade Association websites

Industry specific guidance

Appendix 2:  Meat and Poultry processing

The meat and poultry processing industry is the second largest food industry after bakeries (with approximately 65,000 workers in about 900 factories).

Trade Association websites

BMPA Guidance notes

Appendix 3:  Dairy/Cheese

The dairy processing industry is the fourth largest food industry (with approximately 25,000 employees workers in about 300 factories).

Trade Association

Industry specific guidance

Manual handling of milk trolleys is a significant risk and Dairy UK launched revised guidance in 2014 to promote moving one trolley unless risk assessment justifies moving two. Whilst pushing 2 trolleys from behind is considered acceptable, it is common practice in the industry for operators to push/pull trolleys from the side, which increases MSD risks significantly.

HSE ergonomists assessed the milk trolley handling task and identified significant risks associated with push/pull of 2 trolleys by 1 person from the side. Reports from the 2 visits in 2006 & 2008 are available on TRIM at 2015/0072759 and 2015/0072769.  These can be used to support enforcement action.
Updated 2016-07-27