HSE issues temporary guidance for bakers to cope with restricted dust mask supply due to coronavirus

Breathing in flour dust is an occupational hazard of working in a bakery and can cause asthma – hence the recommendation to wear dust masks (PPE). Unfortunately, though, the HSE said there is currently a restricted supply of PPEs across many parts of the food industry.

However, suitable control can often be achieved using good working practices and local exhaust ventilation (engineering controls), which then means that employees do not need to wear dust masks; reducing overall pressure on the supply chain.

To advise bakeries on what they can do, the HSE has issued temporary guidelines to help businesses and workers continue to provide food for the nation.

Options for using PPE with an APF of 10

1. If PPEs are necessary to assist in reducing exposure to flour dust to a level as low as is reasonably practicable (ALARP), HSE guidance is that it should have an assigned protection factor (APF) of at least 20 (e.g. FFP3, re-useable respirator with a P3 filter or a TH2/3 powered air respirator).

2. HSE recognises, however, that the availability of PPE with an APF of 20 may be reduced due to COVID-19. If an employer is anticipating that their supplies of PPEs with an APF of at least 20 will be exhausted and they are unable to source another supply, then they must carry out a COSHH risk assessment (the Control of Substances Hazardous to Health Regulations 2002). This should identify the combination of additional dust exposure minimising measures in place to maintain adequate protection and ensure the risk to workers is not increased by providing PPE with an APF of 10 (e.g. FFP2, re-useable respirator with a P2 filter). The additional measures should include:

• Using non-stick coatings on conveyor belts and greaseproof paper on trays instead of flouring the surfaces.
• Using low-dust flours as a lubricant and for dusting.
• Using flour improvers in paste or liquid form instead of powder to reduce the airborne dust generated when adding ingredients.
• Separating the weighing and dispensing of flour and powdered ingredients from the remainder of the production area using enclosures to contain the flour dust within the enclosure to minimise flour dust spreading.
• Using mixers with lids to contain the dust at the start of mixing cycles.
• Using effective, adequately designed and maintained local exhaust ventilation for dusty tasks such as bulk flour sieving, dispensing, weighing, tipping powdered ingredients.Ensuring all workers have been provided with information, instruction and training on careful flour handling techniques, including:
  • Safe working practices to minimise flour dust:
  • Ensuring ingredients in powder form are not tipped from a height into mixing bowls.
  • Minimising airborne dust when folding and disposing of empty bags, i.e. rolling the bag from the bottom while tipping avoiding the need to flatten or fold empty bags.
  • Starting-up mixers on slow speed until wet and dry ingredients are combined.
  • Avoiding hand dusting; using a sieve/dredger with minimal drop height.
  • Using high efficiency industrial vacuum cleaners and avoid dry sweeping with a brush.
  • Not using compressed airlines for cleaning off dust from equipment.
• Ensuring supervision to ensure all workers carry out the careful flour working techniques to minimise their exposure to flour dust, and they raise any concerns or defects immediately.

When sourcing alternative PPEs and choosing disposable, reusable or powered air respirators, a fit test is required for any tight-fitting PPE provided as a control measure unless an employer can source the same mask, in the same size, for which the worker has been fit tested before. Inadequate fit can reduce the protection provided to the wearer.

Advice on undertaking face fit testing to avoid transmission of COVID-19 can be found here.​​

Alternatively, devices such as loose-fitting powered helmets or hoods – which do not require face-fitting – could be selected for the affected workers.

Complying with COSHH

3. All control measures must be determined through risk assessment and applied to the extent where they are reasonably practicable. Exposed workers should wear the most practical PPE with the highest APF necessary to control exposure to flour dust. If PPE with an APF of at least 20 cannot be sourced, PPE with an APF of 10  used in a combination of the above measures may control exposure to ALARP, achieving compliance with Regulation 7 of COSHH.

Conserve stocks of suitable PPE

4. In order to optimise the stocks of suitable PPE, employers are encouraged to take steps which will help preserve them. These could include:

• Only providing PPE to those workers who need it.
• Issuing PPE specific to the level of risk for specific tasks i.e. use lower APF PPE, that of an APF of 10, where the level of personal flour dust exposure is lower.
• Providing instruction on maximising the use life of all PPEs, by ensuring adequate user checks, cleaning and storage.

The HSE noted it does not anticipate an increase in the cases of occupational asthma during these unprecedented times. Employers that effectively control exposure to flour dust using good working practices, engineering controls and PPE will not see an increase in cases.

However, whenever cases are reported in line with HSE’s Incident Selection Criteria – which includes the restricted circumstances under which cases of COVID-19 among employees are reportable​ ​– it will investigate  to understand the circumstances.

Following an investigation, HSE cannot guarantee that it would not take enforcement action or prosecute. That decision will be in accordance with its Enforcement Policy Statement,​​ which requires that prosecution must be both proportionate to the seriousness of the breach and in the public interest.

Employers who can demonstrate effective control of risks with the appropriate combination of good working practices, engineering control and PPE are not likely to face enforcement action.