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Mitigating risks by employing a competent workforce

Author : Alan Montgomery, CompEx

12 March 2024

Businesses manufacturing products in the food and beverage industry often have hidden risks in terms of the materials and equipment that are used, creating potential hazards, that necessitate a heightened level of awareness and specialised training through certification bodies. However, the current landscape of this industry reveals an evident lack of understanding regarding these risks, leaving workers vulnerable to potential dangers.

Image: Shutterstock
Image: Shutterstock

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In this article, Technical Development at CompEx Alan Montgomery, discusses the hidden risks found in the food and beverage industry, that during different stages of production can create hazardous environments, and the importance of a competent workforce that is aware of potential dangers in classified zones.

Businesses of all sizes

Mass production, storage and handling facilities in the food and beverage sector often involve complicated systems that have been designed to ensure a safe working environment where process safety is vital to mitigate risk. Many larger manufacturers are likely to already have some of these safety processes in place, in particular those that are using bulk dry materials or those storing and (or) handling flammable gases or liquids. Therefore, the workforce operating in these environments is at risk of being exposed to a variety of potential hazards that demand an in-depth understanding of the established processes to ensure safety on-site.

However, smaller food and beverage manufacturers, such as independent distilleries, may have limited knowledge on the risks that hazardous areas and their mix of materials impose. In the case of those SMEs (with fewer than 250 people), I would recommend that operators invest in raising awareness across all levels of their business, as it’s likely that, with the size of their workforce, roles may be more flexible and, therefore, require an understanding of the regulations, standards and guidelines of both hazardous and non-hazardous environments.

Major accidents and incidents, such as loss of containment of hazardous materials which could lead to an explosion, still continue to happen in manufacturers of all sizes, and yet I have found that this is often overlooked by those operating in hazardous environments who suggest ‘this will never happen to us…’.

Defining a hazardous area

An important starting point for manufacturers and plant owners is to recognise and understand how a hazardous area is classified, so they can determine the area(s) within their site which have a potentially explosive risk. Once identified, this can then be documented on a Hazardous Area Classification drawing for those who go on and work in this area to follow.

With regard to food and beverage manufacturers, hazardous areas are environments where an explosive atmosphere is either continuously present or likely to be present. A lack of understanding as to where such areas are located on the production site creates the risk of an incident occurring, which can result in substantial damage to your asset(s), serious injury and may even lead to the loss of life.

In addition to this, according to roles identified within the relevant regulations and standards, it’s the plant manager (Responsible Person or Duty Holder) who has the responsibility to ensure that the correct and compliant materials are provided for their plant to remain safe. They must install Ex-certified equipment to provide a greater level of protection to those working with potentially flammable or combustible materials.

Unveiling unseen hazards

Unlike industries with well-documented hazards, such as the oil and gas or chemical industry, the risks within food and beverage manufacturing are often more difficult to identify and, therefore, there can be limited awareness regarding potential dangers.

Image: Shutterstock
Image: Shutterstock

There is currently a total of 950 sites in Great Britain that are registered under the Control of Major Accident Hazards (COMAH) scheme1. These sites require statutory scheduled inspections from a specialised regulator to certify that duty holders are applying the correct safety measures, as detailed in the safety report and/or the Major Accident Prevention Policy.

However, it’s thought some manufacturing sites are not COMAH-registered when they should be, due to lack of awareness, increasing the risk of a dangerous incident occurring from absence of inspection. Therefore, it’s crucial for operators to determine whether COMAH regulations apply to the volume of product that is manufactured and what is required as to comply to the safety requirements2.

Dust-producing products, such as any type of grain, flour, tea, coffee, dried milk and sugar can create a risk of ‘dust explosion’. A well-known example of an explosive incident from a combustible dust product is The Great Fire of London, which is believed to have initiated from the combination of an ignition source, fire, combustible dust (flour) and oxygen not being safely managed in a hazardous area.

On the other hand, those manufacturing beverages, such as distilleries, may be working with materials that are classified as flammable liquids, which pose a high risk of ignition. This is particularly prominent for any business that produces the likes of whisky, gin or vodka as the prime product that is being manufactured is flammable and therefore requires careful management by those working on-site.

The role of senior members on-site

It is crucial for senior team members on-site to have control and management of any combustible, flammable, reactive or unstable materials to prevent the loss of primary containment and mitigate the risk of fire or explosion. This requires a clear business leadership strategy that details safe working procedures and practices that employees are disciplined to follow.

I would highly recommend that plant managers ensure that up-to-date safety procedures are being implemented on-site and staying current through regularly reading key reports from public bodies, such as Health and Safety Executive (HSE), which provides useful guides to controlling hazardous risks.

Plant managers can also refer to Dangerous Substances and Explosive Atmosphere Regulations (DSEAR3) to learn more about how the risks of ignition and explosion can be mitigated, and when these regulations need to be applied, in order to protect the workforce operating on-site.

Implementing competency throughout all levels of the business

Some individuals working in potentially hazardous environments, whether engaged directly in the electrical operations or supervising those who are, can be found to lack a comprehensive understanding of the variety of risks associated with their roles. This lack of awareness creates a culture of complacency, which elevates the likelihood of an incident occurring.

I cannot emphasise enough how important it is for manufacturers to implement, follow and uphold well-defined processes to raise awareness around operations that may involve unseen risks that the workforce might not have existing knowledge of.

A prerequisite for competence

To navigate the intricate risks and hazards that mass production food and beverage manufacturing can create, a shift in understanding the need to upskill workforces is imperative when recognising the importance of workplace safety, protecting the asset and compliance with legal responsibilities.  While general workplace safety measures are essential, they often fall short in adequately preparing workers for the industry-specific challenges that they may face, whether that’s working directly or indirectly with hazardous products and areas.

Recognising the unique nature of the risks involved through undertaking specialised training to gain the relevant understanding and qualifications must be encouraged to equip employees with the vital skills to navigate their roles safely.

In my opinion, the overarching goal is not merely regulatory compliance, but the nurturing of a sustainable safety culture to mitigate the risks of potentially life-changing incidents occurring. A skilled and well-trained workforce, equipped with knowledge on the hazardous requirements and regulations, is an investment in the sustained welfare of both employees and the business itself.

However, I would advise in the instance that any ‘near-miss’ occurs on-site, plant managers exercise a thorough investigation to determine the cause of this to avoid something similar occurring in the future, as these can often be dismissed and not recorded.

Plant managers play a pivotal role in ensuring that the workforce on-site is fully aware and has an in-depth understanding of the potential risks and hazards that exist, to a level which can demonstrate competency to a regulator.  By doing so, this will likely avoid the potentially devastating consequences an ignition and explosion could bring to the organisation and is likely to foster a site-wide culture of safety that goes beyond regulatory requirements.

Continuous improvement and increasing awareness, especially in the aftermath of near-misses, are crucial elements in mitigating risks and maintaining a secure work environment in the food and beverage industry.

References

1 Review of Enforcement in the Chemicals Industry (COMAH)

2 https://www.hse.gov.uk/pubns/books/l111.htm

3 https://www.hse.gov.uk/fireandexplosion/dsear.htm

About the author:

CompEx Technical Development Manager, Alan Montgomery is an experienced Electrical Practitioner who has gone on to support and develop Competency Management within Manufacturing and Petrochemical plants. Before joining CompEx, Alan was an instructor and assessor delivering Electrical Safety and CompEx qualifications at Forth Valley College.


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