Author unit / section:

Agriculture & Food Sector (Food Section)

Target audience:

FOD Operational Inspectors and HSAOs

• Summary
• Introduction
• Background
• Advice to inspectors
• Action by inspectors
• Further advice
• Contact HSE

Summary

This SIM provides guidance for inspectors on the significance of the workplace exposure limit when enforcing measures to achieve adequate control of exposure to flour dust in bakeries.

Introduction

1  The Health and Safety Commission (HSC) acting on a recommendation of the Advisory Committee on Toxic Substances (ACTS) introduced an occupational exposure limit for flour dust in May 2001. The background to setting the limit is explained in SIM 01/2001/56 ‘MEL for Flour Dust [77KB]’. The current long-term exposure limit is set at 10 mg/m3 (8-hour time-weighted average (TWA)). The limit is published in EH40/2005 Workplace Exposure Limits. Occupational exposure limits were replaced by workplace exposure limits (WELs) in 2005.

2  COSHH Essentials for Flour Milling and Bakery suggests that bakeries that comply with good control practice can normally expect to reduce exposures to less than 2mg/m3.

Background

3  Recently members of the trade associations have expressed concern that some inspectors are claiming there is a strict legal requirement to reduce exposures to flour dust in bakeries to below 2mg/m3 whilst others are giving the impression that there are plans to reduce the WEL to this value.

Advice to inspectors

4  Regulation 7(1) of the Control of Substances Hazardous to Health Regulations 2002 (as amended) (COSHH) requires every employer to ensure that the exposure of his employees to substances hazardous to health is either prevented or, where this is not reasonably practicable, adequately controlled.

5  Flour dust is a substance hazardous to health and an asthmagen as defined in the Regulations.

6  Furthermore, COSHH regulation 7(7) states that where it is not reasonably practicable to prevent exposure to flour dust, control of that exposure shall only be treated as adequate if:-

(a) the principles of good practice for the control of exposure (set out in Schedule 2A to the Regulations) are applied;

(b) the workplace exposure limit (WEL) is not exceeded; and

(c) exposure is reduced to as low as is reasonably practicable.

7  This means that exposure to flour dust in bakeries should be reduced to as low as reasonably practicable below the WEL.

8  Emphasis should be placed on securing good control practice which in turn should result in exposure being reduced to well below the WEL.

9  Good control practice can reduce exposure to around 2mg/m3, based on an 8 hour TWA.  In many cases, behavioural change and engineering controls will be needed to achieve values around this figure and for some particularly dusty activities, RPE may also be necessary.  It is important to note that 2mg/m3 is an indicative but in many cases achievable value. It should not be regarded as an additional legally- binding exposure limit. There are no plans at this point in time to reduce the WEL to this value.

10  However, there is still a risk of asthma below the level of 2mg/m3.  A recent draft recommendation from the European Commission’s Scientific Committee on Occupational Exposure Limits concluded that there would be only a low risk of developing respiratory symptoms, including asthma, with exposures to inhalable flour dust in the region of 0.5 - 1mg/m3.  Above this exposure range, there is an increasing risk of these effects.

Action by inspectors

11  Inspectors should impress upon employers the importance of following good control practices to reduce exposures to flour dust in bakeries to as low as is reasonably practicable rather than pressing to reduce exposures to a specific level below the WEL.

Further advice

12  Further advice may be found on the HSE website and in the following HSE publications:-

Control of substances hazardous to health (Fifth edition) – the Control of Substances Hazardous to Health Regulations 2002 (as amended) – Approved Code of Practice and guidance – L5 (ISBN 0 7176 2981 3)

EH40/2005 Workplace exposure limits (ISBN 0 7176 2977 5)

HSG233 A baker’s dozen – Thirteen essentials for health and safety in bakeries (ISBN 978-0 7176 2616 8)

Health and Safety in Bakeries Liaison Committee (HSBLC) Booklet – Guidance on dust control and health surveillance in bakeries. This is available from the Federation of Bakers, 6 Catherine Street, London WC2B 5JW (Tel: 0171 – 420 – 7190).

Contact

For further information please contact  Bob Hadway, Agriculture and Food Sector (Food Section), Nottingham Tel. 0115 971 2849 robert.hadway@hse.gsi.gov.uk