Division 32 brings together a range of small-scale and bench manufacturing trades — making jewellery and related articles, musical instruments, sports goods, games and toys, medical and dental instruments and supplies, brushes, and other goods not classified elsewhere. They share a workshop character: benches, machinery, hand and power tools, and often hot work, soldering, plating, casting and finishing. Whatever you make, the duties in this guide apply to running the workshop and employing people. Get this spine in place first, then deal with the product rules for what you sell.
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. Risk-assess your benches, machinery, hot work and chemical processes, provide safe systems of work, and train and supervise your people.
B. Control hazardous substances (COSHH)
Workshops across the division use hazardous substances — solders and fluxes, electroplating and pickling chemistry, casting fumes, lacquers, adhesives, resins and dusts. The Control of Substances Hazardous to Health Regulations 2002 (COSHH) require you to assess, then prevent or adequately control, exposure — often with local exhaust ventilation (with statutory thorough examination), respiratory protection and health surveillance where the regulations require it. In Northern Ireland the equivalent COSHH (Northern Ireland) Regulations 2003 apply.
C. Keep your work equipment safe (PUWER)
Your work equipment — presses, lathes, polishing and grinding wheels, saws, injection-moulding machines, kilns and CNC tools — must be suitable, properly maintained, inspected and adequately safeguarded under the Provision and Use of Work Equipment Regulations 1998, and used only by trained operators.
D. Manage manual handling
Moving raw stock, dies, finished goods and packed cartons carries manual-handling risk, 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 handling aids and safe systems of work.
E. Manage fire safety
Flammable finishes, solvents, dust and hot-work processes give many of these workshops 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 benches, machinery, hot work and chemical processes, and put safe systems of work, training and supervision in place under HASAWA 1974.
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2. Put COSHH controls in for your substances
Assess solders and fluxes, plating and pickling chemistry, casting fumes, lacquers and dusts; control exposure with ventilation and health surveillance where COSHH requires it.
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3. Bring work equipment into a PUWER regime
Make sure presses, lathes, polishing and grinding wheels, moulding machines and tools are guarded, maintained, inspected and used only by trained operators.
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4. Control manual handling and carry out your fire risk assessment
Reduce hazardous handling of stock and finished goods; assess fire risk from finishes, solvents, dust and hot work 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 running the workshop and employing people. On top of it sit the product rules for what you make:
- Follow Place jewellery, toys, medical devices and other goods on the market for the product-conformity regime that fits your products.
- Confirm you have covered everything with the other manufacturing compliance checklist.
Official sources
Authoritative health and safety and data-protection guidance.