Making non-metallic mineral products — glass, ceramics, bricks and tiles, cement and lime, concrete products and cut stone — is machinery-intensive and generates a great deal of dust, much of it containing respirable crystalline silica. The duties in this guide apply to running the factory and employing people, whatever you make. Get this spine in place first, then layer the product, environmental and emissions rules on top.
Health and safety law here is largely devolved. The Health and Safety Executive (HSE) is the regulator in Great Britain and the Health and Safety Executive for Northern Ireland (HSENI) in Northern Ireland; the underlying duties are equivalent across the UK. Work through the sections below in order.
A. Meet your general health and safety duty
The Health and Safety at Work etc. Act 1974 is the foundation. You must ensure, so far as is reasonably practicable, the health, safety and welfare of your employees and of anyone else affected by your work. In a mineral products plant that means risk-assessing kilns and furnaces, crushing, grinding and mixing plant, hot and molten material, dust and material handling, providing safe systems of work, and training and supervising your people.
B. Control respirable crystalline silica and other substances (COSHH)
Respirable crystalline silica (RCS) is the defining health hazard in this sector — generated wherever you cut, crush, grind, screen or handle silica- bearing minerals such as sand, stone, clay and cement. The Control of Substances Hazardous to Health Regulations 2002 (COSHH) require you to assess, then prevent or adequately control, exposure, with engineering controls — local exhaust ventilation, water suppression and enclosure — and health surveillance where the regulations require it. The same duties cover cement and lime (skin-burn and alkali risks), furnace fume, and any glazes, colourants and binders you use. In Northern Ireland the equivalent COSHH (Northern Ireland) Regulations 2003 apply.
C. Keep your work equipment safe (PUWER)
Your machinery — kilns and furnaces, crushers, mills and screens, presses, mixers and conveyors — must be suitable, properly maintained, inspected and adequately safeguarded under the Provision and Use of Work Equipment Regulations 1998. Guarding of crushing and grinding plant, conveyor nips and access, and safe isolation for clearing blockages and maintenance are recurring enforcement themes. Lifting plant reads across to LOLER 1998.
D. Manage manual handling
Moving raw-material bags, moulds, kiln furniture, finished blocks, slabs and glass is routine and often heavy, so the Manual Handling Operations Regulations 1992 apply. Avoid hazardous manual handling so far as is reasonably practicable; where you cannot, assess the risk and reduce it — through lifting equipment, better layout and safe systems of work.
E. Manage fire safety
High-temperature processes, fuels, dust and combustible packaging give mineral products manufacturing a real fire load. The responsible person must carry out a fire risk assessment and maintain fire-safety arrangements. The duty is devolved: the Regulatory Reform (Fire Safety) Order 2005 in England and Wales; the Fire (Scotland) Act 2005 and Fire Safety (Scotland) Regulations 2006 in Scotland; and the Fire and Rescue Services (Northern Ireland) Order 2006 in Northern Ireland.
F. Hold employers' liability insurance
As soon as you employ anyone, you must hold employers' liability compulsory insurance — normally at least £5 million of cover — and display or make available the certificate. This is a legal requirement across Great Britain, with an equivalent duty in Northern Ireland.
G. Meet your equality duties
As an employer you must not discriminate against, harass or victimise people because of a protected characteristic. In Great Britain this is governed by the Equality Act 2010; in Northern Ireland separate equality legislation applies, enforced by the Equality Commission for Northern Ireland.
H. Handle personal data lawfully
If you process personal data — about staff, customers or suppliers — you must comply with the UK GDPR and the Data Protection Act 2018, and in most cases pay the data protection fee to the Information Commissioner's Office (ICO). This applies UK-wide.
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1. Write your health and safety risk assessments
Assess kilns and furnaces, crushing and grinding, mixing and handling, dust and hot material, and put safe systems of work, training and supervision in place under HASAWA 1974.
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2. Put silica and substance controls in under COSHH
Assess respirable crystalline silica from cutting, crushing and handling, plus cement, fume, glazes and binders; fit local exhaust ventilation and water suppression and arrange health surveillance where COSHH requires it.
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3. Bring work equipment into a PUWER regime
Make sure kilns, crushers, mills, presses and conveyors are guarded, maintained, inspected and safely isolated for clearing blockages and maintenance.
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4. Control manual handling and carry out your fire risk assessment
Reduce hazardous handling of heavy materials and product; assess fire risk from high-temperature processes, fuels and dust under the regime for your nation.
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5. Take out employers' liability insurance and register with the ICO
Arrange at least £5 million of cover before anyone starts work, and pay the data protection fee unless you are exempt.
What to do next
This spine covers the duties every mineral products manufacturer shares. On top of it, the rules depend on what you make and how energy-intensive your process is:
- If you place products on the market — construction products or consumer goods — follow Place non-metallic mineral products on the market.
- If you run a cement, lime, glass or ceramics kiln or furnace, follow Meet your environmental permit and emissions trading duties.
- Confirm you have covered everything with the compliance checklist.
Official sources
Authoritative health and safety, silica and data-protection guidance.