Ten years ago the answer was reasonably predictable: guarding, work at height, forklift segregation. Those still matter enormously. But the regulator’s centre of gravity has shifted, and manufacturers who have prepared only for the traditional safety inspection are increasingly being caught out by questions they were not expecting.
The shift towards occupational health
The numbers explain the change. In 2024/25, an estimated 1.9 million working people in Great Britain were suffering from a work-related illness. Around 964,000 of them had work-related stress, depression or anxiety, and 511,000 had a work-related musculoskeletal disorder. Across the same period, 40.1 million working days were lost to work-related illness and workplace injury.
Set that against acute injury. Provisional figures for 2025/26 recorded 126 workers killed in work-related accidents — the lowest annual total the HSE has recorded. Serious injury has not been solved, but the long-term trend is downwards. Occupational ill health has not followed the same curve.
The HSE’s response has been to rebalance its inspection effort. Of the 13,200-plus inspections it completed in 2024/25, more than 7,000 focused on work-related health risks. Three themes dominate for manufacturing: noise, musculoskeletal disorders, and respiratory risk.
What an inspector will actually examine
Respiratory risk and dust
Expect questions about any process that generates dust, fume, mist or vapour — welding fume, wood dust, flour, metalworking fluid mist, silica from cutting or grinding, and solvent vapour.
Inspectors are looking for a COSHH assessment that reflects the actual process rather than a generic template, and for controls that work in practice. Local exhaust ventilation is a common failure point: an LEV system that was correctly specified five years ago but has since had ducting modified, a hood repositioned, or a fan quietly degrade. LEV requires a thorough examination and test at least every 14 months under COSHH Regulation 9, and inspectors will ask to see the reports.
Where respiratory protective equipment forms part of the control strategy, they will ask about face fit testing, and whether the equipment is being maintained, stored and worn correctly. RPE selected without face fit testing is one of the most common findings on a health-focused visit.
Noise
Under the Control of Noise at Work Regulations 2005, the lower exposure action value is a daily or weekly personal exposure of 80 dB(A), and the upper action value is 85 dB(A). There is an exposure limit value of 87 dB(A) taking hearing protection into account.
Inspectors will want to see a noise assessment carried out by someone competent, evidence that you have reduced noise at source where reasonably practicable rather than defaulting to hearing protection, hearing protection zones that are properly marked and enforced, and health surveillance where employees are regularly exposed above the upper action value.
The recurring finding here is a business that issues ear defenders, considers the matter closed, and has never assessed whether a quieter tool, a damping panel or a process change would have removed the problem entirely. Personal protective equipment is the last resort in the hierarchy of control, not the first response.
Musculoskeletal disorders
Manual handling, repetitive work, awkward postures and poorly designed workstations. The HSE’s stated position is that it wants to see preventative controls embedded in day-to-day operations, not simply documented.
That means an inspector is unlikely to be satisfied by a manual handling risk assessment in a folder. They will watch the job being done. If operators are reaching across a conveyor, lifting from floor level repeatedly, or holding a tool in a sustained awkward grip, they will ask what has been done about it and why.
Hand-arm vibration
Where powered hand tools are in regular use, the Control of Vibration at Work Regulations 2005 set an exposure action value of 2.5 m/s² A(8) and an exposure limit value of 5 m/s² A(8). Inspectors will look for exposure calculations based on real trigger times rather than manufacturer’s declared values alone, tool selection and maintenance regimes, and health surveillance for exposed employees.
And still, machinery
None of this displaces the traditional priorities. Regulation 11 of the Provision and Use of Work Equipment Regulations 1998 requires effective measures to prevent access to dangerous parts of machinery, and it continues to generate prosecutions.
In July 2026, Easy Cleaning Solutions Ltd was fined £100,000 with costs of £6,468.18 at Norwich Magistrates’ Court after a worker’s hand was caught in an unguarded conveyor while they removed a cardboard box from the running machine. HSE inspector Paul Shackleton described it as “a wholly avoidable incident caused by the failure to guard dangerous parts of machinery.”
The pattern in guarding cases is consistent and worth stating plainly: the failure is rarely that no guard was ever fitted. It is that a guard was removed for maintenance and not replaced, an interlock was defeated to keep production moving, or a modification created a new access point that nobody reassessed.
Stress and psychosocial risk
A newer area, and one many manufacturers have not yet addressed.
The HSE has signalled that it intends to treat failure to manage psychosocial risks with the same seriousness as physical safety failures, and to address psychosocial risk alongside physical risk during routine inspections. The framework it expects employers to work to is the six Management Standards: demands, control, support, relationships, role and change.
This is not a wellbeing initiative. Work-related stress falls within the general risk assessment duty under Regulation 3 of the Management of Health and Safety at Work Regulations 1999, and the HSE’s Working Minds campaign is explicit that employers have a legal duty here. Shift patterns, workload during peak periods, and how change is communicated during restructuring are all legitimate subjects for an inspector’s questions.
What happens if they find something
If an inspector identifies a material breach of health and safety law — one serious enough that they write to you about it — the HSE recovers its costs under the Fee for Intervention scheme at £188 per hour from 1 April 2026. That covers investigation, correspondence and follow-up until the matter is resolved.
Beyond that sit improvement notices and prohibition notices. In 2024/25 the HSE issued around 4,400 enforcement notices: approximately 3,200 improvement notices and 1,200 prohibition notices. A prohibition notice stops the activity immediately, which for a single-line production facility can be considerably more expensive than any fine.
Preparing properly
A realistic preparation exercise for a manufacturing site looks like this:
- Walk the floor as an inspector would. Not the tour you give customers. Look at the machine that was modified, the LEV hood that was moved, the guard with the tape residue on it.
- Test your paperwork against reality. Pick three risk assessments at random and check whether they describe what actually happens now.
- Check your examination and test records. LEV within 14 months, lifting equipment under LOLER, pressure systems, local ventilation, portable appliances.
- Confirm your health surveillance is running. Noise, vibration, respiratory, skin. Identify who is in scope and when they were last seen.
- Verify your controls at source. For each significant health risk, ask what has been done above the level of PPE. If the answer is nothing, that is your gap.
- Look at the maintenance interface. Most guarding incidents happen during setting, cleaning, clearing blockages or maintenance. Check that safe systems of work exist for those tasks specifically.
Soteria (UK) Ltd provides practical, sector-experienced health and safety support to manufacturers across the UK and Ireland. Our consultants are Chartered Health and Safety Practitioners registered on the OSHCR, and our Annual Fixed Fee service gives you proactive support with a named consultant rather than a report and an invoice.
Call 01925 626283 or email info@soteriauk.co.uk.
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