Kicking off the session, legal expert Duncan Reed from Birketts offered an overview of the risk landscape, firstly setting out how legal risks in food production broadly fit into two categories – civil and regulatory.
Understand your risks
He explained that operators have more control over civil risks which can arise from contractual relationships with supply chain partners as well as claims from customers, retailers, wholesalers and employees.
These kinds of claims often start with a formal letter and usually can be managed in a more controlled way, including settlement and confidentiality.
Regulatory risks on the other hand involve bodies such as the Trading Standards, the Health and Safety Executive, and the Food Standards Agency. In the most severe cases they can involve fatalities and police intervention.
Reed explains that once regulators are involved, companies lose control over both process and outcome - with enforcement often slow.
Regulators also have extensive powers, including the ability to impose financial penalties. These are linked to turnover, so the larger the organisation, the higher the financial penalty will be.
In addition, Reed flagged the risk of individual liability, which can impact directors and offices if an offence is committed with consent, connivance or neglect.
“Management oversight, board oversight of operations, and the controls and measures they should put in place to protect against risks arising from those is something that definitely cannot be underestimated,” he noted.
To emphasise his points, the legal expert set out some recent examples of health and safety failings, highlighting that the common denominator was that the risk assessment in place was found to be lacking or insufficient.
“One of the things that you can do as an operator to try and control the legal risks arising from production is to keep on looking at the risk assessments and ensuring that they’re adequate for the purposes and the operations that are taking place," he said.
Weetabix’s hygiene transformation
Drilling down into a particularly risky hidden hazard, Dave Heathcote, industrial vacuum specialist from Nilfisk, talked through the challenge of dust.
“Most companies using dry powder food ingredients will find that they have combustible dust in some shape or form,” the cleaning expert said.
“The go-to method, as it is in my house, would be to grab a sweeping brush, push it away and say job done and move on. That may look good...from the outside it looks as though the area is clean, but typically you have pretty much removed, let’s say, 80-90% of the dust.”
The remaining very fine dust – often invisible to the naked eye – has simply been pushed back into the atmosphere and is now floating around, making its way onto surfaces around the factory.
Weetabix had been previously relying on brushes in its own hygiene routine.
“For decades, floor brushes have been a staple of hygiene practice across all of our plants,” Adrian Watts, hygiene improvement manager for Weetabix told webinar viewers.
“While routine monitoring of airborne particles showed that it stayed significantly below the workplace exposure limit – and we always have respiratory protection in place during dry cleaning activities – audits showed that there was an increase in dust disturbance during the cleaning window.”
The hygiene transformation team – which Watt is part of and that looks at best practice, current practice and horizon scanning for hygiene practices – was tasked with finding an alternative.
This process saw the business moving from brushes to squeegees and vacuum based cleaning provided by Nilfisk.
For Weetabix, this transition was not just a procedural update, it was a cultural shift and technical challenge that ultimately led to a major improvement in workplace safety.
Cultural change is far harder than procedural change. People revert to familiar methods, especially in high pressure environments, and one of our biggest obstacles was behaviour.
Adrian Watts, hygiene improvement manager for Weetabix
“During the early audits of the changes that we were making, we observed that some colleagues would hide brushes so that they could use them when they thought no one was looking. That wasn’t malicious, it’s just human nature to want to carry on in the way that you’ve always done things,” explained Watts.
“People are inclined to stick with what works for them, especially if they’re not yet convinced that the new method is better. Now, recognising this early on allowed us to adopt a slightly more supportive and a coaching based approach, rather than a punitive one.”
