More than 23,000 overseas nationals are believed to work in the UK food and drink manufacturing sector. Often highly educated, qualified and skilled, they are an invaluable resource to an industry that is blighted with labour shortages at all levels.
But they can also be a health and safety manager's nightmare.
A few years ago, ensuring that safety signs and training materials were understood meant translating them into a couple of other languages, says Greencore safety and health co-ordinator Tom Chambers. Today, he says, it's a whole different ball game.
"The UK is getting an influx of labour from all over the world, most recently from the European Union accession countries. Ensuring that everyone understands what we're telling them is becoming considerably more difficult."
Take safety glasses, he says. "We brief staff in their appropriate language, have pictorial signs and ensure that supervisors check that they are being worn. However, it is still a challenge to satisfy health and safety inspectors that staff understand that they must be worn in a particular area. Is a picture of safety glasses enough, or do you need to translate 'Put on your safety glasses!' into 20 languages? If so, you need a bloody big sign."
At the moment, there is no clear guidance for manufacturers on this issue, he says.
You may, for example, employ 100 staff: 50 of them English, 20 Portuguese, 20 Polish and the rest from all over the world. Is it OK just to translate formal training materials into Polish and Portuguese, with this then translated verbally during training sessions for the remainder, or do you have to translate everything in writing for everyone else as well, he asks. What percentage does there need to be of one nationality before you have to do this? And if you don't, what happens if there is an accident and you have relied on verbal translation only?
Pictures are not the complete answer, he claims. Colour coding schemes for days of the week can be helpful, he adds, "but you still have to explain that Monday is yellow"
An equally pressing issue is how you know whether interpreters are telling staff what boxes to fill in on forms, he says. "It's very difficult for a manager that doesn't speak the language to know whether this is happening.
"I really believe that this is one of the biggest health and safety challenges facing the industry over the next five years."
John Nevitt is health and safety manager at Tulip's UK cooked meats division, and like Chambers, is a member of a working group drawing up a code of practice to address the health and safety implications of employing an ethno-linguistically diverse workforce along with the North West Food Alliance, legal firm Eversheds, Uniq and Northern Foods.
In some Tulip plants, more than a third of staff do not speak any English, he says. "We have been very proactive with ESOL (English for speakers of other languages) courses, translating key documents, pictograms and so on. But so much gets lost in translation."
Cultural awareness is also crucial to foster good working relationships, and many companies are looking at prayer facilities and food provision very carefully, says Northern Foods internal communciations manager Debbie Sutton. Managers at Fox's Biscuits have been on an Islamic awareness course, for example.
Conflicts can also arise when staff have come from countries where men and women do not have equal rights, adds Tulip's Nevitt. "Some Iraqi men don't like taking instructions from a female supervisor or translator, for example. Staff from some other countries think it's OK to drink [alcohol] at lunchtime. Having said that, there are very few things that a game of football and a curry won't solve."
While a curry might resolve a shopfloor dispute, however, it won't help you in court if you are found to have breached health and safety, racial discrimination or asylum and immigration laws, points out Naeema Choudry at legal firm Eversheds. "There can be a conflict between health and safety and discrimination legislation. If, for example, for health and safety reasons, you select a Portuguese speaker over another equally capable candidate for a job that involves supervising lots of Portuguese staff, you could be accused of discrimination."
The issue of whether manufacturers are able to stipulate that candidates must speak English is also a thorny one. Memory Lane Cakes, for example, asks new recruits to sit a basic English test, which it claims is justified on health and safety grounds.
Whether a tribunal accepts these grounds is a different matter, says Chris Baker, an employment law expert at legal firm DLA Piper. "This could put you in breach of the Race Relations Act. You would have to demonstrate that the cost of ensuring that non English speakers are properly trained would be disproportionate. And for a large company, that's actually quite hard."
Having said that, many employers would not get any applicants at all if they imposed such entry requirements, points out Paul Burnley, head of corporate defence at DLA Piper's Leeds office. Far better, he says, to employ something like a buddy system that pairs up a recruit with little or no English with an English-speaking employee, who then reports back to bosses as to whether the new recruit can understand the training and safety information. "But clearly, not every company has the resources to do this."
Halo Training founder John Craig predicts that interactive training materials that demonstrate equipment functions, cleaning and maintenance, and health and safety information via videoclips and animations will become increasingly popular as companies employ more staff that do not have a strong command of English.
Ultimately, companies will just have to find new ways to communicate, says John Nixon, skills development director at food sector skills council Improve.
"Labour shortages at all levels in food and drink manufacturing are not being filled by the indigenous population. There are villages in some parts of Wales where a large percentage of the local people are actually out of work and claiming benefits and yet local food manufacturers are having to ferry in workers from Portugal. That's just the way it is." FM
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