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Workplan 2016-17: Inspecting the poultry industry

Summary

This operational guidance outlines the 2016/17 FOD proactive inspection programme to poultry farms where workers can be exposed to respirable dust and other risks that can lead to ill health or injury. Although the focus is on reducing serious ill health from exposure to dust that is generated during the various stages and routine tasks undertaken in this industry, this should be done in context of an overall assessment of health and safety management.

Introduction

Poultry dust is the collective term that refers to the host of different airborne particles generated by various activities carried out routinely across the different segments of the industry. It includes pure wood dust/straw/bedding materials, complex mixtures of organic and inorganic particles, faecal matter, feathers, dander (skin material), mites, bacteria, fungi and fungal spores.

Poultry dust is defined as a substance hazardous to health because the dust can contain asthmagens. It has also been established to be a significant cause Extrinsic Allergic Alveolitis (EAA) and COPD in farm workers. The dust can harm the respiratory system, leading to sore throats, coughing, wheezing, shortness of breath, bronchitis and occupational asthma. Workers may also experience flu like symptoms.

This is particularly an issue in the intensive rearing of poultry including the rearing of hens, turkeys, geese, game birds and ducks for meat, egg production and in hatcheries.

Action

DIOs

Premises should be selected using the SIC code (01470) and other targeting information in the Organisation section of the OG. Sufficient visits should be identified ready to be sent to FOD units ahead of quarter 4.

Normal work recording instruction should be followed and cases set up under the DOIT.

FOD Inspectors

The effectiveness of health and safety management should be assessed, with particular focus on the exposure of workers and contractors to poultry dust and manual handling, particularly where operations referred to in AIS 39 are likely to occur.

Matters of Potential Major Concern (MPMC) and Matters of Evident Concern should be dealt with in line with OC18/12. It is likely MPMC such as LPG (for heating), structural safety (condition of buildings and housing), pressure systems (airlines), confined spaces (silo’s and pits), Asbestos (building fabrication and materials) and fire and explosions (dust and housekeeping) will be present and as with any inspection these matters should be actively enquired about along with the others listed in OC18/12. This will help assess overall management of health and safety.

The larger multi- site employers should be prioritised so that a head office visit can be conducted followed by a sample of other site visits to assess effectiveness of arrangements. For businesses operating across FOD administrative boundaries, lead should be taken based on head office location, coordinating with other FOD teams as necessary.

Inspectors Should

Part 1

Part 2

Part 3

Inspectors should particularly consider taking enforcement action where there is:

Enforcement action should also be considered when

Any enforcement action should be taken in line with the principles of the EMM and EPS

Occupational Hygiene Inspectors 

Provide support to FOD inspectors on assessment, monitoring and control issues.

Occupational Health Inspectors

Provide support to FOD on cases of ill health and health surveillance issues.

Sector Staff

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

Background

An extensive survey carried out by HSL showed that workers undertaking certain tasks (including catching, laying down bedding, populating houses, cleaning and litter removal and final cleaning) were exposed to high concentration of poultry dust for frequent and in some cases prolonged periods of time. As such the principles of the Control of Substances Hazardous to Health 2002 (COSHH) (as Amended) should be applied and exposure should be reduced as low as is reasonably practicable. A statement of evidence has been produced.

Research suggests that working in poultry housing is associated with higher exposures to organic dusts than for cow or swine housing and prevalence of symptoms among poultry workers is also higher. An Institute of Occupational Medicine review in 2008  reported a high prevalence of respiratory symptoms in poultry farm workers including a 15% prevalence of chronic bronchitis. .

Additionally a recent Portuguese small scale survey of seven poultry farms (Viegas et al 2013) reported a high prevalence for asthmatic (42.5%) and nasal (51.1%) symptoms. Obstructive symptoms were also related to years of exposure. It is suspected that those who develop respiratory symptoms leave the industry and much ill health is unreported.

There is comprehensive guidance published by HSE on the effects of exposure to poultry dust which was developed with the poultry industry.  Consideration should be made of the duties under COSHH when dealing with exposure to dust, including the requirement health surveillance.

Few of the operations where significant risk arises can be mechanised; many poultry houses have low roofs so only small vehicles, such as skid steer loaders and mini tractors, can access them.  Poultry sheds which can be accessed by vehicles fitted with filtered cabs are rare (although it should still be considered and assessed as it is likely to be reasonable practicable for some employers). The use of compressed air and air blowers to clean down cages, walls, floors etc. and straw choppers to spread bedding is common and may require action to be taken (see appendix 1).

In addition some operations, typically poultry catching and final cleaning of sheds, contractors are commonly used and may include the employment of gang labour or migrant workers, so management arrangements should take account of these factors.

The result of this combination of factors results in a routinely significant exposure to dust and a high dependence on the use of RPE. Therefore, it is essential that RPE is properly selected, provided, maintained and worn in line with HSE guidance.

Priority should be given to minimising the risk (i.e control) over arrangements for managing the symptoms (i.e health surveillance) and focus should be given on those common tasks where inadequate controls can result in an extreme or substantial risk gap under the EMM.

Further details on the application of the EMM and the IEE are contained in Appendix 1 and AIS 39 sets out the benchmark to be achieved in the key tasks where risk is likely to be at its highest.

If Inspectors require a sample visit plan and aide memoir, please contact the Agriculture Sector.

Organisation

Targeting

Visits should be made across all FOD regions to a total of 60 larger farms and companies in the industry.  A list of premises will be provided by the Agriculture Sector.

Head office visits should be coordinated as described in the "Action" section.

Timing

Visits are scheduled in the workplan for quarter 4. However, visits can be carried out in quarter 3 to take advantage of the seasonal trade of turkey rearing.

Resources

Inspect sites nationally in line with targeting.

Recording & Reporting

Visits should be recorded in accordance with current work recording instructions (COIN/DOIT).

Health and Safety

Visits should be made by appointment to allow for biosecurity requirements to be discussed, if relevant. 

For more general advice on visiting farms see http://intranet/yourhealthsafety/safety/visiting-agriculture.htm

Diversity

Workers may be employed whose first language is not English.

Further references

General COSHH referenced

General asthamagen references

Industry specific guidance

Contacts

Vulnerable Workers, Agriculture, Waste & Recycling Unit.

Appendix 1: Initial Enforcement Expectations for Health

Poultry Dust Health Risks

The health consequence of Occupational asthma is serious in the EMM

The likelihood is usually described as possible in large poultry farms

 Task

Situation

IEE

Comment

Bedding

Adding whole straw to nest boxes by hand (for egg producers)

Not wearing RPE where significant dust is generated.

IN

RPE with a minimum APF of 20 eg. FFP3

Machine laying down (soft) wood shavings (e.g. hen rearing or broiler chicken production).

Driver with windows down or cab not fitted with suitable ventilation and not wearing RPE.

IN

The person hand-raking to spread out the bedding should also wear RPE with a minimum APF of 20 eg. FFP3 where significant dust is generated.

 

 

 

 

Poultry Catching/depopulating

Catchers not wearing RPE where significant dust is generated.

IN

Depending on the site specifics and length of task; RPE with a minimum APF of 10, eg. FFP2 or, for more dusty tasks an APF of 20 eg. FFP3

 

 

 

 

Cleaning

Cleaning egg production colony system sheds using air blowers

Not using wet cleaning techniques, such as, damping down or wet mopping or not using a vacuum cleaner and not wearing RPE with a minimum APF of 20 eg. FFP3 where significant dust is generated.

IN

Air blowers may be used for convenience, as well as, for hard to reach areas. Refer back to the adequacy of the risk assessment for consideration of alternative cleaning methods

Cleaning broiler shed floors using a front end or skid steer loader

Driver has the window open or cab is not fitted with suitable ventilation and is not wearing RPE.

IN

RPE with a minimum APF of 20 eg. FFP3 is required where significant dust is generated.

Removal of residual dry litter and manure using hand- held stiff brushes, flails or compressed air

Not wearing RPE with a minimum APF of 20 eg. FFP3.

IN

Very high dust levels expected.

 

 

 

 

RPE

RPE not maintained or no face fit test for tight fitting masks

IN

 

 

Health surveillance

H.S. absent and the dust controls  are not fully effective, resulting in a possible risk of occupational asthma and COPD

IN

Discuss with Occupational Health

Just for information:

The benchmark level of risk is usually nil/negligible for health. The risk gap is determined by the consequence and likelihood of the actual risk against the consequence and likelihood of the benchmark level of risk.

Likelihood Descriptors:

Probable

Possible

Remote

Nil/Negligible

 Repeated and/or prolonged exposure

Repeated low level or single high level exposures

Single/occasional low level exposure

Exposure reduced to ALARP or ALARP below WEL value where available

 

Updated 2016-11-19