Occupational lung disease is a priority for the Health and Safety Executive across 2025 and 2026, with inspections to take place to ensure and enforce compliance. This article aims to tackle some of the complexities health and safety professionals and employers face when assessing risks, planning and implementing controls and remaining compliant
A Compliance Headstart
Before we go into detail, it is worth using an expert such as Synergy Environmental Solutions to help pre-HSE inspection. Our team consists of BOHS-qualified consultants who are experienced and great at their jobs.
We have an in-depth understanding of the COSHH Regulations and utilise state-of-the-art workplace air monitoring equipment for personal, area, and real-time monitoring. We also provide Local Exhaust Ventilation (LEV) testing and servicing, as well as a range of health surveillance services for total worker welfare and regulatory compliance.
Why are HSE Focusing on Air Hazards?
The HSE’s key objectives in its 25/26 business plan include maintaining Great Britain’s record as one of the safest countries to work in and reducing work-related ill health. The plan states that there are 12,000 lung disease-related deaths a year that are linked to past workplace exposure.
As employers and as a service provider, we and you must protect people and significantly reduce the alarming number of deaths.
While no employer would accept putting its workers in danger, business priorities can mean that risk assessments and worker checks can be put on the back burner. The HSE inspections, although not welcomed with open arms by employers, are a way of prioritising COSHH regulations, workplace air monitoring, and ensuring control measures are effective in reducing occupational lung disease.
What Substances is the HSE Focusing On?
The HSE introduced Health Focused Inspections in 2024, and 25/26 is expanding on this to focus on hazardous dust. They have a particular focus on:
Respirable Crystalline Silica
Crystalline silica is a naturally occurring mineral found in many materials, including quartz, sand, gravel, and rocks. It is a fundamental component of the Earth’s crust and has a wide range of industrial applications. Various industrial processes crush or disturb materials, releasing fine dust particles of respirable crystalline silica into the air. These tiny, inhalable particles are known as respirable crystalline silica, RCS, or silica dust.
RCS is a common substance found in various industries and construction activities. Exposure to RCS can pose serious health risks to workers and have environmental consequences.
Dusty Ingredients in Bakeries
Workers in bakeries, flour mills, and kitchens face a notable health risk: flour dust and enzyme-containing additives such as amylase. These common substances are the second leading cause of occupational asthma and can also trigger dermatitis.
Flour dust refers to any finely ground particles of cereals and pulses that result from grinding processes and subsequent handling. Additives within the flour are also included as a hazard.
Flour is a respiratory sensitiser; once flour sensitises a worker, even small amounts in the air will cause increasingly severe reactions. Sensitivity is permanent once it happens and will prevent that person from handling flour or being in the vicinity of flour again.
Isocyanates
Isocyanates are a group of chemicals commonly used in the production of polyurethane products such as foams, adhesives, coatings, spray paints, and insulation materials.
Exposure primarily occurs through inhalation or skin contact during manufacturing, application, or removal of products containing these chemicals. Furthermore, the hazards associated with isocyanates can range from mild irritation to severe respiratory issues and even life-threatening conditions.
Who is Going to be Inspected?
The HSE’s business plan states that inspections will take place in businesses that are involved in:
- Commissioning, designing and specifying operations
- Supplying products and equipment, including hiring and maintaining
- Providing competent advice on risks and controls
- Measuring exposure and reviewing protective measures.
This is quite a blanket statement. Businesses likely to be inspected include manufacturers, construction firms, bakeries and millers, and even firms like Synergy, which undertake exposure monitoring.
Exposure Limits for Hazardous Substances
Before detailing the exposure limits for the hazards outlined above, we are keen to stress that these limits are the legal limit and results that fall below them do not guarantee the safety of your employees. Synergy recommends that companies aim to achieve <10% of the workplace exposure limit (WEL) in line with the recommendations of BS EN 689:2018. For a better idea of WELs, read our blog, Understanding Workplace Exposure Limits.
EH40/2005 contains the list of workplace exposure limits for use with the COSHH regulations.
WELs are concentrations of hazardous substances. They are averaged over a specified period, which is referred to as the time-weighted average (TWA). Many WELs have two periods, short-term (15 minutes) and long-term (8 hours). The exposure limits we detail below are measured in milligrams per cubic metre.
Silica Dust Exposure Limits
- Long-term exposure limit: 0.1mg.m3
- Short-term exposure limit: N/A
Because respirable silica is carcinogenic, employers must control it so that it is “as low as reasonably practicable”. Even if exposure is below the exposure limit, companies must use further controls if they are available. They must do this because there is no safe exposure level to carcinogens.
Flour Dust Exposure Limits
- Long-term exposure limit: 10mg/m3
- Short-term exposure limit: 30mg/m3
Despite the provision of a limit, because flour dust is a sensitiser, the HSE requires employers to control it to as low as reasonably practicable (ALARP). This rule applies even if a worker’s exposure is below the limit. If further control measures are available to a company, then they should employ them. Employers must minimise exposure because there is no safe exposure level to sensitisers.
Isocyanate Exposure Limits
Isocyanates, except methyl Isocyanate:
- Long-term exposure limit: 0.02mg/m3
- Short-term exposure limit: 0.07mg/m3
Methyl Isocyanate:
- Long-term exposure limit: N/A
- Short-term exposure limit: 0.02mg/m3
Like flour and silica dust, employers need to control isocyanates to as low as reasonably practicable.
Monitoring Airborne Hazards
Workplace air monitoring is a way to measure whether your controls are adequate. By simply monitoring, you are not satisfying regulations or reducing occupational lung disease. Monitoring should be used to understand the risks and help establish or improve control measures.
Monitoring is appropriate when you need to show compliance with a WEL or to demonstrate that control equipment or personal protective equipment (PPE) is working well enough.
Types of Air Monitoring
Depending on the type of work you do and the equipment used, several methods of air monitoring may be suitable; these include:
- Personal Sampling:
- Workers wear personal air samplers.
- Measures hazard concentration in their breathing zone.
- Provides data on individual exposure and risk.
- Area Sampling:
- Stationary air samplers are placed in work areas.
- Gauges the general air quality and identifies high-concentration spots.
- Assesses overall workplace exposure.
- Real-Time Monitoring:
- Instruments provide immediate feedback on exposure levels.
- It can be worn by workers or placed in an area.
- Enables prompt corrective action.
* A note on real-time silica dust monitoring
The options for real-time silica dust monitoring are limited in terms of direct-reading instruments. Synergy rarely adopts this approach for respirable crystalline silica.
We currently use MDHS 101/2, which is the HSE’s approved gravimetric method for measuring RCS and involves collecting respirable dust on a filter and subsequent analysis by X-ray diffraction (XRD). The advantages of this method are that it provides legally defensible, substance-specific measurement of respirable crystalline silica mass concentration in mg/m³, meets regulatory requirements for compliance monitoring under COSHH and HSE guidance and produces results suitable for comparison with the Workplace Exposure Limits for RCS.
Monitoring Challenges
Calculating exposure limits is a challenge, especially when factoring in time-weighted averages and the duration that someone is exposed to the hazards. Monitoring challenges include:
- Exposure Variability: Levels of airborne hazards vary greatly by job and even within the same role, making monitoring complex.
- Sampling Duration: Selecting the right sampling time is key; too short misses fluctuations, and too long can be impractical.
- Detection Limits: Accurately detecting low levels of hazards, especially with other dust sources present, is challenging but crucial.
- Instrument Calibration: Regular calibration and maintenance of monitoring instruments are essential for accurate measurements.
- Worker Compliance: Ensuring workers consistently use samplers and follow safety practices requires education and enforcement.
- Data Interpretation: Occupational hygienists must accurately interpret collected data to understand worker exposure and health risks.
Health Surveillance
Health surveillance is necessary when:
- Exposure at work can be directly connected to a specific disease or health condition (eg Asthma, Dermatitis, Cancers).
- It is possible to detect illnesses early and reduce potential harm.
- Conditions in the workplace are likely to cause illness (monitoring results may highlight this need).
Health surveillance is a systematic process of monitoring workers’ health for early signs of work-related illness. It’s more than just a test; it’s about proactively protecting employees from occupational hazards.
For instance, this could involve regular checks on lung function for those exposed to respiratory irritants, or skin condition assessments for workers handling certain chemicals.
Taking Action
Simply conducting tests isn’t enough. Employers must ensure the results are properly interpreted by a competent professional. Crucially, this interpretation must lead to action, whether that is eliminating the exposure, implementing further controls, or, if necessary, redeploying affected workers to prevent further harm.
Using Occupational Health Professionals
Health surveillance should be carried out by a qualified occupational health professional, such as a doctor or nurse specialising in workplace health.
While individual clinical outcomes remain private, the service provider will interpret these for each worker. They’ll also supply general, anonymised data to help employers maintain up-to-date health records and identify broader health trends within the workforce.
At Synergy, we provide a range of health surveillance services including spirometry, skin surveillance, urinalysis and biological sampling.
Controlling Exposure
A key tool for controlling air hazards is the hierarchy of control. The hierarchy of control prioritises control measures from most effective to least:
- Elimination: The most effective step is to remove the hazardous substance entirely from the workplace.
- Substitution: If elimination isn’t possible, replace the hazardous substance with a safer alternative.
- Engineering Controls: When elimination or substitution isn’t feasible, implement physical controls like Local Exhaust Ventilation (LEV) to reduce exposure at the source.
- Administrative Controls: If engineering controls aren’t enough, introduce procedural methods such as safe work practices, job rotation, or restricted access to limit exposure.
- Personal Protective Equipment (PPE): As a last resort, if all other methods are insufficient, provide PPE, such as respirators, to protect individual workers.
Everyone Plays a Part in Safety
Beyond effective controls and monitoring, a crucial element in maintaining a safe workplace is comprehensive employee training.
Workers must receive clear, ongoing instruction on potential hazards, safe work procedures, and the correct use and maintenance of all equipment, including Personal Protective Equipment (PPE). Employees can then understand risks, make informed decisions, and actively contribute to their safety and that of their colleagues.
Employees have a responsibility to apply this training diligently, use the provided equipment as instructed, and report any concerns or defects, ensuring that safety is a shared commitment rather than solely an employer’s burden.
Need Help? Contact Synergy
Need to prepare for an HSE inspection? Synergy Environmental Solutions can help. Our team of BOHS-qualified consultants brings expert knowledge of COSHH Regulations and uses state-of-the-art equipment for all your workplace air monitoring needs – personal, area, and real-time.
We also offer Local Exhaust Ventilation (LEV) testing and servicing, alongside comprehensive health surveillance to ensure full worker welfare and regulatory compliance.
