Tobacco Manufacturing UK-wide

Set up and run a safe tobacco factory

Tobacco processing is machinery- and dust-intensive: conditioning, cutting, drying, blending, rolling and packing, using casing and flavouring chemicals. Whatever you make, this is the universal spine. It takes you through your core workplace health and safety duties, control of hazardous substances and tobacco dust, work equipment safety, manual handling, fire safety, employers' liability insurance, equality and data protection.

Guide summary

You must assess and control risks from machinery, dust, and chemicals in your tobacco factory. Meet your general health and safety duty under the Health and Safety at Work Act and follow COSHH rules to control hazardous substances. Work through all sections of this guide first, then add tobacco-specific product and track-and-trace rules.

  • Assess risks from machinery, dust, chemicals, and manual handling
  • Provide safe systems of work and train your employees
  • Control tobacco dust and chemicals under COSHH regulations
  • Install local exhaust ventilation on dust-generating machines
  • Provide health surveillance where risk assessment requires it
  • Get employers' liability insurance
  • Follow fire safety rules for your factory
  • Comply with equality and data protection laws
  • Work through all sections of the guide in order
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Related guides in Employment & HR

Processing tobacco — conditioning and stripping leaf, cutting, drying, blending, casing and flavouring, rolling and packing — is machinery- and dust-intensive. The duties in this guide are not specific to the tobacco product itself. They apply to running the factory and employing people. Get this spine in place first, then layer the tobacco-specific product, duty and track-and-trace 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 tobacco plant that means risk-assessing the machinery, the dust, the casing and flavouring chemicals and the material handling. It also means providing safe systems of work, and training and supervising your people.

B. Control exposure to hazardous substances (COSHH)

The Control of Substances Hazardous to Health Regulations 2002 (COSHH) require you to assess, then prevent or adequately control, exposure to hazardous substances. In tobacco manufacturing that means respirable tobacco dust generated by cutting and processing, and the casing and flavouring chemicals you add. Provide engineering controls — local exhaust ventilation on dust-generating operations — 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 machinery — cutting and shredding lines, drying plant, primary processing, cigarette-making and packing machines — must be suitable, properly maintained, inspected and adequately safeguarded under the Provision and Use of Work Equipment Regulations 1998. High-speed making and packing machinery and in-running nips are recurring guarding concerns, and equipment must be isolated for cleaning and unblocking.

D. Manage manual handling

Moving bales and cases of leaf, reels of packaging and finished-product cases is routine, 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

Dried tobacco and tobacco dust are combustible, giving tobacco processing and storage an elevated fire load. The responsible person must carry out a fire risk assessment and maintain fire-safety arrangements. The duty is devolved. In England and Wales the Regulatory Reform (Fire Safety) Order 2005 applies. In Scotland the Fire (Scotland) Act 2005 and Fire Safety (Scotland) Regulations 2006 apply. In Northern Ireland the Fire and Rescue Services (Northern Ireland) Order 2006 applies.

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. You must also 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. In most cases, you must also pay the data protection fee to the Information Commissioner's Office (ICO). This applies UK-wide.

  1. 1

    1. Write your health and safety risk assessments

    Assess conditioning, cutting, drying, blending, making and packing, and put safe systems of work, training and supervision in place under HASAWA 1974.

  2. 2

    2. Put COSHH controls in for tobacco dust and casing chemicals

    Assess respirable tobacco dust and casing/flavouring substances. Fit local exhaust ventilation and arrange health surveillance where COSHH requires it.

  3. 3

    3. Bring work equipment into a PUWER regime

    Make sure cutting, making and packing machinery is guarded, maintained, inspected and safely isolated for cleaning and unblocking.

  4. 4

    4. Control manual handling and carry out your fire risk assessment

    Reduce hazardous handling of leaf, packaging and product. Assess fire risk from dried tobacco and dust under the regime for your nation.

  5. 5

    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 of running the factory and employing people. On top of it sit the tobacco-specific product, duty and supply-chain rules:

Official sources

Authoritative health and safety and data-protection guidance.