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Manufacturing sector strategy 2012-15

Sector description

Manufacturing is a diverse sector that encompasses a large number of industries and sub-industries, ranging from heavy industries to specialist or delicate operations. They span large employers to those dominated by micro-businesses or the self-employed, and include growing industries as well as those in decline. The health or safety hazards are often specific to the processes involved, which differ substantially between industry / subsector.

This strategy covers the various different industries that make up the manufacturing sector. It takes into account:

Efforts to improve control of health and safety risks across manufacturing as a whole must accommodate the diversity between the industries yet continue to be efficient and effective by using consistent approaches. However, approaches may need to be customised to meet the requirements of specific industries and sub-industries.


As manufacturing is such a diverse sector, selecting those industries / sub-industries for specific attention is a challenge.

Typical routes of classification (such as Standard Industrial Classification (SIC) codes) are not necessarily appropriate when grouping industries as the risk profiles of industries within the same SIC classification can be quite different.

Selection could be approached in a number of different ways:

HSE has used the hybrid groupings approach. It allows the strategy to accommodate the challenges posed by the diversity of the sector, providing a basis for targeted attention in key areas while retaining sufficient scope for tailored industry (or sub-industry) interventions.

The four broad industry groupings were developed by considering:

These industry groupings were developed by consideration of the following factors:

Group Industries Basis of grouping Approach by enforcing authority
  • Basic and molten metals
  • Shipbuilding and ship repair
  • Food (dairy products, meat & poultry products)

Higher hazard and control of risks unsatisfactory

Established routes of influence through intermediaries

Sufficient scale for return of regulator investment

Proactive intervention / inspection

Increasing focus on role of intermediaries

  • Motor vehicle repair (MVR) (part)
  • Stoneworking
  • Woodworking / furniture
  • Fabricated metal products (part)
  • Plastics
  • Semiconductor manufacture

Higher or medium risk industries

Dispersed industries (eg small / micro-business dominated or without effective trade associations)

Targeted proactive intervention on particular processes, occupational groups or dutyholders

  • Plastics
  • Rubber
  • Fabricated metal products (part)
  • Mineral industries (ceramics, glass, glazing, cement, concrete, bricks etc)
  • Other food & drink
  • Paper & board

Higher or medium-risk industries.

Structural factors give clearer role for others in health and safety system (eg trade associations or supply chain intermediaries with influence)

Focus on role of intermediaries

Where HSE intervenes directly with dutyholders it is likely to be reactive action

  • Leather
  • Laundries
  • Computer, electronic and optical products
  • Printing
  • Textiles
  • Other manufacturing industries, not listed elsewhere

Lower risk industries
declining industries with (relatively) few at risk

Principally reactive

This strategy excludes chemical industries and waste and recycling, which are covered by separate sector strategies.

Key stakeholders

Stakeholders are relatively well established and identifiable:

Some trade bodies are represented in the standards-making process (EN or BS), sit on training and qualifications bodies (such as the Sector Skill Councils), and negotiate with Government, professional institutions and HSE on benchmark compliance standards.

Unions continue to exert a strong influence in some, usually more traditional, industries. However, many manufacturing industries are either non-unionised or have a mixed degree of union membership.

Safety and health issues

Group A: Basic and molten metals; Shipbuilding, ship repair and dismantling; Food manufacture (part - dairy products, meat & poultry products)

All sectors in this group can generally be characterised by the presence of high-hazard processes and relatively high injury and / or ill health rates.

Underlying causes of incidents are often failings in corporate risk management and practices in relation to higher hazard activities. Although risk control may be unsatisfactory, the hazards are generally well recognised by industry, as are the requirements for effective risk assessment and controls.

Where appropriate, the role of intermediary bodies could be extended in future to take an increasing lead as control of the major risks improves.

Basic and molten metals

  • Approximately 62 000 employees
  • Relatively high rates of fatalities, accidents and disease
  • Historical exposures to metal fumes and dusts (but improving)
  • Inherently hazardous work (involving significant masses, machinery, handling and transport activities, as well as high temperatures, dusts and fumes) with potential for severe consequences if risks are not properly managed
  • Key health risks include the development of long-latency occupational diseases such as cancers, asthma and COPD
  • Long established, often large employers - opportunity for sharing information about, and direct learning from, severe incidents, ensuring that lessons are shared across the industry
  • Good trade association representation
  • Investigations continue to identify poor performance from failures to translate commitment through management systems and organisational structures

Shipbuilding, repair and dismantling

  • Employment is around 35,000, but varies, with high levels of contract or short-term contract labour at times of demand
  • Often hazardous work, eg heavy engineering, hot or cold metal forming
  • Injury and ill health rates significantly above the manufacturing average
  • Potential for multiple casualties from a single incident
  • Safety risks typically involve machinery, movement of heavy components, work at height and transport
  • Occupational diseases include cancer, asthma, COPD at significant levels (associated with welding fume, asbestos) and hand-arm vibration disorders (HAVs)
  • Dominated by long-established, larger businesses with formal management structures
  • Potential to influence industry via Shipbuilders and Shiprepairers Association
  • There is a need for improvements in health and safety competence, leadership and worker involvement, even where the risks and responsibilities are recognised at a senior level
  • A need for the industry to develop a health and safety culture where lessons are learned and shared at all levels, across multi-site businesses and all aspects of their operation

Food and drink - part (dairy, meat and poultry products)

  • Numbers at risk: 90,000 (within overall food and beverage manufacturing sector employing approximately 395,000)
  • Main issues are associated with manufacture of dairy products and meat and poultry products - particularly high RIDDOR injury rates, suggesting this subsector needs to implement appropriate health and safety management controls

Aims for 2012–15


At Board, and throughout management and supervisory levels, people are held accountable for delivery of health and safety.


Organisations are aware of significant work-related health risks and take appropriate actions.


Dutyholders and others actively seek new ways to reduce accidents, particularly where progress has slowed.

Group B: Motor vehicle repair (MVR) (part - excluding dealerships of vehicle manufacturers and national chains for vehicle part replacement/servicing); Woodworking & furniture; Stoneworking; Fabricated metal products (part); Plastics; Semiconductor manufacture;

The significant hazards faced by large numbers of dispersed small businesses in this group require continued efforts to secure improvement, ensuring the risks and controls are recognised, understood and implemented. In particular, this extends from the familiar safety topics to include occupational disease issues.

With trade or intermediary bodies having limited penetration or influence, the regulators' role will be geared specifically to the needs and priorities of small businesses.

Motor vehicle repair (MVR)

  • Numbers at risk: 182 000
  • Risks well documented
  • RIDDOR rates are about the average for manufacturing but significant under reporting means the actual harm levels are much higher
  • A number of fatalities each year are linked to safety issues such as elevating vehicles, vehicle movement, petrol fires
  • Health risks - isocyanate spraying and HAVs (in body shops)
  • Greater public interface than many aspects of manufacturing, due to the prevalence of consumer service activities such as tyre and exhaust fitting
  • Standard of working environments can vary substantially between organisations:
    • The part of this sector in Group B involves all bodywork repair and refinishing businesses, and small and micro-businesses carrying out mechanical repair
    • At the better end there can be good facilities (mainly linked to vehicle showrooms and national chains) and these are excluded from Group B
  • Large players represented through HSE-hosted MVR Forum, but this does not reach the significant numbers of SMEs and self-employed
  • Often have self-employed workers and work in low-grade industrial accommodation
  • Without a direct focus on these small businesses to ensure a widespread awareness of risks and adoption of practicable controls, the injury and ill-health toll in this subsector will remain unchecked

Woodworking and furniture

  • Numbers at risk: 184 000
  • Greater than manufacturing average RIDDOR rates, mainly associated with high-risk machinery that's difficult to guard
  • Difficult industry to influence due to low trade association membership, micro/SMEs, and operator competence (relies on operator setting machines correctly)
  • Overall, well-documented safe working practices
  • Health risks relate to dusts and solvents and are reflected in high rates of work-related cancer registrations, asthma and COPD, even though exposures can be readily controlled with LEV and other measures


  • Less than 8000 employed, often in small businesses
  • From unskilled processes to high-end craftsman, who generally have higher competency levels and are more highly qualified
  • Increasing reliance on migrant labour at the low skill end
  • High fatality rate - associated with heavy loads, lifting operations, transport
  • Risk of occupational diseases (COPD and silicosis) strongly linked to silica exposure
  • Trade association membership is low and consequently is unable to exert a significant influence on health and safety issues
  • There is a need for greater understanding of the risks and necessary controls which could best be achieved through a variety of intervention techniques including targeted communication activity, inspection and enforcement action

Fabricated metal products

  • About 163,000 employed in the relevant sub-industries:
    • Treatment and coating of metals
    • Manufacture of lifting and handling equipment
    • Manufacture of 'other' fabricated metal products
  • Mainly semi-skilled processes
  • There are no trade associations with effective coverage in this sector; this, combined with small business size, makes it a difficult industry to influence
  • Greater than manufacturing average RIDDOR accident rates
  • Use of high-hazard substance - health risks are prevalent, commonly dermatitis and sometimes respiratory ill health from exposure to metal working fluids, solvents, welding fume or other product specific substances or processes
  • Other health risks, eg MSD or from noise/vibration are not uncommon
  • The diversity of the risks, and limited effective leverage routes, makes effective influence on control unlikely by any method other than involving some direct proactive work


  • Large sector employing about 125,000 people
  • Significant proportion of SMEs
  • Rates of fatalities, accidents and illness – lower range - around or below the average for manufacturing
  • Safety issues largely overcome due to machine design – largely automated
  • Risks from exposure to substances are low (mainly due to design and substitution) although manual handling issues remain
  • Trade associations, but low membership
  • Trade body-led initiative, known as SIMPL (Safety in manufacturing plastics), is providing new leadership for health and safety in the sector

Semiconductor manufacture

  • High TA coverage, medium RIDDOR rate, use of high hazard substances
  • Specialist and focussed industry dominated by 20 companies employing 10,000 workers
  • Manufacturing process uses a range of chemicals and gases many of which are hazardous, including carcinogens.

Aims for 2012-15

Customising approaches for SMEs

SMEs are aware of their obligations and areas where action is required in order to effectively manage health and safety in their business.

Securing justice

Learning from investigations is captured and shared, and those found to fail in their health and safety responsibilities are held to account, with enforcement action taken to secure both immediate and sustained compliance with the law.

Group C: Paper & board, Rubber, Fabricated metal products (not covered in Groups B or D), Other food & drink, Non-metallic mineral products

Industries in this group need to make sure standards are maintained and, in some areas, improved. With trade bodies already addressing health and safety priorities these intermediaries can lead and accommodate the needs of SMEs and occupational disease issues. Opportunities to influence also exist through the supply chain.

Paper & board

  • Numbers at risk: 51 700
  • Rates of fatalities, accidents and illness – mid to high range
  • Higher than average rate of fatal and major incidents in relation to machinery, handling and transport
  • RIDDOR injury rates are significant, including serious incidents often linked to machinery, mechanical handling and transport activities
  • Safety standards are well-known
  • There are limited health risks from substances in the sector but reported ill-health rates overall are high, due to inadequate control of musculoskeletal disorders (MSDs) and noise
  • Highly effective trade associations
  • Dominated by well-established, large / multinational businesses
  • The Industry Advisory Committee (PABIAC) has been effective in improving health and safety. Their challenge is now to extend their influence to the smaller, newer businesses


  • Large sector employing about 125,000 people
  • Significant proportion of SMEs
  • Rates of fatalities, accidents and illness – lower range - around or below the average for manufacturing
  • Safety issues largely overcome due to machine design – largely automated
  • Risks from exposure to substances are low (mainly due to design and substitution) although manual handling issues remain
  • Trade associations, but low membership
  • Trade body-led initiative, known as SIMPL (Safety in manufacturing plastics), is providing new leadership for health and safety in the sector


  • Numbers at risk: 20 000
  • Mature industry - specialised process with many firms are long established firms
  • Significant decline in rubber-tyre plant; industries moving into other areas, eg retreads, tyre distribution and fitting and rubber crumb recycling, resulting in increase in SMEs that are potentially less aware / compliant with established standards
  • The bulk of the materials and forming processes create a hazardous environment with significant RIDDOR injuries linked to machinery, handling and transport
  • Historical health problems mean the sector is attuned to occupational disease issues generally, and control is by established working practices
  • Trade associations are well represented and have been effective in instilling good practice
  • Tyre and Rubber Industry Safety Action Group (TRISAG) positions the industry well to maintain performance and to ensure that SMEs are equally involved

Fabricated metal products (part)

  • The activities are diverse and the sector accounts for around 520 000 employees, more than a fifth of all of those employed in manufacturing overall
  • Employers range from very large businesses to small and micro firms
  • Subsectors have typically medium / medium–low RIDDOR rates:
    • Metal forming
    • Steel stockholding
    • Manufacture of transport vehicles
    • Micro-electronics
    • General engineering
    • Wire and tube manufacture
  • Risks associated with operating machinery and lifting and transporting components broadly in line with the manufacturing sector average
  • Specific health risks linked particularly with welding (fumes), metalworking fluids, handling of components and noise and vibration
  • Some subsectors have specific trade associations or safety groups but the fragmentation limits effectiveness, although EEF takes an active lead to raise standards across the board
  • A common feature is the dependence on consumables, production equipment and other supplies. The supply chain is an effective conduit for information and advice

Food and drink manufacture (excluding dairy and poultry products)

  • Large sector - 395 000 employed
  • Businesses span from very large multi-national firms with strong consumer awareness and reputational drivers for good performance, to micro businesses working close to source in basic conditions
  • Alignment between the regulators (eg FSA and HSE) with proportionate interventions is necessary to ensure management controls are equally effective for food hygiene and health and safety offers potential scope to reinforce compliance
  • Major injury rates are above the manufacturing average, linked typically to slips given the nature of the production and machinery interventions.
  • Ill-health issues centre on MSDs resulting from packaging and transportation processes, with specific substance issues where dusts are generated
  • Strong and inclusive trade association, which established the long-running 'Recipe for safety' initiative that continues to provide a lead and focus for health and safety

Non-metallic mineral product industries (other than stoneworking)

  • About 87 000 workers
  • High levels of relatively severe injuries and ill health ((linked to silica and COPD)
  • Strong and influential trade associations well engaged in health and safety - ability to influence and affect operations beyond their direct membership
  • Activities in these long-established businesses involve cement making, ceramics, concrete, glass & glazing, heavy clay & bricks and refractories
  • Some large multinationals but many activities are undertaken within SMEs
  • The industry advisory committee, CHARGE, has established a health and safety strategy and addressed specific subsector issues through tailored initiatives
  • The focus remains on maintaining engagement and action on health and safety, predominantly through the effective lead of the trade associations and larger companies' promotion of good practice

Aims 2012-15


All representative bodies can demonstrate what they are doing to improve health and safety across their sector.

Wider perspective

Active engagement from within and beyond the system on matters directly and indirectly effecting health and safety.

Group D: Printing, Textiles, Leather, Laundries and Metal products (part - Computer, electronic and optical products), (MVR) (part - dealerships of vehicle manufacturers and national chains for vehicle part replacement/servicing), Other manufacturing industries not elsewhere specified

The challenge for this group is for businesses to maintain compliance with established standards using recognised controls and to seek health and safety improvements, particularly in light of any changing processes or technologies. This relies on ongoing commitment to health and safety at all levels within organisations and a proportionate response to the risks.

For the more organised sectors with mature and effective trade associations, these bodies are already positioned to deliver support to this end. In the more fragmented sectors, greater reliance rests on the individual businesses and the recognition of established standards.

Ongoing reactive work in line with the Enforcement Management Model will be important to detect new issues or any decline in standards which may warrant more intensive activity. This will be complemented by keeping abreast of the trends and prospects that may have a bearing on health and safety.

Textiles, footwear and leather

  • Numbers at risk: 85 000
  • Continued decline in the face of foreign competition
  • Primary processing of raw material is largely carried out overseas and the majority of garments are imported ready made or put together here.
  • Includes significant logistics and warehousing activities to manage the import and distribution of clothing / material from abroad
  • Low trade association membership, meaning centrally coordinated activity has limited impact
  • Leather tanning and processing now employs few people in GB. It is largely carried out by just two well established groups which are relatively well engaged with health and safety


  • Numbers at risk: 39 000
  • Some specific machinery risks but few in number
  • Compliance standards are well documented
  • The Textile Services Association is an effective and influential trade association on health and safety matters
  • Injury and ill-health rates are low in the sector, with a few key issues relating to MSDs and machinery risks, including work in confined spaces (eg for maintenance). Substance exposure risks are minimal

Fabricated metal products (part - manufacture of computer, electronic and optical products)

  • 117 000 employees
  • Low RIDDOR rates and modest levels of occupational disease
  • Relatively engaged regarding health and safety
  • Some parts of these industries there may be exposure to solder fume, the precautions are well documented
  • In general, the nature of the products requires controlled environments and work to precise specifications and the health and safety risks and standards required are generally well recognised

Printing and recorded media

  • 121 000 employees
  • Dominated by SMEs with few medium / large companies
  • Stronger than average trade union representation
  • Risks generally well recognised and controlled
  • The reach of the various trade associations is limited in part because of the low-level of membership among the many SMEs
  • Shift to inherently less hazardous processes means it is becoming easier for businesses to apply simple health & safety precautions
  • The precautions for the remaining traditional presses and associated machinery are well known and well documented

Other manufacturing industries not elsewhere specified

  • 161 000 employees
  • Miscellaneous industries with no common features
  • Low to moderate accident rate, and no specific health risks
  • The variety of this section makes industry-specific approaches untenable, and there is a need for greater reliance on generic health and safety guidance

Aims for 2012–15

Injury & ill-health

Organisations are aware of health and safety risks and take effective and proportionate action to prevent accidents and occupational diseases.

Legislation and regulation

There is very little industry specific legislation, and most legal compliance activity relates to enforcement of generic legislation (eg HSW Act, COSHH).

Strategic regulatory and sector approach

In the majority of manufacturing industries health and safety legislation is enforced by HSE. Within small sub-industries (particularly steel stockholders and in some service centre type MVR) enforcement is by local authority enforcement officers.

In recent years there have been a number of initiatives to transfer MVR premises from HSE to LA through formal enforcing authority transfer. Additionally, visits to HSE-enforced MVR premises have been made by local authorities under a defined flexible warranting scheme. This approach reduced regulatory burdens where local authority officers also had responsibility for environmental emission control visits.

For premises where visits are paid by both HSE and other enforcing authorities (eg to enforce environmental emission or food hygiene legislation) there is a potential for regulators to work together to convey key messages and reduce regulatory burdens for businesses.

Future trends

The number of people employed in manufacturing has shrunk considerably over the past 30 years, partly as a result of automation and improved production techniques, and partly as a result of cheaper imports and the export of production capacity by GB manufacturers.

However, the position now is relatively stable due in part to the diversity of the sector, which contains:

Changes in manufacturing methods linked to new materials, new technologies and greater automation ('advanced manufacturing') should also support relatively high 'added-value' domestic producers rather than low-cost (overseas) manufacturers.

Updated 2021-02-25